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SecondQuarter l
PerformanceReport 9
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JULY 1998 i
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MILLSTONE STATION UNIT 3 Second Quarter Performance Report
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JULY 1998 l
 
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TABLE OF CONTENTS I
V Second Quarter Performance Report 1.
Performance Monitoring Report - Introduction.......................................1
: 11. Perfo rm an ce on Key i s s u e s...........................................................................
i 1. L e a d e rs h i p..................................................................................
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: 2. Safety Conscious Work Environment................................................ 8 j
: 3. S elf-As s e s s m en t................................................................................ 14
: 4. C o rre ctiv e Acti o n................................................................................ 1 6 5. O v e rs i g h t........................................................................................... 2 0
: 6. Config u ration M ana g em ent................................................................ 24
: 7. R eg ulato ry Com plianc e..................................................................... 29 8. T rai n i n g............................................................................................. 3 9
: 9. Ope rational P e rfo rm ance................................................................... 4 2
: 10. Wo rk Cont rol an d Plan ning................................................................ 47
: 11. Proced u re Quality and Adherence..................................................... 50
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: 12. E m e rg e n cy Pl an nin g.......................................................................... 5 3 l
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: 13. Radiological P rotectio n...................................................................... 57 1 4. S e c u ri ty............................................................................................. 61
: 15. Environ montal C omplia nce................................................................ 65 Appendix 1 Key Performance Indicators Millstone Unit 3 Safety Conscious Werk Environment Oversight Procedure Compliance and Quality AdditionalCorrective Action /Self-AssessmentIndicators Nuclear Training Culture and Leadership Radiological Protection Security Additional Work Control Configuration Management
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Additional Operational Readiness
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PERFORMANCE REPORT i
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Introduction The successful efforts throughout the station which have raised performance for each of the sixteen Key issues to a standard supporting restart authorization must be maintained in the future. For each Key Issue, significant accomplishments were achieved through extensive, dedicated efforts. This level of performance is being sustained by carefully tracking the designated key performance indicator (KPI) data, supplementing the on-going efforts with directed self-assessments, and taking appropriate action if performance fails to meet or exceed management expectations.
' NSAB performance will be assessed by the Nuclear Group CEO. For each of the remaining 15 Key Issues previously established Success Criteria for recovery, related self-assessments planned for 1998 are listed, and the corresponding performance measures, including Key Performance Indicators (KPis), are identified.
I Success Criteria, modified to define sustaining performance, are included to reiterate l
the baseline for future performance. KPis provide an important indication of performance. He key concept is that KPis are a tool to:
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. Identify areas requiring focus or additional management attention; J
Identify barriers to success; and Identify improvement strategies.
Management uses the KPis to monitor performance against goals and expectations and to determine the need for remedial action. Reviews of the indicators are regularly performed. When performance is not meeting established standards or goals, the responsible individual provides an analysis as to why performance is deficient and takes action to bring performance back to the specified standard. KPis are provided l
weekly to Millstone senior management and monthly to the NU Board of Trustees.
Assessments are conducted routinely to verify acceptable performance and validate the information presented in the KPls. These self-assessments include, but are not limited to, those currently planned during 1998. Assessment topics may be added, substituted, deleted, or rescheduled as circumstances dictate during the course of the year. For some Key issues, the list of assessments includes a combination of self-assessments, monitoring activities by Nuclear Oversight, the Nuclear Safety Assessment Board, the Training Advisory Council, and " Window Annunciators".
1 Each of the 15 Key issues will be monitored through the remainder of 1998 and into mid-1999.
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2 Nuclear Oversight Restart Verification Plan 0
During the second quarter of 1998, Nuclear Oversight continued monitoring the progress of Unit 3 recovery following the protocois of the Nucl ear Oversight Restart Verification Plan (NORVP). Key issues were assessed based on a set of attributes derived from NU, NRC and industry documents. Color codes were assigned to each key issue based on a scoring system (0-100) and best judgment. In general, the colors correspond to the following scores: Satisfactory " green" 70-100, Improvement needed
" yellow" 20-69, Significant weakness " red" 0-19. (See KPI C-2)
The following chart summarizes the results of the NORVP for the Key issues for the second quarter of 1998:
Keyissue-NORVP Summary Leadership Leadership was rated as " green," (satisfactory) for all of the second quarter. Oversight noted good management controls for the recent PASS drill and good ownership and interactive dialog during strategic planning meetings. Improvement was needed to refocus line management attention to safety issues.
Self-Assessment Self-Assessment was rated as " green" throughout the second
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quarter. Strengths were noted in the new Environmental Services
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Group self-assessment program and the establishment of an Engineering Quality Review Board. Improvements were noted as being needed in the area of reporting results, not just activities, and following self-assessment outlines.
Safety Conscious Safety Conscious Work Environment improved from a " yellow" Work Environment (improvement needed), rating at the very beginning of the quarter to a " green" for most of the second quarter. Favorable progress was observed in all success criteria with recommendations for improvement noted in increasing line ownership of the Safety Conscious Work Environment process.
Corrective Action Corrective Action for Unit 3 was rated as " green" for the entire second quarter. Highlights included the development of the HP Work Observation program and line management attention to identifying issues. Increased attention was noted as being needed in the area of prioritizing deficiencies on the basis of safety significance.
Oversight Oversight (Recovery) was rated " green" in the second quarter.
Various organizations have shown interest in Nuclear Oversight participation and the role of Oversight in the recovery has been favorably acknowledged at public meetings. More attention was Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\P M-207. DOC
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1 Key lasue NORVP Summary
' O" noted as being needed to a training program for NO personnel.
Configuration Configuration Management was rated as " green" during the Management second quarter of 1998. Pluses were noted in the areas of identifying design inputs. Several productive CM meeungs were held to discuss Safety Evaluation Screenings and the graded approach to Configuration Management.
Procedure Quality Procedure Quality and Adherence was rated " green" during the and Adherence second quarter with several management initiatives designed to continue to enhance procedure effectiveness noted as pluses.
The need to include procedure review as a component of pre-job briefs was noted as an area needing improvement.
Work Control and Work Control and Planning was rated as " yellow" for the first half Planning of quarter but improved to " green" for the second half.
Improvements were noted in reducing preventive maintenance tasks, scheduling on-line activities on time, and reducing the on-line backlog.
Regulatory Regulatory Compliance was rated as " green" throughout the C]/
f Compliance second quarter. Reporting period highlights included the conduct of self-assessments and the closure of SIL packages. An attribute noted as needing attention or continuing improvement included ownership and involvement in safety evaluation screenings.
Emergency Emergency Preparedness was rated as " green" for the entire Preparedness second quarter. Response and call-in drills were conducted satisfactorily. The operability of the PASS system was resolved prior to entry into Mode 2. Oversight noted the need to maintain a
" questioning attitude" conceming the acceptability of equipment associated with the Emergency Plan.
Radiation Radiation Protection was rated as " green" for the entire second Protection quarter. Strengths were reported in the areas of self-assessments and raising standards for the threshold for CR documentation.
Security Security continued to be rated as " green" for the second quarter.
Security was noted as being pro-active in communicating safety and security reminders to the site. Security was noted as needing to maintain site awareness of proper badge control and visitor escort responsibilities.
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Environmental Environmental Monitoring was rated as " green" for the second Protection quarter. Positive attributes included clarifying ownership for Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM 207. DOC
 
4 Keyissue.
NORVP Summary
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V environmental programs and preparing a draft Master Manual covering environmental areas. Weaknesses included the need for better coordination and the need to take action to preclude EPA violations.
Training Training performance improved from " yellow" in the early part of the quarter to " green" at the close of the quarter. Training programs showed an improvement in verification of a number of Corrective Actions associated with a June 1997 audit.
Management expectations were met in the areas of Unit 3 Engineering training and support of rotational assignments with Nuclear Oversight.
Conduct of The Operator Readiness (Operational Performance) issue was Operations alternately rated " green" and " yellow" during the second quarter.
l The latest rating was " yellow" which underscored the attention l
needed to be given to completing corrective actions for I
configuration control events. Additionalline management and Nuclear Oversight attention has been placed on operator performance, and improvements have been noted.
All of the Key Issues were judged to be acceptable for entry into Mode 2 prior to the mode change to Mode 2.
The Nuclear Oversight Restart Verification Plan (NORVP) which addressed recovery issues for Unit 3 is being succeeded by the Nuclear Oversight Verification Plan (NOVP) which will cover recovery, restart and on-going operations at Millstone. The NOVP is designed to provide an integrated and rigorous Nuclear Oversight assessment of the readiness of Millstone to ceniact a safe recovery and reliable and event-free operations. The next quarterly submittal will report the results of the NOVP assessments.
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Key issue: Leadership--
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Success Criteria l
I The following Success Criteria are established and summarize the performance
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baseline for this Key Issue:
l 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
,G The following self-assessments are currently planned for 1998:
b 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 will be used for the on-going monitoring of this Key Issue:
Leadership Assessment Pil Culture Survey Skip-Level Leadership Assessment A
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V Second Quarter Status Leadership Assessment Instruments Assessment Title -
schedule.
Completed Revised Date (Y/N) schedule if Not Complete Nuclear Oversight Restart Bi-weekly Y
Verification Program Report (NORVP)
Leadership Assessment 2nd Y
Quarter Pil Culture Survey 2nd Y
Ouarter Assessment Results Leadership Assessment
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A Leadership Assessment was conducted at Millstone Station during May 1998.
O Results are based on 2066 assessmant forms from both employees and contractors. Preliminary results of the survey show that employee perception of leadership effectiveness has held steady since the survey was last administered
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in November 1997. The overall effectiveness score was 5.76 in May 1998 versus 5.80 in November 1997. (A score between 4 and 5 is considered
" effective." Scores above 6 are evaluated as " superior.")
The leadership scores improved the most from the initial survey in the 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 May 1998 survey with the November 1997 survey in the five l
(5) creas evaluated, j
l The Leadership Assessment revealed several strengths in the ability of l
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 meet regularly with employees and to pay attention to personal development needs.
The May Leadership Assessment included a " skip" level survey to allow l
employees to assess a level of management above their direct supervision. At i
O Millstone, personnel tended to be more positive about their direct supervisor than
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V about their skip level management. The " skip" level measurement resulted in an Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_P E R RR M\\P M-207.D O C l
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7 overall lower score than that obtained for direct supervision, (5.56 vs. 5.76). Full analysis of the results of the " skip" level assessment is on-going.
Culture Survey The Millstone Culture Survey was completed in June 1998. Preliminary results 4
show that the " Culture Index" for Millstone employees has remained above the previously established goal of 13. (Culture Indices range from 1 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 12.67. 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 preliminary results also showed a 3.9 %
l increase with respect to employee perception of the Millstone Safety Conscious Work Environment.
Performance Measures Millstone Station Leadership Assessment KPI G-1 l
e Millstone Station Cultural Survey KPI G-2 e
V Conclusions Leadership Assessments and Cultural Surveys indicate that Millstone is continuing to maintain a focus on leadership and work environment issues.
l Preliminary results show that the gains made during the station recovery are being sustained as the station transitions from recovery to operations.
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8 Key issue: Safety Conscious Work Environment l
l Success Criteria The following Success Criteria were previously established and summarize the performance baseline for this Key Issue:
Demonstrate that employees are willing to raise concerns Demonstrate that management is effective in evaluating, prioritizing and resolving employee issues Demonstrate that the Employee Concerns Program is effective in addressing i
issues raised by employees that are not resolved satisfactorily by other j
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 Maintain a Safety Conscious Work Environment as viewed by the Employee Concerns Oversight Panel Maintain a Safety Conscious Work Environment as viewed by the
[V9 Independent Third Party Oversight Program, established by NRC Order Self-assessments The following self-assessments are currently planned for 1998:
Effectiveness of Selected Employees Concerns Comprehensive Plan Action Items - 1st Quarter Pil Culture Survey - 3rd Quarter Executive Review Board Effectiveness - 3rd Quarter HR Customer Feedback Surveys - 4th Quarter Personnel Performance Reviews - 4th Quarter Continu3us Monitoring by third party - Employee Concerns Oversight Panel j
Leadership Assessment -late 2nd Quarter Performance Measures l
The SCWE infrastructure includes the dedicated SCWE group (including the Key issue Manager), the Employee Concems Program, the Employee Concerns b'
Oversight Panel, and the Human Resources organization for NU Nuclear.
L.J Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RMiPM 207. DOC
 
l 9
i Importantly, each of these four groups work closely together under the direction N
of one Officer. The Independent Third Party Oversight Prograni(Little Harbor (j
l Consultants) will continue to function consistent with the terms of the October, l
1996 Order, and their recommendations and NU's responses are routinely updated. On-going performance monitoring includes:
l Leadership Assessment (SCWE Element)
Culture Survey (SCWE Element)
NU Concerns and NRC Allegations Received, Millstone Station Millstone Employee Concerns Confidentiality Trend, Millstone Station Employee Concern Resolution Timeliness Employee Satisfaction With Employee Concerns Program Focus Area Action Plan Status, Millstone Station Concems Alleging HIRD, Millstone Station Second Quarter Status Safety Conscious Work Environment.
Assessment instruments
,p The following assessments were completed during this period, i.e., second kj quarter of 1998 (April through June 1998). One assessment was scheduled to be
'i completed this quarter (Leadership Assessment), one assessment (Pil Culture Survey) was completed ahead of its scheduled time of 3rd quarter 1998. The individual results of the Culture Survey will be rolled out to the site during the 3rd quarter Both of these assessments contain a specific SCWE element. In addition, LHC provided ongoing assessment during this quarter.
l Assessment Title.
schedule Ccimpleted Revised Date -
(Y/N) schedule if Not Complete -
Leadership Assessment 2nd Quarter Y
1998 Culture Survey 3rd Quarter Y
Completed in 2nd 1998 Ouader LHC Ongoing Assessment Ongoing Y
Assessment Results l
l Leadership Assessment and Culture Survey p
The Culture Survey and Leadership Assessment results show that satisfactory performance is being sustained. The preliminary results show no new areas of concem. Our workforce has become more discerning in this area. In the l
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10 Leadership Assessment and Culture Survey we see our employees providing n
improving scores on SCWE and the Employee Concems Program (ECP). This i
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is an indicator of sustained performance. With all the issues we have faced in getting Unit 3 on-line and reorganizing to support Unit 2, these results show we have improved the ability of the organization to respond and address emerging issues. These results also show that we can sustain initialimprovement and continue to improve. Specific Leadership Assessment results are shown below:
1.eadershio Assessment Overall Results by Cateaorv e Concerns 6.15 Leadership 5.84
* Communications 5.72 Development 5.53 l
Performance Accountability 5.31 Overall Score 5.76 A score of 4 to 5 is evaluated as effective, between 5 and 6 is "very effective" and a score of 6 is evaluated as superior.
77 Specific strengths were identified in the SCWE area:
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ls easy to approach and talk with 6.35 Does what is right 6.34 Respects and cares about me 6.14
* Establishes an environment of trust 6.03
* Gives me a chance to make decisions 6.21 Fosters a supportive workplace environment 6.36 Respects individuals with differing viewpoints 6.20 Will listen to my concerns 6.47 Does not react defensively to my concerns 6.18 Asks for my input to resolve concems 6.07 Would be my first choice to go to 6.35 Demonstrates sensitivity to concerns raised 6.43 The following areas, although still rated effective, were identified as areas for improvement:
+ Meets with me on a regular, ongoing basis 4.89
+ Works with me on personal development 4.62 G'
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m 11 Specific Culture Survey results are still being tabulated and will be rolled out in l
q the third quarter. The overall site SCWE indicator shows that 86.6% of l
t personnel agree that a SCWE exists in their area; this is up from the previous assessment of 82%. Preliminary results show a 3.9% increase with respect to employee perception of the Millstone SCWE, increasing from a rating of 3.07 to 3.19 out of a possible 4.0. The overall adjusted Culture Index for this survey was 12.99. This was divided into 13.17 for NU employees and 12.67 for contractors.
i The " skip" level survey is undergoing analysis to determine results and establish goals.
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I Little Harbor Consultants Assessment LHC's ongoing assessment during this quarter showed steady performance with improving trends in two areas: ECP performance and management's ability to j
deal with HIRD. On July 15,1998, LHC presented the results of their latest formal assessment of SCWE/ECP. LHC cited improved training, particularly the
" Quick Start" leadership training for new leaders, management's response to i
emerging issues, the improved ECP process for evaluating HIRD and l
10CFR50.7 issues, and the reduction of the ECP backlog as contributing to the improved performance ratings. LHC also noted that overall progress continues and that the SCWE had matured much faster than they would have expected, particularly in the HR area.
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;e Finally, we are planning an additional assessment for the second half of 1998 - a
'i self-assessment of leadership training.
Performance Measures Leadership Assessment (SCWE Element) KPI B-1 Goal: At least 90% of supervisors and above are evaluated by their employees through the Leadership Assessment as being an individual to whom employees are willing to raise concerns.
Current Actual: 98.7%. This parameter most directly relates to the first success criterion and the current actual value reflects strong performance.
Culture Survey (SCWE Element) KPI B-2 Goal: At least 90% of total respondents to the Pil Culture Survey agree their i
work area supports a willingness to raise concems.
Current Actual: 86.6%. Improved from 82% in November 1997. Although the current value is not at the long-term goal, we believe that the current level of willingness to express concems in the work environment, coupled with the results of the leadership survey showing a "very effective" rating for management in dealing with employee concerns, and the feedback from the ECOP survey supports a satisfactory rating for this criterion.
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12 Millstone Employee Concerns Confidentiality Trend, Millstone Station KPI (S
B-4
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Goal:There is not an adverse trend in the number of concerns to ECP requesting confidentiality or anonymity.
Current Actual: Less than 35% of concems have been filed anonymously or have requested confidentiality since the beginning of 1998. Based on the June 1998 numbers, the trend appears to be flat with the exception of the March and May numbers. Our analysis of the concems data did not reveal any specific reason why this pattern occurred. ECP monitors this closely for any adverse trend.
NU Concerns and NRC Allegations Received, Millstone Station KPI B-3 Goal: There is not an adverse trend in the ratio of concems received by NU versus the number of allegations received by the NRC.
Current Value: There is no adverse trend. The number of concems received by NU has increased from 15 per month in mid-1997 to approximately 20 per month in the first six months of 1998. During this same period, the number of allegations received by the NRC has decreased from a peak of 12 to an average of four per month.
Employee Concern Resolution Timeliness KPI B-5 Goal: The average age of unresolved concerns does not indicate an adverse trend.
p Current Actual: The average age of unresolved concems has significantly i"j declined from approximately 45 days to 23 days. This shows an improving trend s
in the timeliness of resolving employee concerns.
Employee Satisfaction With Employee Concerns Program KPI B-6 Goal: A substantial majority of employees who have used ECP state they would use it again.
Current Actual: In January 1998, seventy-five (75%) of employees surveyed by ECOP stated that they would use the process again. January 1998 feedback from Little Harbor Consultants indicates that 83% of those surveyed would use the ECP again. In March 1998, the Employee Concems Oversight Panel conducted a survey that concentrated on personnel who had used the program in the last six months. This survey indicated 90% of the people surveyed would use the program again. This is particularly significant because ECP did not substantiate a number of the respondents concerns. These personnel stated that they felt they had been treated well and would use the program in the future.
Additional second quarter data indicates this level of satisfaction continues.
Focus Area Action Plan Status, Millstone Station KPI B-7 l
Goal: The number of areas where it has been determined that one or more of I
the attributes of a Safety Conscious Work Environment is challenged or lacking does not indicate an adverse trend.
p Current Actual: The cumulative number of " focus areas" from program inception j
to June 30,1998 is 33. Of these,26 areas have had their action plans completed Millstone Station / Unit 3 Second Quarter Performance Report j
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i 13 and closed. Six of the 25 are awaiting independent effectiveness reviews. The remaining 7 are in progress. These focus areas were assessed to identify r(rm']
potential barriers to Unit 3 restart. The results of this assessment indicated that these focus areas presented no barrier to Unit 3 restart. NU has added personnel I
trained in organizational behavior to increase attention to this area. In many cases, proactive responses to potential " focus areas" have successfully prevented the creation of new " focus areas." We believe we have prevention and detection occurring with increasing frequency and remediation of areas that have been allowed to occur declining in frequency.
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Concerns Alleging HIRD, Millstone Station KPl B-8 Goal: The number of concerns alleging HIRD does not show an adverse trend Substantiated 10CFR50.7 concerns are infrequent and handled responsibly.
Current Actual: The number of concems alleging 10CFR50.7 HIRD continues to trend downward. There have been no substantiated concerns involving alleged violations of 10CFR50.7 since August 1997.
Conclusions Our performance monitoring and second quarter assessments demonstrate steady, improving performance, with no indication of any backsliding. We continually look for areas to refine and improve. Our workforce is not only empowered in the area of SCWE, it is also well educated, maturing, and more l
lp capable of responding to emerging events.
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14 f3d Key lasue:cSelf-Assessment-l Success Criteria The following Success Criteria wera previously established and summarize the performance baseline for this Key Issue:
Achieve greater than 90% of self-identified issues No programmatic issues identified by intemal and/or external oversight Self-Assessments The following self-assessments are currently planned for 1998:
Station Self-Assessment Program Quarterly Performance " Windows" Conduct of Self-Assessment Nuclear Oversight Restart Verification Plan (NORVP)
I Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:
Condition Report Method of Discovery - By Unit
/O V
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15 O
Second Quarter Status
.Self-Assessment.
Assessment Instrument Assessment Title schedule Completed
- Revised -
Date (Y/N) schedule if Not.
Complete Quarterly Self-Assessment of June 1998 Y
Performance " Windows" OSTl-NRC Inspection Report April 1998 Y
50-423/97-83 Assessment Results The following summarizes the results of the self-assessment activities:
In June 1998, the Millstone Performance Windows assessment rated self-assessment as satisfactory as compared to the INPO 97-002 criteria.
NRC Operational Safety Team inspection (OSTI) noted at the May 5,1998 V
exit meet;ng that "... Self-Assessment programs have been significantly strengthened and are acceptable for restart."
Performance Measures Condition Report Method of Discovery - Unit 3 KPI A-2: The Unit 3 performance data was negatively affected by the number of ICAVP Discrepancy Repart CRs. Since June 3,1998, externally generated CRs have decreased and self-identified issues have achieved the goal of greater than 90% As of July 1, 1998 self-identified issues are 94% of the total Unit 3 CRs.
Conclusions An environment reflecting a questioning attitude and self-identification at Millstone continues to improve. The self-assessment program and performance are determined to be at a satisfactory level to support the safe operation of Unit 3.
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Key lasue: Corrective. Action" d
i Success Criteria l
l The following Success Criteria are established and summarize the perfonnance baseline for this Key Issue:
I Demonstrate that a low threshold exists for identifying conditions adverse to l
quality by increasing the ratio of Level 2 and 3 CRs to Level 1 CRs The ratio of self-identified to extemally identified conditions adverse to quality continues to increase i
High quality corrective action plans are provided within 30 days of l
e identification Corrective actions are completed in accordance with a schedule established in the action plan Corrective actions are effective in resolving the issuo Adverse trends are resolved in six months of identification and do not recur O
Self-Assessments O
The following self-assessments are currently planned for 1998:
Monthly Unit Trend Reports Quarterly Unit Trend Reports Quarterly Station-wide Integrated Trend Report Quarterly Self-Assessment of each unit Corrective Action Program Annual Assessments of each department corrective action performance Semi-Annual Nuclear Oversight Corrective Action Program Audit Nuclear Oversight Restart Verification Plan (Monthly)
HPES Effectiveness - 2nd Quarter Operating Experience Program Effectiveness - 3rd Quarter Station Corrective Action Program Effectiveness - 3rd Quarter Performance Measures l
Trend reports track corrective action system key parameters on a monthly and f g) quarterly basis for each unit as well as for the station.
The following performance measures will be used for the on-going monitoring of V
this Key issue:
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17 Human Performance (as measured by the number of precursor, near miss and breakthrough event Condition Reports (CRs) per 1,000 man-hours worked)
Timeliness of Screening CRs for Operability and Deportability Action Plan Development Time for Level 1 and Level 2 CRs Action Plan Quality Median Age of Open CRs l
Overdue Corrective Actions Recurrence of Significant Conditions Adverse to Quality l
l Second Quarter: Status Corrective' Astion' Assessment instruments The following assessments of Unit 3 performance in the area of Corrective Action were scheduled during the second quader of 1998.
Assessment
 
==Title:==
Schedule Completed
. Revloed,
- Date :
-(Y/N)=
LSchedule if O-
. Not.
!,b
^
Complete l
Monthly Unit Trend Reports Monthly Y
Quarterly Unit Trend Reports 6/98 Y
l Quarterly Station Wide Integrated Trend 6/98 Y
Report Quarterly Annunciator Window Unit 6/98 Y
Corrective Action Program HPES Effectiveness 6/98 Y
Assessment Results l
Monthly / Quarterly Trend Reports Monthly and quarterly trend reports for Unit 3 indicate that the areas of operations configuration control, performance of safety evaluations, implementation of the action tracking program, and human error require continued rnanagement attention because the adverse trends in these areas have not been satisfactorily resolved.
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i 18 Quarterly Station-Wide Integrated Trend Report in
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No Unit 3 specific trends were identified in the Unit Trend Report Quarterly Annunciator Windows l
Overall organizational performance of Unit 3 with respect to corrective actions was satisfactory at the end of the second quarter. Two areas, condition report evaluation timeliness and age of open consition reports, did not meet expectations for the second quarter in a row. The Unit Director has placed these areas under weekly focus.
HPES The Unit 3 HPES Coordinator has been reassigned leaving a gap in this function temporarily. The position has subsequently been refilled. Although not specific to Unit 3, three areas for improving the HPES program at Millstone were identified in the self-assessment:
Identify an executive sponsor for the HPES program Integrate HPES activities across the station Assign a full-time HPES coordinator to each unit An action plan is under development.
b) f~
Performance Measures A review of the Unit 3 Corrective Action Key Performance Indicators reveals the following:
The ratio of Level 2 and 3 to Level 1 CRs during the second quarter of 1998 remained nearly constant. The percentage of Level 1 CRs fluctuated around 4% during the quarter consistent with the end of the first quarter.
During the quarter, the percent of self-identified CRs continued to increase.
The goal of greater than 90% self-identified CRs was achieved throughout the month of June. KPI A-2 Action Plan development median age for Level 1 and 2 CRs has slowly increased throughout the quarter, falling short of the goal of completing evaluations in less than 30 days. KPI A-1 Action plan quality remaine above the goal of 3 on a scale of 0 to 4. KPI A-9 m
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\P M-207.DO C
 
1 l
l 19 l
/m D)
The median age of open Level 1 and Level 2 CRs at the end of June is indicated below and shown on KPl E-1. The stated goal is a declining trend.
Time in Days i
CR Level 1 CR Level 2 All CRs 243 202 Oversight initiated 218 223 Externally initiated 204 153 The median age for Level 1 CRs has remained flat during the quarter while the median age for Level 2 CRs has slowly increased. This adverse trend will be analyzed and corrective actions taken.
Overdue corrective actions showed an increase during the quarter. This was symptomatic of the focus on completing restart required actions which had a floating due date and were not included in the calculations. Senior management intervention has been taken and the trend has been reversed, although not yet meeting the operational objective of less than 1% overdue corrective actions. KPI A-3 Human Performance KPl shows that the total number of Unit 3 human performance errors has declined over the quarter, however, the number of v
near misses remained about the same. KPI A-4 Conclusions The focus of activity during the quarter was on restart activities. Those CRs l
related directly to restart were acted upon promptly. The remaining CRs received less attention. Senior management has refocused attention and taken action to reverse those indicators that are not trending toward station goals.
I
(-V Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\P M-2Q7.DO C f
 
20 (m)
K. ey issue: Oversight g
success criteria The following Success Criteria were previously established and summarize the performance baseline for this Key issue:
Majority of problems are self-identified Oversight Condition Reports are addressed in a timely manner Self-Assessments The following self-assessments are currently planned for the remainder of 1998:
Third Quarter Performance Evaluation: Oversight Training Effectiveness (TQ1)
Audits and Evaluation: Benchmark Millstone typical number of audits / assessments performed by similar plants / stations to meet
(.
requirements. (Artificial Island, Palo Verde and North Anna)
(
Programs: CA Effectiveness in NO Performance Evaluation: Follow-up to 1997 4th Quarter Performance e
Evaluation Self-Assessment in Work Control Process Fourth Quarter Programs: SA Process in NO Programs: Revised NOVP Process
+
Audits and Evaluation: Oversight Training Effectiveness (TQ1)
Performance Measures The following performance measures will be used for the on-going monitoring of this Key Issue:
Condition Report Method of Discovery Status of Oversight Condition Reports, Millstone Unit 3 OV Millstor.c Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S US_PE R RR M\\P M-207.DO C
 
21 Ob
'Second Quarter Status Oversight Assessment instruments Assessment Title
. schedule
. Completed -
Revised
. Date
' (Y/N).-
schedule if.
Not '
Complete Nuclear Safety Engineering:
2nd Y
Operating Experience Program Quarter 98 (Vendor Information Tracking)
Recovery Oversight: Issues 2nd Y
Resolution Quarter 98 Audit & Evaluation: Training 2nd Y
Effectiveness Quarter 98 Performance Evaluation: Personnel 2nd Y
Qualification and Training Quarter 98 Performance Evaluation:
2nd Y
Continuing Training for Quality Quarter 98 Control Personnel Performance Evaluation:
2nd Y
'\\
IAT(Independent Assessment Quarter 98 Team) Recommendation i
implementation l
Joint Utility Management 2nd Y
Assessment (JUMA)
Quarter 98 l
Performance Evaluation: Customer 2nd N
In-process Satisfaction Quarter 98 Nuclear Safety Engineering:
2nd N
In-process Customer Satisfaction Quarter 98 Audit & Evaluation: Programmatic 2nd N
Canceled Assessment Comparing Quarter 98 Commitments Audit & Evaluation: Process 2nd N
Deleted Assessment Comparing Audit Quarter 98 Process to Other Utilities Assessment Results 1
l Nuclear Safety Enaineerina - Vendor Information Tracking (MP2)
This assessment determined that vendor information items received by NU have been adequately reviewed and dispositioned for Millstone 2.
p Department interfaces within the VETIP (Vendor Equipment Technical Information Program) are working, but procedures need to be improved.
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/980:\\RWM\\QTR LY\\S U S_PE R F\\R M\\P M-207. DOC
~
 
i 22 Additionally, program measures for vendor interfaces and in-house io accounting need enhancements.
I Recoverv Oversiaht - Issues Resolution i
The assessment revealed the need to assure a consistent Analysis &
Programs management understanding of the details and requirements of issue resolution, and the need to consistently distribute weekly reports.
Audits and Evaluation -Training Effectiveness l
'The assessment indicated that familiarization training has been i
implemented, although deficiencies were identified. The assessment I
noted that administrative improvements are needed to assure required training is not missed, and to assure audit performance feedback is evaluated for training value.
Performance Evaluation - Personnel Qualification and Training The assessment determined that the training program satisfies requirements, although documentation supporting that conclusion is incomplete. Another weakness was the need for implementation guidance for the continuing training program.
,p)
.t!V Performance Evaluation - Continuing Training for QC Personnel The assessment concluded that continuing training has been effective i
and beneficial to the performance of inspection activities. Noteworthy was that some training involved a mix of inspectors and workers which fostered an improved mutual respect of each other's roles and responsibilities. The assessment pointed out the need to equalize opportunities to attend available training.
i Performance Evaluation -lAT Recommendation implementation The assessment revealed that Performance Evaluation is placing its strategic focus on the issues most critical for the unit restarts, presentations to management have improved, and meetings with the NRC l
are rnore effective. It also revealed areas that need enhancement such as more management emphasis on following up cn recommendations, implementation efforts, communications, anc -,ending time with staff members.
OG Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PER F\\R M\\PM-2Q7. DOC
 
23 JUMA - Joint Utility Management Assessment The annual Joint Utility Management Assessment (JUMA), as required by the Northeast Utilities Quality Assurance Program (NUQAP) Topical Report, was performed during the week of June 22,1998. This assessment is designed to assess the effectiveness of Oversight in the implementation of the NUQAP in compliance with regulatory and licensing commitments. The team also evaluated the readiness of Nuclear Oversight to function as an operation quality organization and assessed the adequacy of corrective actions arising from past JUMA recommendations. The JUMA Team concluded that significant improvements had been made in Oversight's ability to perform its intended function. Areas for improvement were identified regarding corrective action effectiveness, communications, teamwork and trust, and Oversight work product quality.
i Performance Measures Indicator:
Condition Report Method of Discovery - Millstone 3 KPI A-2 Status:
The goal of less than 10% identified by events and extemal sources was achieved and maintained in May and June.
g Indicator:
Status of Oversight Condition Reports - Millstone 3 KPl C-1 Status:
Performance has not been tracking to satisfactory since March.
Conclusions i
l Critical 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. The timeliness of line actions in developing and approving corrective action plans for condition leports initiated by Nuclear Oversight has not been tracking to satisfactory since March. Senior management has refocused attention on those indicators trending away from station goals.
I MiHstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\PM-207. DOC
 
24
')
Key issue: Configuration Management:
l (V
I Success Criteria The following Success Criteria were previously established and summarize the performance baseline for this Key issue:
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 Self-Assessments During the second quarter of 1998, the Unit Configuration Management (CM)
Teams for Units 2 and 3 were re-assigned under the Manager, Programs and
[d Engineering Standards. This re-organization brings together these two teams 1
along with the Engineering Assurance Group (EAG) and the Design and Configuration Control (D&CC) Group.
This new organization allows for the monitoring of Configuration Management programs, processes and procedures under one department. The main focus of EAG will be the evaluation of processes (Design Control Manual, NCR process, Safety Evaluation process,'etc.) to ensure high standards are in place and implemented to maintain LB/DB.
The main focus of the CM Teams is to evaluate products (i.e., design change records, calculations, procedures, etc.) to ensure configuration control is maintained between the Licensing basis and Design basis, and physical plant.
The D&CC Group is the custodian for the key programs, process, and procedures pertaining to Configuration Management. Included are the Design Control Manual, the Temporary Modification procedure, and common design specifications.
The self-assessment plan for the remainder of 1998 reflects this re-organization (O]
with the consolidation of assessments. The assessments are as follows:
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25 p
Second Quarter Follow-up Assessment from PES-97-020 (dated 4/16/98)
MP3 Technical Specification Review (3 CMT-98-001, dated 4/29/98) l Corrective Action Effectiveness Review (CM Related)(PES-SA-98-002, dated l
l 6/9/98)
{
Corrective Action Effectiveness Review (Departmental) (PES-SA-98-017, dated 6/8/98) l Third Quarter Attention to Engineering Quality (PES-SA 98-039, dated 7/10/98) l MP3 Engineering Qualification Record Status (PES-SA-98-041, dated 7/5/98)
Calculations (PES-SA-98-009, dated 7/10/98)
PDDS Relief Valve Setpoints (PES-SA-98-003, ongoing)
Review of Minor Modifications (U2-CMT-98-004/3CMT-SA-98-04)
Review of Material issue and Control Processes (3CMT-SA-98-06, ongoing) l Foudh Quader Review of Design Change Records / Minor Modifications (PES-SA-98-007)
Review ot T; "porary Modifications (PES-SA 98-008)
Corrective Actions Effectiveness Review (U2-CMT-98-005/3CMT-SA-98-05)
Performance Measures l
The following performance measures will be used for the on-going monitoring of this Key issue:
Temporary Modifications Control Room and Annunciator Deficiencies Operator Work Arounds Configuration Management Annunciator Windows Configuration Management Training Configuration Management Related Self-Assessments Configuration Management Related Condition Reports l
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26 (G'
Second Quarter Status:
Configuration Management l
Assessment instrument Assessment Title schedule Date Completed Revised 1
(Y/N) schedule if i
l Not Complete ESAR PES-97-020 DCR/MMODS 2nd Quarter 98 Y
Review of MP3 Technical 2nd Quarter 98 Y
Specification 3CMT-98-001 Section 6.0 PES Corrective Action Program 2nd Quarter 98 Y
Effectiveness PES-98-SA-002 Self-Assessment Report 2nd Quarter 98 Y
PES-SA-98-017 MP3 Engineering Attention to 2nd Quarter 98 Y
l Engineering Quality PES-SA-98-039 MP3 Engineering Department 2nd Quarter 98 Y
Engineering Qualification Record Status i
PES-SA-98-041 MP2 and MP 3 Calculations 2nd Quarter 98 Y
PES-SA-98-009 Assessment Results ESAR PES-97-020 "DCR/MMOD"(Follow up) The overall effectiveness of the corrective actions from Self-Assessment PES-ESAR-97-020 (Design Change Records / Minor Modifications) is acceptable. A strength was observed in the area of management receptiveness to the associated corrective actions. This follow-up assessment identified that training initiated as a result of corrective actions requires follow-up reinforcement to have lasting effectiveness.
3CMT-98-001, " Review of MP3 Technical Specification Section 6.0" This assessme it determined if plant procedures properly implement the Administrative Controls Section (Section 6.0) of the Millstone Unit 3 Technical Specifications. A general trend identified a lack of recognition by the responsible I
procedure and program owners on how their programs and procedures are tied to Technical Specifications. Training for the program and procedure owners has been identified to reverse this trend.
l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S._P E R F\\R M\\P M-207.DO C
 
i 27 PES SA 98-002," Corrective Action Program Effectiveness" This O
assessment concentrated specifically on: closure of assignments from Level 1
)
and Lrvel 2 CRs and AITTS closure notes, assignment completion on or before s"
due date, RP4 procedure compliance and CR initiator contact. It was determined that the PES Corrective Action Program is satisfactory, and the performance criteria was met.
PES-SA-98-017,"Self-Assessment Report" Three randomly selected CRs processed within a past 3-month period were reviewed. The scope included content compliance with RP4, investigation and corrective action plans to ensure they satisfy the intent of the condition reported, ensure the CR initiator was contacted and determine if required supporting information/ documentation was included in the CR package. It was concluded that the investigation and ~ action plans adequately address the items specified by the CR and the initiators were contacted. Necessary supporting documentation was included with the CR packages.
PES-SA-98-039,"MP3 Engineering Attention to Engineering Quality" In support of the management intervention currently under development to raise the performance standard of " attention to engineering quality," Unit 3 Design Engineering and Technical Support products were reviewed to determine compliance with appropriate procedures. It was determined that many of the documents reviewed do not satisfy the performance criteria, and did not meet n
management expectations. Immediate compensatory measures were taken: An
,'"j Engineering Quality Review Board was implemented and emphasis was placed on the roles and responsibilities of the Independent Reviewer.
PES-SA-98-041, "MP3 Engineering Department Engineering Qualification Record Status" The assessment evaluated the MP3 Design Engineering group for compliance with TO-1 " Personnel Training and Qualification." Multiple cases of personriel performing work without properly documented qualification records were identified. The Engineering Directorimmediately reemphasized his expectation to each applicable supervisor that quality work was not to be performed without appropriate personnel qualifications.
PES SA-98-009, "MP2 and MP3 Calculations" The assessment evaluated performance and compliance with the calculation process as defined in the Design Control Manual (DCM). The calculation process as defined in the DCM is adequate. Additionally, expectations to ensure that calculations are properly completed, revised, controlled and indexed were met. Minor deficiencies were noted and are currently being addressed.
l f3)
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_P E R F\\R M\\P M-207.DO C
 
28 O
Performance Measures Indicator:
Summary Configuration Management KPI Status:
The Programs and Engineering Standards Department is enhancing the Configuration Management (CM) KPis to focus more on CM attributes critical to an operational unit versus a unit in the recovery mode. These enhancements are designed for long term monitoring of CM and will provide more efficient integration with the Corrective Action process to more effectively drive CM improvement initiatives. Therefore, the CM KPis will not be issued this period, but will be reissued next period in their new format.
l Conclusions l
Self-assessments completed through June indicate satisfactory implementation of processes to maintain configuration management. These areas are receiving appropriate management attention. Performance with respect to configuration l
s management is assessed to be at a satisfactory level which supported the restart i
of Unit 3 and its continued safe operation.
I 1
l t
l 4
.(v Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R RR M\\PM-207. DOC L
 
29 Q
Key.lssue:1 Regulatory Compliance l
&j 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' e, and communications are complete, I
accurate, and timely i
Self-Assessments The following self-assessments are currently planned for 1998:
Effectiveness of Corrective Actions Related to the Key issue of Regulatory Compliance-COMPLETE Effectiveness / compliance with RAC 08," Regulatory Communication and
,q Docketed Correspondence" - COMPLETE I
PV Effectiveness / compliance with RAC 01, " Licensing Basis Management"-
Revised to 3rd Quarter Effectiveness / compliance with RAC 06, Regulatory Commitment Management Program"- Substituted by effectiveness review of corrective actions associated with Root Cause Evaluation for CR-M3-98-2293 Effectiveness / compliance with RAC 03, " Changes and Revisions to Final l
Safety Analysis Reports"- Substituted by PES-98-001, "MP 3 Engineering FSAR Change Requests Assessment."
Effectiveness / compliance with RAC 13, " Organizational Changes" - Revised to first quarter 1999 Effectiveness / compliance with RAC 05, "10CFR50.72 Notification, 10CFR50.73 and 10CFR50.9(b) Deportability determinations, and Licensee Event reports"- Postponed to 1999 Effectiveness / compliance with RAC 02, " Technical Specification Change Requests and Implementation of License Amendments"- Substituted by l
Oversight Assessment of License Amendment Request Implementation Department training / qualification effectiveness - 4th Quarter o
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS._PERF\\RM\\PM-2Q7. DOC
 
30 D]
t Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:
l Compliance Manaaement i
Licensee Event Reports l
Notices of Violation l
Inspection items 1
License Basis Manaaement Docketed Correspondence Technical Specification Change Requests FSAR Change Requests i
License Basis Condition Reports (Link to Corrective Actions Program)
Regulatory Commitments SehondlOOartsrSIatul &
7$$ddRegulatoryghi$hlikrimsd@
,p lt Assessment Results Nine (9) assessments were performed relating to the Key issue of Regulatory Compliance during the period April 1998 through June 1998. This brings the total to Twelve (12) assessments in this key area for the year-to-date. One assessment scheduled for completion during the second quarter was rescheduled. These assessments are tabulated and summarized below.
: AssessmentTitlepy,+
,% p schedule Completed; -?:rhRevised;M
,w-wwg y
$ gjath
$/N)r tschedule'IfM 5
,39
;y T uv WotiC6mpletel Effectiveness / Compliance with RAC 08, 2nd Quarter Y
N/A
" Regulatory Communication and 1998 Docketed Correspondence" (3RAC-SA-98-02) 50.54(f) Recovery Oversight Not Y
NA Assessment Report, "NRC Briefing previously Book Validation Process" scheduled (2 Assessments)
Effective / compliance with RAC 01, 2nd Quarter N
3rd Quarter
" Licensing Basis Management" 1998 1998 i
(3RAC-SA-03)
MiHstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PE R F\\R M\\PM-207. DOC
 
l
)
31 gh iAssessmentTitleW 4
- Schedulet Completed 7:4Heviseda Date)b @ g(YIN) W.sSchedule:lfs
;d a?
, y
:;p -
4 s
1 N ~~ b 1Not Complete:
Root Cause Evaluation for Condition Not Y
NA Report M3-98-2119," Organizational previously Changes Without Prior RAC 13 scheduled Evaluation" Root Cause Evaluation for Condition Not Y
NA Report M3-98-2293,"Non-Compliance previously to Millstone Station Procedures RAC scheduled 06, " Regulatory Commitment Management Program" and RAC 08, l
" Regulatory Communications and Docketed Correspondence" 50.54(f) Recovery Oversight Not Y
NA Assessment Report,"MP3 Licensing previously j
Bases Activities" scheduled MP3 Engineering FSAR Change 1st Quarter Y
NA Requests Assessment 1998 PES-SA-98-001 Review of MP3 Technical Specification 1st Quarter Y
NA Section 6.0 - Administrative Controls 1998 ESAR 3CMT-98-001 50.54(f) Recovery Oversight Not Y
NA Assessment of Unit 3 Unreviewed previously Safety Questions (USO) submittals scheduled Assessment Results EffectivenessfCompliance with RAC 08, " Regulatory Communication and Docketed Correspondence"(3RAC-SA-98-02)- This assessment evaluated the effectiveness of the procedure related to the preparation of complete, accurate, and timely regulatory correspondence. This assessment concluded that the procedure was effective. Information provided in submittals reviewed was found to be materially complete and accurate. In addition, correspondence was provided to the NRC in a timely manner. Areas for enhancements were identified and are being addressed as part of the corrective action program. The enhancements were in the areas of improved proofreading and clear expectations for processing and maintaining validation packages which support statements of facts in correspondence.
50.54(f) Recovery Oversight Assessment Report, "NRC Briefing Book Val /dation Process"-Two assessments of the correspondence validation process were conducted by Recovery Oversight for the April 23,1998 and May 22,1998 NRC Briefing Books. The assessments concluded that validation packages were prepared and reviewed in accordance with RAC 08," Regulatory Communications and Docketed Correspondence," and that the validation y
process helped ensure that statements of fact were complete and accurate. In addition, some improvements in the effectiveness of the process were realized MlHatone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER F\\R M\\P M-2Q7.DO C
 
1 32
(
with the May 22nd issue. Oversight's recommendations for process enhancements are being captured in conjunction with corrective actions and addressed as part of the self-assessment of RAC 08 (see above).
Root Cause Evaluation for Condition Report M3-98-2119, " Organizational Changes Without Prior RAC 13 Evaluation"- On April 21,1998, Condition l.
Report M3-98-2119 was initiated by the subject matter expert for RAC 13 when a potential adverse trend was noticed. Some organizational changes appeared to be implemented prior to completion of an evaluation to ensure that regulatory requirements are met. This evaluation is required by station procedure RAC 13,
" Organizational Changes." The root cause was inadequate ownership for the LB l
organizational structure. Two significant factors that contributed to this condition were unclear expectations regarding what specific actions should be taken to properly review organizational changes for regulatory impacts and a lack of understanding of the portion of the organization that is described in LB documents. A total of fourteen RAC 13 evaluations were reviewed to determine the extent of condition. Three of the fourteen did not adhere to the RAC 13 procedure. Of those three, two were found to be regulatory noncompliant.
These two have since been addressed and compliance was restored. The issue I
was primarily procedural adherence with the new RAC 13 which represents a l
higher standard for the station. RAC 13 is being revised to establish clear ownership of the LB organizational structure and to delineate specific actions required for reviewing organizational changes for regulatory impact. Also,
{
organizational charts used by the majority of nuclear personnel have been annotated to show the subset of the organizational structure which is part of the LB.
Root Cause Evaluation for Condition Report M3-96-2293, "Non-Compliance to Millstone Station Procedures RAC 06, " Regulatory Commitment j
Management Program" and RAC 08, " Regulatory Communications and Docketed Correspondence"- On May 1,1998, Condition report M3-98-2293 was initiated by Regulatory Affairs and Compliance to address procedural non-l compliance with two procedures that are key in the management of regulatory l
commitments. The root cause evaluation concluded that the risk of missing or undoing a regulatory commitment is low. This is substantiated by the fact that of the 910 commitments reviewed,99% were appropriately implemented as j
scheduled. The root cause determined that the cause of the procedural compliance issues was inadequate management oversight and ownership during the transition from a fragmented regulatory commitment management program j
to a new and integrated station program. Corrective actions have been taken to correct the procedural compliance issues. Remedial actions are being implemented that clarify regulatory compliance policy and expectations for commitment management. Long term actions are being developed for simplifying and improving the process functionality and program user interfaces.
[
50.54(f) Recovery Oversight Assessment Report, "MP3 Licensing Bases
\\
Activities"- Due to the significance of regulatory commitment management, this assessment, which was requested by the Regulatory Affairs and Compliance Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PE R F\\R M\\PM-207. DOC
 
33 Department, independently evaluated many of the same issues associated with the root cause evaluation of Condition Report M3-98-2293. The assessment concluded that the while there was the necessary framework needed to maintain an effective commitment management program, implementation of the program is a concern with respect to procedure adherence. Additional clarification and instruction is warranted. Corrective actions have been taken and are continuing to provide both clarification of program requirements and more detailed implementing instructions in response to both Condition Report M3-98-2293 and this Recovery Oversight assessment. It should be noted that Recovery Oversight considered the corrective actions taken and planned in this area sufficient to address the issues identified in their report and the results of the assessment were factored into CR M3-98-2293. There were no issues found relative to commitment conformance.
MP3 Engineering FSAR Change Requests Assessment (PES-SA-98-001) -
This assessment evaluated selected MP3 Final Safety Analysis Report Change Requests (FSAR-CRs) prepared in conjunction with Unit 3 design changes and the Configuration Management restoration effort in response to the NRC 10CFR50.54(f) letter. This assessment concluded that the improved process to maintain the FSAR (an element of the licensing basis) is functioning adequately and FSAR changes are being properly made. The review showed that previous i
recommendations to enhance the FSAR change process have been l
incorporated in the improved procedure. In addition, evidence of strong l
ownership of the FSAR-CR process was found, resulting in satisfactory program performance. Minor deficiencies categorized as either " administrative / attention to detail" errors or " procedure non-compliance" errors were found. These errors are considered minor considering the volume of FSAR-CRs processed in 1997 (viz.,618) None of the errors affect the FSAR content or the determination of whether the FSAR change constitutes an Unreviewed Safety Question.
Review of MPS Technical Specification Section 6.0 - Administrative Controls (ESAR 3CMT-98-001) - This review was a corrective action from a Level 1 Condition Report (CR M3-97-4644), whose Root Cause Evaluation concluded that there was "a failure to clearly assign ownership for the implementation of this portion of the Licensing Basis." The purpose of the review was to ensure that requirements of the Administrative Controls of the Unit 3 Technical Specifications were being properly implemented through plant procedures and programs. This review confirmed the Root Cause Evaluation conclusion that there was a lack of recognition by the implementing procedure and program owners that the activities being implemented related to specific Technical Specification requirements in Section 6.0. Seventeen (17) Condition Reports (CRs) were initiated during this assessment (7 of which were written by the procedure or program owner who implemented a Section 6.0 requirement).
Required actions to support Mode 2 have been completed. items deferred past O
Mode 2 are for enhancement of the procedures. The majority of the remaining actions are scheduled to be completed by the end of this year.
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34 50.54(f) Recovery Oversight Assessment of Unit 3 Unreviewed Safety m
Questions (USO) Submittals - An assessment of selected Unreviewed Safety Questions (USO) was conducted to determine if the NGP 3.12, " Safety Evaluation" and subsequently RAC 12, " Safety Evaluation Screens and Safety Evaluations," procedural process was effectively implemented, whether the process was applied when appropriate, whether supporting documentation had been appropriately compiled and intemally evaluated, and whether the documentation effectively addresses the identified issue. Significant changes to the Safety Evaluation process have recently been impleritented to address weaknesses in the previous process. RAC 12 became effective March 1,1998 and replaced NGP 3.12 Rev.10. This assessment concluded that the safety evaluation (SE) process in place, once implemented, provides adequate actions to identify USO issues. It was also concluded that RAC 12 provides an effective process to identify USQs and document the evaluation / assessment criteria, and is applied effectively when used. Four USO determinations were reviewed and were found to have effectively documented and evaluated the issues, and provided supporting information to facilitate PORC/SORC review and the NRC evaluation of the conditions as docketed in the Proposed License Amendment Request (PLAR). The review and approval sign off process establishes effectiva measures to enhance quality and provides a clear accountability chain. One area of concem centers on the issue that intemal processes to initiate SE screens or SE's was not effectively invoked for two of the reviewed issues. NRC questions initiated the SE/USO process for those issues. Engineering is
,b currently evaluating actions to respond to this concem, iV I
Performance Measures l
l In addition to the above assessments, monitoring of performance against the Success Criteria was conducted using Unit 3 windows and Key Performance Indicators (KPI's).
Regulatory Performance Monitoring at Millstone Station is performed by Regulatory Affairs and focuses more globally on station performance. The KPI's have been used l
to assess Unit 3's readiness to restart as well as to provide data for trending and identification of emerging problems. The following summarizes Regulatory Compliance KPI's for the period from April 1998 to June 1998 for Unit 3. Since the last report, the KPI focus has shifted to an operational focus and a goal of excellence while still assuring there is no backsliding from the restart performance threshold. (See figure RAC-1 for a summary.)
Success Criterion 1 Contribmors Assessments Results - The assessments discussed above show that the processes for maintaining the licensing basis are functioning satisfactorily, however, procedure compliance issues are higher than expected and are receiving management focus to ensure quality and adherence to high standards. However, Millstone Station / Unit 3 Second Quarter Performance Repor1 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRM\\PM-2Q7. DOC
 
35 since some of these procedures are new, it was expected that issues would arise and that the procedures would be appropriately improved based on user feedback.
The Effectiveness (Compliance with RAC 08, " Regulatory Communication and Docketed Correspondence" 3RAC-SA-98-02 assessment concluded that the procedure was effective and allinformation provided in submittals reviewed was found to be materially complete and accurate.
The 50.54(f) Recovery Oversight Assessment Report, "NRC Briefing Book l
Validation Process" assessments concluded that validation packages were l
prepared and reviewed in accordance with RAC 08, " Regulatory i
Communications and Docketed Correspondence," and that the validation process helped ensure that statements of fact were complete and accurate.
The Root Cause Evaluation for Condition Report M3-98-2119,
" Organizational Changes Without Prior RAC 13 Evaluation"has provided insights to provide added assurance that organizational changes remain compliant with the LB organizational structure documented in various LB documents such as the Technical Specifications.
Root Cause Evaluation for Condition Report MS-98-2293, "Non-Compilance to Millstone Station Procedures RAC 06, ' Regulatory Commitment Management Program' and RAC 08, ' Regulatory Communications and l
Docketed Correspondence'" concluded that the risk of missing or undoing a regulatory commitment is low, however, additional management attention and process improvements are being applied to further reduce this risk.
The independent review by the 50.54(f) Recovery Overs /ght Assessment Report, "MP3 Licensing bases Activities"also concluded that while the necessary framework needed to maintain an effective commitment management program is in place, implementation of the program is a concem. Additional clarification and instruction is needed and is being addressed as part of the corrective actions for Condition Report M3-98-2293.
MP3 Engineering FSAR Change Requests Assessment (PES-SA-98-001) concluded that the improved process to maintain the FSAR is functioning adequately and FSAR changes are being properly made.
The Review of MP3 Technical Specification Section 6.0 - Administrative Controls (ESAR 3CMT-98-001) determined the corrective actions necessary provide assurance of regulatory compliance by Mode 2. Required actions to support Mode 2 were completed.
50.54(f) Recovery Oversight Assessment of Unit 3 Unreviewed Safety Questions (USO) Submittals concluded that the cafety evaluation (SE) process in place, once implemented, provides adequate actions to identify USO issues and is implemented effectively.
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC
 
36 l
Success Criterion 2 Contributors q
Regulatory Commitments - For 1998, the commitment management process is functioning satisfactorily, however, implementation deficiencies were identified 4
and resr%d in 10 commitments completed after their due date. This represente about 1 percent of the 910 commitments that were fully implemented as scheduled. Commitments required to be completed for Modes 4,3 or 2 were i
met. Communicating, reporting and management attention to the commitment management program will continue.
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 of TSCRs. A schedule has already been provided for future submittals of TSCRs. Unit 3 performance is satisfactory.
l FSAR Change Requests (FSARCRs)- The FSARCR process is functioning satisfactorily and FSAR changes are being properly made. Submittal of the l
Annual Report (10CFR50.59) and Revision 11 to the Unit 3 FSAR was completed on time. The implementation focus is now shifting to dispositioning l
the backlog of FSARCRs. Unit 3 performance is satisfactory.
i Licensee Event Reports (LERs) - The process for deportability determinations l
and LER preparation is functioning satisfactorily. Unit 3 performance is satisfactory.
The majority of Deportability Determinations requiring input from engineering and/or Regulatory Compliance are completed within 48 hours. Licensee Event Reports (LERs) are consistently being submitted on a schedule which meets the 30 day requirement and they are materially complete and accurate. The number of LERs associated with historical design issues is declining and performance is expected to trend toward the industry average. Unit 3 implementation performance is satisfactory.
Docketed Correspondence - The process for preparation of docketed l
correspondence is functioning satisfactorily. The standard for validation
- packages has been raised. There are some issues regarding procedural adherence with respect administrative items. Improvements to the process are currently being evaluated to administratively improve the handling of docketed i
correspondence. Overall, Unit 3 performance is satisfactory.
For the period from April 1998 to June 1998 over one hundred sixty (160) outgoing docketed correspondences were processed. The docketed correspondence is generally submitted in a timely fashion and the submittals are i,)
materially complete and accurate. However, there were a number of (V
administrative or typographical errors found. The results of the second quarter self-assessment to determine "The Completeness and Accuracy of i
l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER F\\R M\\PM-207. DOC l
t
 
37 Correspondence Provided to the NRC and the Effectiveness / Compliance of RAC
! (q 08, ' Regulatory Communication and Docketed Correspondence'" agree with the l
j V
above conclusion. A plan for remediation, which is being tracked by the corrective action program, was developed to address this issue. Improvement has already been noted. Unit 3 implementation performance is satisfactory.
Notices of Violations (NOVs) - NOV responses for Unit 3 have generally been submitted in a timely manner in response to NOVs received from the NRC.
Condition Reports are being generated at the time of the inspection exit meeting, or sooner, if known during the inspection period. This allows for an improved process for identifying root causes and the appropriate corrective actions corresponding to the applicable root causes. These actions are being properly tracked through the Corrective Action Program. Unit 3 performance is satisfactory.
As the corrective actions addressing past violations received during the Unit 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 - Submittal of closure packages to support Unit 3 startup is complete. Focus will now have to be on working with the NRC to reach closure on those packages which have been submitted. Subsequently, the focus will
! (9 need to be on submitting closure packages for those items greater than two lV years old, followed by those greater than 1 year old.
J License Basis Condition Reports (CRs) -The CRs issued to address the RAC l
processes were focused primarily on RAC 06, " Regulatory Commitment l
Management Program," RAC 08, " Regulatory communications and Docketed l
Correspondence," RAC 12, " Safety Evaluation Screens and Safety Evaluations,"
i and RAC 13, " Organizational Changes." This performance indicator provides an indication of trends requiring increased management attention. The majority of the CRs were Level 2 CRs, however, two were Level 1 CRs whose root causes i
were discussed in the self-assessment section above. The Level 2 CRs indicated either important issues to be addressed or that procedure enhancements are necessary. Both Level 1 CRs were an indication of j
procedure compliance and management oversight issues rather than process issues.
Conclusions I
Regulatory Compliance is satisfactory to support Unit 3 restart and continued g
safe operations.
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l 38 1'
Key Performance Indicators Success C iterson 1 Met iL Self Assessment f
Results (GREEN)
Success Cri trion 3 Met ik Cor tspo d nce FSAR Change Requests (GREEN)
' Licensee Event N
NRC inspection Reports items (GREEN)
(GREEN) l l
l Licens Basis Conditio.. Reports (GR 'EN)
GREEN Satisfactory l YElluGWJimprovement Necessary RED Not Satisfactory RAC Figure 1 1
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39 O
l Key 11ssue: 7 Training l 3
Success Criteria The following Success Criteria were previously established and summarize the performance baseline for this Key Issue:
A high degree of success is to be achieved by the Unit 3 upgrade / initial license operator training class Nuclear Training programs are upgraded and ready for Unit 3 restart and operations. This is confirmed by Nuclear Training Management Self-assessment and by Nuclear Oversight.
Self-Assessments The fol!owing self-assessments are currently planned for 1998:
i Nuclear Training Department Procedures - 1st Quarter V
Shift Manager Qualifications - 1st Quarter Training Effectiveness 5.05/5.06 - 1st Quarter l
Systematic Approach to Training Effectiveness - 1st Quarter Feedback / Evaluation Process - 1st Quarter Corrective Action Effectiveness - 1st Quarter Procedure Compliance Effectiveness Review - 2nd Quarter TO1 Implementation - 1st Quarter 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 l
Changes (Unit 3) - 2nd Quarter l
Technical /ES Programs - 4th Quarter Review of Simulator Design Changes (Unit 2) - 2nd Quarter Performance Measures O
\\
i, The following performance measures will be used for the on-going monitoring of this Key issue:
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER F\\R M\\P M-207.DO C l
l
 
40 Executive Technical Council Meetings g
V Training Advisory Committee Meeting Curriculum Advisory Committee Meeting l
Simulator Availability I
Secorid Quader/ Status!
J iii # ~:
..JTralnind.jj Assessment Instrument t
Assessment Title schedule Completed Revised Date (Y/N)
Date TO 1 Implementation (New revision 1st Otr 1998 N
3rd Qtr l
became effective 7/10/98) 1998 Procedure Compliance Effectiveness-2nd Otr 1998 N
3rd Qtr Review 1998 l
Millstone Operator Training Programs 2nd Qtr 1998 Y
l INPO Accreditation Team Visit Non-Accredited Training Programs 2nd & 4th Otr N
4th Otr l p\\
1998 1998 l(
(only) l Process Computer and Simulator -
2nd Qtr,1998 Y
Impact of Plant Design Changes l
(Unit 3)
Review of Simulator Design Changes 2nd Otr 1998 Y
l (Unit 2)
Assessment Results INPO Accreditation Team Visit (ATV): To determine the status of Millstone's Operator Training Programs (Licensed Operator Initial Training, Licensed Operator Requalification Training, Non-licensed Operator Training, Shift Technical Advisor Training, and Shift Manager Training) with respect to the eight (8) accreditation objectives contained in ACAD-91-015, Accreditation Objectives and Criteria. The evaluation team consisted of both INPO personnel and NU peers. The evaluation team did not identify any weaknesses that were not self-l identified by Millstone in the Accreditation Self-Evaluation Report. The team evaluated the status of the eleven (11) Utility identified Weaknesses (UlW's) and defarmined that five (5) remain at the accreditation objective level and require
( ~.itinued attention. The other six (6) UlWs were determined to currently meet the accreditation objectives.
V Simulator Unit 3 Self-Assessment 98-006: Conducted to determine if the simulator group is receiving all pertinent items from the design process by a Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PER RR M\\PM-207. DOC l
 
41 sampling using " Closure Tasks by ID No." for Millstone Unit 3 (MP3). This
.[
document represented a sampling of all items which were required for MP3 restart. The simulator group had received all but five documents, exceeding a 98% success rate. The items not received were determined to be of a minor nature and did not adversely affect training scenarios.
Simulator Unit 2 Self-Assessment 98-008: Conducted to evaluate the MP2 Simulator Certification Management System (SCMS) records for compliance with NSEM 5.01. This was accomplished by a review of 20% of all DR packages issued since the inception of the SCMS. The reviews showed that all DR packages were being maintained in accordance with NSEM 5.01 and that all DR packages not yet complete can be located.
i Performance Measures I
Indicator:
Executive Training Council Meeting KPI F-1 l
Status:
The Executive Training Council has been more active than the i
specified goal of one meeting per quarter.
I Indicator:
Training Advisory Committee Meeting KPl F-2 Curriculum Advisory Committee Not Meeting KPl F-3 i
Status:
The meeting frequency for the Training Advisory Committee (TAC) b has exceeded the goal of 3 TAC meetings per quarter. The Curriculum Advisory Committee (CAC) meetings have fallen behind the established goal of 55 CAC meetings per quarter. Training Advisory Committees (TACs) have been informed of this adverse trend. TACs have reinforced the meeting frequency requirement with station management.
Indicator:
Simulator Availability KPI F-4 Status:
The average Simulator Availability for the second quarter was 99.7%. All simulators exceeded the goal of 99%.
Conclusions Performance continues to improve throughout the training process. Involvement in the day-to-day training efforts by line personnel has fallen off due to the resource and time demands of startup and power ascension. Training performance is determined to be at a satisfactory level and fully supporting the continued safe operation of Unit 3.
O Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC
 
42
/#h b
Key issue:; Operational Performance l
I Success Criteria I
With Millstone Unit 3 operational, the focus for this section shifts from l
" Readiness for Operation" to " Operational Performance."
j l
The following Success Criteria have been established and summarize the performance baseline for this Key issue:
Readiness Focus Complete the Licensed and Non-licensed Operator Training addressing changes to the plant and procedures, and provide required simulator training for normal start-up, operation, and abnormal conditions. Provide an opportunity for Operators to observe power operations.
Confirm, by Operations Management and Nuclear Oversight, that Operator Readiness will support the conduct of safe operation.
Confirm, by use of performance indicators, that operator burdens are
,O minimized.
~ (_)
Performance Focus Operational performance is consistent with established goals for excellence The plant is operated within the licensing basis and Technical Specifications Confirm, by use of performance indicators, that operator burdens are minimized Self-Assessments The following self-assessments are currently planned for 1998:
Administration and Organization (Unit 3) - 1st Quarter l
Management and Leadership (Unit 3) - 1st Quarter Culture Survey - 2nd Quarter Conduct of Operations (Unit 3) - 2nd Quarter Interface effectiveness between Operations and other departments (U,it 3) -
3rd Quarter EOP/AOP Operations Resource Support (Unit 3) - 3rd Quarter p
Configuration Control (Unit 3) - 4th Quarter Industry Recurring Operations Problem (Unit 3) - 4th Quarter V
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43 Effectiveness of Operations Department Corrective Action Program (Unit 3) -
0 4th Quarter Quarterly Assessment of Performance," Windows" l
Performance Measures The following performance measures will be used for the on-going monitoring of l
this Key Issue:
Readiness Foe s Temporary Modifications Operator Work-Arounds Control Room and Annunciator Deficiencies Open Operability Determinations Performance Focus Unplanned Automatic Scrams per 7000 Hours Critical Unplanned Safety System Actuations (ESFAS/RPS)
Safety System Performance - EDGs Safety System Unavailability - AFW and SI Systems Unit Capability Factor
(
Unplanned Capability Loss Factor Thermal Performance Fuel Reliability Chemistry Indicator Industrial Safety Accident Rate Unplanned Entry into LCOs Operator Errors (including procedure adherence and negative impact on core reactivity)
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r 1
l l
44 i
'SecondjQUartsrLStntiskMMR"[M Oberat'lonalPerfarmaricsM Assessment instruments Assessment Title Schedule Date Completed Revised (Y/N)
Date Conduct of Operations 2nd Quarter N
Third Qtr 98 1998 Nuclear Oversight Monthly Reports Monthly Y
Ouarterly Assessment of Performance, 1st Quarter 1998 Y
" Windows" Assessment Results Nuclear Oversight Restart Verification Plan, The monthly Nuclear Oversight Restart Verification Plan reports information which is evaluated bi-weekly.
Nuclear Oversight currently assigns Unit 3 Conduct of Operations a satisfactory O
grade with a cautionary note (" yellow" rather than " green") to underscore their concern based on ongoing efforts to complete corrective actions for configuration control events. Additionalline management and Nuclear Oversight attention has been placed on operator performance, which includes 24-hour coverage in the Control Room for unit restart and power ascension, and improvements in operator performance have been noted as the staff regains a better " operational 1
feel" for the plant following the extended shutdown period.
l Quarterly Self-Assessment. The Unit 3 line organization performs quarterly self-assessments (windows) of fourteen (14) departments including Operations.
During the second quarter of 1998, Operations was assessed as an overall
" white" (meets expectations / criteria). Thirty-eight (38) of the assessed areas which contribute to the overall window rating were evaluated as " green" (exceeds expectations / criteria) or " white." The exceptions include the following areas:
Surveillance Test was assigned a " red" (falls short of expectations / criteria, goals / criteria impacted) due to a surveillance that was missed in March; Logkeeping Practices were assigned a " yellow" (falls short of e
expectations / criteria, goals / criteria not impacted) as a result of weaknesses and areas for improvement identified during the period; Severe Accident Management and " Black Board" were " blue" (currently i
I unassessed or under development);
Mllistone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC
)
o-----________
 
45 I
Technical Specification Quality was evaluated as " yellow" due to greater than three condition reports (no Level 1's) for changes / clarifications required for Technical Specification conformity.
I NRC Operational Team inspection (OSTI). The NRC OSTI was conducted from April 1
13-24,1998. This inspectien was an independent, broad scope _ assessment of I
management controls, administrative programs, equipment and personnel and their l
readiness to support restart and safe operation of the Millstone Unit 3 facility. Specific l ~
to Operations, the OSTI team found that conduct of operations, procedures and procedure adherence, operator training and command and control to be generally good
- and were adequate to support plant restart. However, the team noted two operational events that occurred during heatup to Mode 3 and several plant equipment configuratiori issues which required root cause evaluation and implementation of corrective actions prior to plant restart. With the performance of these evaluations and l
associated corrective actions, the OSTI team determined that plant hardware, staff and management programs at Millstone Unit 3 were ready to conduct a safe plant restart and continued operation, i
Performance Measures Indicator:
Temporary Modifications KPl A-6 l
Status:
The number of Temporary Modifications is 16, one of which is required to support the restart. Of the remaining items,9 require l
design changes,4 are awaiting parts, and 2 will remain until the next refueling.
Indicator:
_ Operator Work Arounds KPI A-8 l
Status:
The Work-Around program is expanding in scope as the plant l
retums to power and different work-arounds are discovered.
l_
Eighteen work-arounds, including three awaiting retest, were listed l
as of the end of the second quarter of 1998. Three additional l
work-arounds have been added in July. New goals have been established as part of the unit backlog reduction program.
Indicator:
Control Room and Annunciator Deficiencies KPI A-7 Status:
The number of Control Room and Annunciator Deficiencies is ten.
These items are being aggressively worked as they are discovered on power ascension. The deficiency category is being expanded as part of the unit backlog to include the greater scope of equipment that would not be considered in a shut-down plant.
Indicator:
Open Operability Determinations KPl K-1 Status:
There are 28 open Operability Determinations for the unit.
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS PERF\\RM\\PM-2Q7. DOC
 
46
(.
Conclusions Significant issues noted during the second quarter included configuration control concems by NORVP; surveillance testing, logkeeping, severe accident management, blackboard, and Technical Specification quality issues by the Quarterly Self-assessment; and equipment configuration concems by OSTI.
Condition reports were written and compensatory actions taken to address the issues identified. These included extensive procedural reviews, field walk-downs of system line-ups, and reiteration of management's expectations for configuration control and procedure compliance. Long term corrective actions were initiated to prevent recurrence of the significant issues. Specifically, an overall program will be developed to integrate existing processes / programs into a total configuration control program.
The NRC Restart Assessment Panel (RAP) made a restart recommendation for l
Millstone Unit 3 to the Nuclear Regulatory Commission in June,1998, and the Commission recategorized the Unit to a Watch List Category 2 plant, thereby passing the final authority for authorizing restart to the Executive Director of Operations (EDO) and the Special Projects Office. Unit 3 notified the EDO that the Unit was ready to commence restart the end of June, along with the j
recommendation from the Special Projects Office to allow restart. The EDO approved restart with the condition that the Restart Plan, with power plateaus
(
and associated reviews, would be followed. Unit 3 began execution of the Restart Plan by bringing the plant to Mode 2 on June 30,1998 but then retumed to Mode 3 when Intermediate Range Nuclear instrumentation did not function properly. The Intermediate Range Nuclear instrumentation was repaired and Mode 2 was reentered within 24 hours.
O Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER F\\R M\\P M-207. DOC
 
47 Key; issue Work Controliand!Pisndidg?.,,.
w gy g.
Success Criteria The following Success Criteria were previously 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 Preventive maintenance and surveillance activities are completed as scheduled Institution of an on-line work management process in a schedule adherence rate consistent with industry standards Self-Assessment The following self-assessments are currently planned for 1998:
O)
Work Management Training Issues and Compliance - 1st Quarter
(
Resource Loading Analysis -4th Quarter Procedure Usage and Compliance - Refueling Schedule - 2nd Quarter Maintenance Planning Effectiveness - 3rd Quarter Schedule Adherence - 3rd Quarter Work Management Corrective Action Program - 3rd Quarter INDUS Passport Automated Work Order (AWO) Software - 4th Quarter Maintenance AWO/ Procedure and Feedback Program Effectiveness - 4th Quarter Condition Report Process and Tracking Effectiveness - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key Issue:
l On-Line Corrective Maintenance Backlog Preventive Maintenance Tasks Overdue (b
N Surveillance Performance Schedule Performance Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_P E R RR M\\P M-207. DOC
 
l 48 Second.Q'uarterStittuhd31i idorliiContMliandplanningw,_
\\
Assessment Instruments h
[
WC-14 Work Control Self-Assessment 2nd Quarter Y
j l
Second Quarter Condition Reports 2nd Quarter Y
{
l Quarterly Assessment of Performance, 2nd Quarter Y
l
" Windows" l
l l
Assessment Results i
Second Quarter Condition Reports l
All condition reports from the second quarter were reviewed for their bearing on the recovery plan and success criteria. While several issues were identified, one i
significant issue conceming control of work associated with RCS*V132 represented a deficiency in awareness of requirements associated with high risk
/~3 activity. Related corrective actions have been implemented to prevent
;h recurrence. Additionally, the review did not reveal any new trends representing l
issues which had not been previously identified.
l 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.
l I
l i
j
/
i Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PE R RR M\\PM-2Q7.DO C
 
49 O
Performance Measures Indicator:
On-Line Corrective Maintenance Backlog (On-Line Work Order Status) KPl A-5 Status:
The On-Line Corrective Maintenance Backlog has attained our established goal indicator:
Overdue Preventive Maintenance AWOs KPI J-2 Status:
Prevent:ve Maintenance tasks overdue remain at the established goal of zero indicator:
Surveillance Test Program Schedule Performance KPl J-1 Status:
Performance remains satisfactory on average Indicator:
On-Line Schedule Performance KPI J-3 Status:
The goal for work activities started and completed on time have not been consistently met due to emergent work activities and rescheduling required to support the start-up and power ascension.
Conclusions The tools required to monitor that performance are being maintained in this area.
The online scheduling starts have been evaluated for improving performance.
Performance is improving and should attain the goal next quarter.
L M!ilstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC
 
i 1
1 50
\\OV Kep; issue: tProcedure QuslitvfandjXdliersnc' ef gl Success Criteria The following Success Criteria are 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 acceptable l
Instances of not adhering to procedures remain at an acceptable level Self-Assessment 1
t The following self-assessments are currently planned for 1998:
l Station Administrative Procedures Window - Quarterly lO Procedure Biennial Reviews - 1st Quarter l
Procedure Compliance - 2nd Quarter Station Qualified Reviewer - 3rd Quarter Master Manual - 4th Quarter t
1 Performance Measures 1
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 l
1 l
I f%
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51 O) i V
Second Quarter l Status;, * [ Procedure 0ualityfand dhnence/.
7 l
l t
l Assessment instrument 1
AssessmentTitle e schedule;
. Completed,- y; Revised)
;o-v.
Date-
.(Y/N),c1
;:. Schedule'.if.?
Not Con plete:
l Biennial Review Status 1st Otr.
Y 1998 Procedure Compliance 2nd Otr.
Y 1998 Station Administrative Procedures Quarterly Y
Group Window for Procedures Quality Assessment Results Procedure Compliance l
O)
The Station Administrative Procedure Group completed a self-assessment l
" Procedure Compliance" for the second quarter of 1998. The assessment team looked at a programmatic issue, " Confined Space Entry," and detennined that i
when Management / Supervision is "part of the process" and sets the standards for all involved, Millstone processes do work and procedures are complied with.
Station Administrative Procedures Group, Window The Station Administrative Procedure Group Annunciator Window for Procedure l
Quality reported the following performance:
Station Qualified Reviewer Program " White"(Satisfactory) l Organizational Effectiveness " White" Administrative Procedure Process " White" Procedure Upgrade Project - Project Complete i
N.,
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER RR M\\P M-207.DO C
 
52 y
Performance Measures Procedure Compliance Millstone Unit 3 KPI D-1. The total non-compliance errors /1000 hours has remained below the goal of 0.5 for Unit 3 since December of 1997 indicating satisfactory performance. The trend of maintaining performance has been demonstrated throughout the quarter.
Condition Reports involving Deficient Technical Procedures KPl D-2. The quality of technical procedures for Unit 3 and the Station is acceptable. The total number of procedure-related 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 This assessment shows that performance is being maintained. The technical accuracy of procedures and procedure compliance is improving at Unit 3 and across the station. Performance with respect to the success criteria established for procedure quality and adherence is at a satisfactory level.
Old i
i l
i O
l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRimPM-207. DOC
 
53 rs Key.lss'uet Emergency Planning (,
;; l t
Success Criteria l
l The following Success Criteria were previously established and summarize the performance baseline for this Key issue Demonstrate that Millstone Station has an effective Emergency Response 1
Organization Complete Emergency Preparedness Maintenance program improvement actions Self-Assessment I
i l
The following self-assessments are currently planned for 1998:
Effectiveness of Root Cause and Self-Assessment Corrective Actions - 1st Quarter
,Q Emergency Action Level Annual Review - 2nd Quarter V
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 performance measures will be used for the on-going monitoring of 1
this Key issue:
Station Emergency Response Organization l
Off-site Emergency Response interface / Activity l
Regulatory Compliance l
Conduct of Drills t
Station Emergency Plan & Procedures Industry Benchmarking Y
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_ P E R F\\R M\\P M-207. DOC
 
54 f
lSecond;Qu.arter; Perform,.ances
.a E,m,ergency) Planning:
.,..m l
Assessment instrument Assessment Results
' AssessmentTitle
: Schedulec (Completed JRevised( '
+
Date *.
-(Y/N)7-ScheduleIf Note w
O Completsi EAL Self-assessment 2nd Quarter N
Started-2nd 1998 Quarter Scheduled Completion-3rd l
Quarter Inventory of Response 2nd Quarter Y
Facilities and Equipment 1998 Emergency Response Drills 2nd Quarter Y
1998 Assessment Results Emergency Action Levels (EAL) Self-Assessment The start of the second quarter self-assessment on Emergency Action Levels was delayed until June it is currently in progress and is scheduled for completion by the end of July.
Inventory of Response Facilities and Equipment Quarterly inventories for response facilities and equipment have been conducted and found satisfactory. Facilities and equipment were maintained in a " ready state."
Emergency Response Drills l
A Unit 1 SERO drill was conducted on June 17,1998. All objectives selected for the drill were demonstrated and a number of new SERO members were qualified through participation in the drill. A critique was conducted where issues were identified and subsequently entered in the station corrective action process.
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55 In addition, a Unit 3 Post Accident Sample System (PASS) drill was conducted on June 19th. This drill was observed and evaluated by the NRC to address outstanding Unit 3 restart issues. All objectives selected for the drill were met s
and there were no significant issues identified by the NRC. NU concluded and the NRC confirmed that the Unit 3 PASS was adequate for restart.
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 drills to satisfy qualification requirements and fill vacant positions. Selected SERO members are also being scheduled for training associated with Severe Accident Management.
Off-Site Response Offsite interface activities continued to be conducted. Routine monthly meetings between Millstone Emergency Planning Services Department (EPSD)
Management and staff were held with State of Connecticut OEM Director and staff to discuss 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 second quarter meeting was held on May 15th. It should also be noted FEMA has discussed an interest in attending future meetings.
I Regulatory Compliance One Notice of Violation (NOV) was received during the second quarter (April).
The NOV was associated with the PASS and resulted from the NRC Inspection conducted in February. A response to the NOV was issued. The NRC retumed to the site in June to evaluate a Unit 3 PASS drill and associated PASS documentation. NRC verified that the PASS was adequate for the restart of Unit 3.
Conduct of Drills Two drills were conducted during the second quaiter. A Unit 1 SERO drill was conducted on June 17th and a Unit 3 PASS drill June 19th. Selected objectives for both drills were met and areas for improvement identified. Improvement items are being tracked by the station corrective action process.
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i 56 Emergency Response Plan Approval was received in June from the NRC on Revision 24 to the Millstone Emergency Plan. The plan is scheduled to be implemented 60 days from the date of approval. Familiarization for affected SERO members on the changes j
made to the plan is in progress. This activity will be completed prior to plan implementation.
I i
A project to streamline emergency planning procedures was initiated and is scheduled for completion in October,1998. Severe accident management t
procedures are in the process of being developed for Units 3 and 2 and are l
scheduled to be completed by the end of August.
l Industry Benchmarking Millstone EPSD was involved in two industry benchmarking activities during the second quarter. The EPSD Manager attended the annual NEl conference in June and an EPSD staff member participated as part of a Duke Engineering team conducting an emergency planning audit at the Vermont Yankee site.
i Industry benchmarking on the subject of the PASS is scheduled to be l
conducted in the third quarter.
i l,
Conclusions
)
,k l
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 e,urveillances. 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.
I l
O Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRM\\PM 207. DOC
 
57 I p()
, Key issue:J Radiological Protectioni 1
1 Success Criteria The following Success Criteria were previously established and summarize the performance baseline for this Key issue:
Nuclear Oversight Assessments of the Radiation Protection Program indicate l
satisfactory performance Demonstrate compliance and high standards l
Foster a culture of Radiation Protection Program ownership Achieve a going forward goal of zero incidence of High Radiation entry l
dosimetry events Achieve a goal of less than one event per 20,000 entries into any Radiologically Controlled Area Self-Assessments Igg The following self-assessments are currently planned for 1998:
(,)
Health Physics Equipment Program Assessment - 1st Quarter Radioactive Materials Shipment - 1st Quarter Mixed Waste - 2nd Quarter Radiation Protection Surveys (Unit 3) - 2nd Quarter l
Station ALARA Program Assessment - 3rd Quarter
{
Tool Decontamination in the Solid Radwaste Building - Process and Techniques - 3rd Quarter HP Training and Professional Development (Unit 2) - 4th Quarter i
Free Release of Materials in Warehouse #9 - Process and Techniques - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:
Cumulative RCA Entry Error Rate, Millstone Station i
Low Level Radioactive Waste Volume 6
Radiation Exposure j
O i
l Millstone Station / Unit 3 Second Quarter Performance Report l
08/10/98C:\\RWMiOTR LY\\S U S_PE R RR M\\P M-207.D O C l
1
 
58 O
Q)
Second Quarter l Performance
_ um Radiologi. cal: Protection %
Assessment Instruments I
Assessment Title schedule Completed.
Revised schedule 1 1
Date
.(Y/N)
If Not Complete?
l Radioactive Material Jan 1998 Y
N/A Transportation Training
* Monitoring Equipment, April 1998 Y
N/A Engineering Controls, Respirators Mixed Waste April 1998 Y
N/A Confirmatory Monitoring April 1998 Y
N/A Radiation Protection Surveys June 1998 N
July 1998 (Unit 3)
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.
* The Radioactive Material Transportation Training self-assessment was conducted in January 1998 but not reported in the previous report.
Assessment Results Monitoring Equipment, Engineering Controls, Respirators (HP98 HPSA-01,02,03)
This was a multi-unit team observation of three major components of the station radiological protection program. No significant adverse findings were listed in the radiological monitoring instrumentation area or in engineering control (i.e.
shielding, HEPA ventilation, etc.) area. The respirator program has several areas of improvement opportunities as detailed in station generated CRs.
Confirmatory Monitoring Mini-Assessment (3HP-98016)
This self-assessment looked at Unit 3 effectiveness of engineering controls, representative air sampling, and biologicalintake data for 1997. This l
assessment determined that no significant radionuclides uptakes occurred in i
1997 at Unit 3. This assessment listed areas of improvement for proper identification of air samples in the air sample logs to improve the usefulness of the information for assessment purposes.
(
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS PERPJIM\\PM-207. DOC
 
59 l
i Radioactive Material Transportation Training (NS 98-28)
A self-assessment of the Radioactive Material Transportation Training, (RMTT),
provided by a vendor was conducted January 17 through January 30. The RMTT program was determined to function effectively and no areas for improvement were identified. Significant strengths of this program included the excellent correlation between the course objectives / agenda and the test questions and between the training objectives and the training material.
Mixed Waste Self-Asa,essment (NS 98-21) l The mixed waste self-assessment conducted on April 21 and April 22 identified a number of potential 40 CFR (EPA) environmental compliance issues as well as program enhancement recommendations. Condition Report M3-98-2922 was initiated as a result of this assessment and 8 corrective actions were developed.
These are expected to be completed by the end of 1998 with an effectiveness review scheduled for completion by March 1999.
Performance Measures 1
Cumulative RCA Entry Error Rate, Millstone Station KPI H-1. The major l
radiological protection adverse condition identified in 1997 was the failure to assure that personnel had the required monitoring devices consisting of a
'O TLD and electronic dosimeter in the RCA envelope. Millstone Station V
underwent several improvement initiatives and management actions in 1997 to address this weakness. A. continualimprovement performance has been realized in dosimetry compliance during this period. Since July 1997 Millstone Station has met or surpassed its performance goal of less than one dosimetry infraction per 20,000 RCA entries. In 1998, Millstone station is averaging less than one dosimetry infraction per 37,000 RCA entries. The performance goal has now been raised to one infraction per 25,000 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. In the past 12 months, all dosimetry events have been reported by workforce personnel rather than Nuclear Oversight or Nuclear Regulatory Commission reports.
1998 Rad Exposure Summary KPI H-2. The 1998 cumulative radiation i
exposure for Millstone Unit 3 has been set at less than 51 rem. This goal l
represents the level of exposure which the Health Physics department strives to stay below in order to maintain occupational exposures as low as reasonably achievable (ALARA). To date, the cumulative exposures are tracking well within the ALARA goal.
lO l
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC
 
I 60 Conclusions g\\
l Nuclear Oversight has reported an event at Unit 2 conceming survey adequacy and monitoring for alpha activity. This resulted in an Event Review Team report with several proposed corrective actions.
A culture 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 self report infractions. An improvement has been realized in the Radiation Worker training program with the advent of improvement in the practical factor facilities and HP l
technician involvement in radiation worker training, j
Improved process centers for health physics functions has been accomplished by closing multiple entry points into the RCA and the installation of mechanical tumstiles 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 l
of a timed portal monitoring system at station exit points. Additionally, a truck i
contamination monitor is being installed as a first devise of its type at a US j
commercial nuclear utility during 1998. Millstone Station is maintaining an effective radiological protection program commensurate with safe nuclear l
O operations and industry standards of performance.
,b 1
I l
l l
l I
l J
V)
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER RR M\\PM-207. DOC
 
61 l
lO
( )
Key 31ssue':; Securityi Success Criteria l
The following Success Criteria were 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 Self-Assessments The following self-assessments are currently planned for 1998:
Security Alarm Response - 1st Quarter SSMR Process - 1st Quarter CAS/SAS Operation - 1st Quarter Personnel PA/VA Access Control - 1st Quarter
;f)T Socurity Training Program - 1st Quarter k.
Station Qualified Reviewer implementation - 1st Quarter Security Weapons Testing / Surveillance / inspection - 1st Quarter l
Security Processing Center - 1st and 3rd Quarters Visitor Control - 1st and 4th Quarters Protection Security Personnel - 2nd Quarter Patrolling - 2nd Quarter Security Locks and Keys - 2nd Quarter 1&C Training and Qualification - 2nd Quarter Safeguards Information - 2nd and 4th Quarters l
Vehicle PA Access Control-2nd and 4th Quarters Fitness For Duty Center - 3rd Quarter Security Surveillance - 3rd Quaiter Contractor Termination - 3rd Quarter Application of Compensatory Measures - 3rd Quarter Performance Observation Program - 3rd Quarter Security Lighting - 3rd and 4th Quarters Security Report / Trending Analysis - 4th Quarter
(]/
Station Lock and Keys - 4th Quarter Security Emergency Response - 4th Quarter Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98 C :\\RW M\\QTR LY\\S U S._P E R F\\R M\\P M-207.D OC
 
62 V
Performance Measures The following performance measures will be used for the on-going monitoring of this Key Issue:
Control of Safeguards Information Vehicle Controlinside the Protected Area Security Badge Control Control of Visitors Inside the Protected Area Second QuOterstattis; "i
uz.i
', [Sicurityd Assessment Instruments
% A'ssessmentTitle 34 7 !sc_hedulef [Compjetedj RHevised)
. +j 4: g #
,' % d !!
1 iDate!
W
^ ScheduleIfi:
a;, Qp. y@(Y/N)?M YJ 1Nsticompidteh
,a t
1 g;7 j
[')
I&C Training and Qualification 2nd Y
\\v/
Program Quarter 1998 Security Lighting 2nd Y
Ouarter 1998 Security Locks and Keys 2nd Y
Ouarter 1998 Vehicle Protected Area Access 2nd Y
Control Quarter 1998 Patrolling 2nd Y
I Quarter l
1998 l
Safeguards Information 2nd Y
Quarter 1998 O
s t
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER F\\R M\\P M-207.DO C
 
63 1
Assessment Results Fourteen self-assessments were scheduled and completed during the first two quarters of 1998 - eight in the first quarter, and six in the second quarter. The j
self-assessments covered the topics shown above and resulted in
)
recommendations to enhance the respective programs. These self-assessments were documented under 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. A brief synopsis follows:
Second Quarter I&C Training - Technicians are knowledgeable of equipmont and repairs, l
good resource library available, Department Instruction addressing I&C j
Training needs complete revision.
l Security Lighting - Procedures dealing with Security Lighting are accurate and concise, recommendations focused on lighting level surveys and how they should be conducted.
Security Locks and Keys - Security and Operations personnel are knowledgeable of the program, recommendations focused on enhancements to existing procedure.
Q
. _ Vehicle Protected Area Access Control - New computer program in place and working, additional person assigned to duties at Vehicle Access Point, recommendations focused on enhancements to existing practices.
Patrolling - New patrolling practices implemented and working, recommendations focused on clarification on procedure wording.
Safeguards - Security and Non-Security custodians of Safeguards Information knowledgeable in program, recommendations focused on enhancing control of material in the Security Safeguards Work Center and Central Alarm Station.
1 Performance Measures Key performance indicators have been established for the following areas:
Control of Safeguards information KPl1 A goal of no more than three i
events was established for 1998 - a reduction from the 1997 total of ten j'
actual events. Two events have occurred during 1998 ( one in the 1st quarter, one in the 2nd quarter) causing this KPl to track satisfactorily.
Vehicle Controlinside The Protected Area KPl1-2-- A goal of no more h
than six events was established for 1998 - a reduction from the 1997 total of V
eight actual events. Four events have occurred during 1998 (one in the 1st l
I
. Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC
 
64 quarter, three in the second quarter) causing this KPI to be overall satisfactory with improvement needed.
N Security Badge Control KPl 1-3 A goal of no more than 96 events was e
established for 1998 - a reduction from the 1997 total of 141' actual events.
l Thirty-two events have occurred during 1998 (eighteen in the 1st quarter, 1
fourteen in the 2nd quarter) causing this KPI to track satisfactorily.
j Control of Visitors inside The Protected Area KPI l A goal of no more than 12 events was established for 1998 - a reduction from the 1997 total of j
25 actual events. Five events have occurred in 1998 (two in the 1st quarter, three in the 2nd quarter) causing this KPl to be overall satisfactory with
- improvement needed.
i 4
Conclusions j
This assessment shows 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 on l
track to meet our goal in security related events. Security programs are satisfactory and will support the restart of Unit 3 and continued safe operations.
,OV l
l I
l
\\
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC
 
l 1
65
/%
C)
Key lssueqEnvironmental Compliance; Success Criteria l
The following Success Criteria were previously established and summarize the performance baseline for this Key Issue:
l l
The program and procedures that cover environmental requirements exist l
and are effective; and l
There is reasonable assurance that environmental regulations and permit requirements are being effectively implemented.
Self-Assessments i
The following self-assessments are currently planned for 1998:
Assess the adequacy of Environmental Roles and Responsibilities Manual -
2nd Quarter l n 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 t
i 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 l
appropriate / effective - 4th Quarter l
Performance Measures i
The following performance measures will be used for the on-going monitoring of this Key issue:
i Notices of Environmental Violation
)
NPDES Permit Exceedences Prompt Reports to the Department of Environmental Protection (DEP) t]
Spills O
Progress Against ISO 14000 Environmental Management Standard l
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C ARWM\\QTR LY\\S U S_P E R RR M\\PM-207,D O C L----------------------
 
I
(
66 O
Ne6ond;Qusrt'ehStatusr ~
; r,[f Tsiivironmehtal"Complianc'eM Assessment instruments AssessmentTitles
;Schedulen (Completed
; Hovised>.a 3
m
-w Date:.,
l(Y/N)f > : Schedule if Not?
a
'Completoi o
gg Environmental Roles and April 1998 Y
Responsibilities Manual Effectiveness Air Quality Program Compliance June 1998 Y
and Procedural Effectiveness Environmental Correspondence June 1998 N
July 1998 and Commitment Tracking Effectiveness Nuclear Oversight Audit of Air Mar.1998 Y
Quality and Meteorology Root Cause Investigation of May 1998 Y
j tO Meteorological Program Issues Root Cause investigation of Water April 1998 Y
Ouality Parameters from EDAN Root Cause Investigation of June 1998 Y
Emission Source Permits Assessment Results Environmental Roles and Responsibilities Manual The Environmental Roles and Responsibilities Manual self-assessment evaluated the adequacy of the manualin clarifying, for affected managers, their respective environmental duties. The assessment indicated that the manual was a good first step in defining environmental ownership, but certain programs, such as meteorology which bridge multiple functions, still lack clear program ownership. Condition Reports are in place to address the gaps. As indicated below, the ownership issue has been resolved and, going forward, responsibilities will be further clarified as part of the site Environmental Program Manual Program Description under development.
(
Air Quality Program i
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/980:\\RWM\\QTR LY\\SU S_PER RR M\\PM-2Q7. DOC
 
1 67 i
The assessment of air quality compliance which included permits and related O
documentation indicated that significant improvement had taken place in the air quality program in the last twelve months and that for each major issue identified l
from our reviews there were action plans in place. For example, preparation of l
the required Clean Air Act Title V permit application and an Oversight Audit indicated emission sources for which permits had apparently not been obtained.
l As of June 30, all sources on site had operating authorizations in place as a l
result of corrective actions. Remaining areas of improvement include l
documentation and record keeping for emissions. A CR has been prepared to modify procedures and related forms to ensure proper records of fuel use and engine operation are kept and forwarded to Environmental Services for reporting i
to DEP.
Nuclear Oversight Air Quality Audit At the request of Environmental Services, Nuclear Oversight performed an audit of the station's air quality program including emission sources and meteorology.
i The review made a s'gnificant contribution toward improving each of these environmental prog.am areas. Sources of emicsions apparently without permits were identified art i authorizations were subsequently obtained from CT DEP as i
noted above. De1iciencies within the meteorological program, including tower l
operability, were inked to lack of clear program ownership and support.
Corrective actior,s are discussed below.
l (3
i V
Root Cause, Meteorology The root cause stemming from the above audit confirmed Oversight's findings i
with respect to the need to clearly identify program ownership. Additional issues to be resolved included revisions of associated procedures used by on and off-l site organizations and clarification of the design bases for the meteorological system including ties to tech specs and FSARs. Program ownership has subsequently been assigned to the Vice President Nuclear Work Services and the Manager Environmental Services. The tower has been returned to operable status in conformance with tech specs of all three units. Additional Action Requests from the root cause are underway.
Root Cause, Water Quality Parameters A CR indicated discrepancies in the use of the Environmental Data Acquisition Network (EDAN) cooling water flow data for the purpose of calculating radioactive effluent releases and resulting dose assessments. The flows used for dose assessments were not necessarily the pump design values and j
therefore were different than those reported to DEP for purposes of water quality monitoring. While this CR was classified as a level 2, Environmental Services undertook, on its own, the performance of a root cause considering the importance of the dose calculations and the fact that other EDAN data are used d
for NPDES permit compliance. As with the EDAN system as it relates to meteorology, there was not clear ownership for these data, nor effective Mbione Station / Unit 3 Second Quarter Performance Report 08/10f98C:\\RWM\\QTR LY\\ SUS _PERF\\R M\\PM-207 DOC
 
68 coordination among the various users. Environmental Services has now.
I assumed on-site EDAN ownership and has moved to resolve these issues b
through the CR process.
Root Cause, Emission Sources Requiring Permits l
The above audit of air quality compliance indicated that two sources of emissions had expired permits, that record retention for the purpose of emissions reporting i
was not well organized and that it was unknown whether the emissions sources l
on site met CT DEP opacity requirements. The root cause was attributed to a l
lack of management focus on these issues historically and a corresponding lack I
of clarity in respective roles and responsibilities. However, with the formation of the on-site Environmental Services organization in early 1997, accountability for programmatic development and support of implementation has been established. Further, as a result of this audit, related self-assessments and preparation of the Title V Clean Air Act Permit application, our knowledge of and our attention to permit issues and related monitoring of air sources at Millstone Station has increased dramatically. Action Plans are in place to address these issues. As indicated above, all sources in use on site now have authorizations and additional submittals to the CT DEP are planned to deal with longer-term permit issues.
O Performance Measures V
Ag79W T* ?
@wy Notices of Environmental Violations None None (one DEP audit thus farin 1998)
Number of Spill Reports TBD 8
Number of NPDES Exceedences 3
None ISO 140001 Progress (17)
Number of Elements EMS Action Plan Elements Complete in 1998 Complete,in review l
Training Programs Development Complete July 1998 Eight of ten modules developed to date Environmental Screeningin Key Complete in 1998 DCM,DC3,MP2-WC1, Procedures NGP 5.14, EPIP Reporting, complete T)rompt Reports to DEP TBD 15 The above environmental performance measures are a combination of 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 i
station procedures which control design modifications and physical work.
Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC 1
 
69 Regulatory reporting requirements have led to several Prompt Reports to the
/s Department of Environmental Protection. These reports relate largely to the fact b
that the design bases of the plant discharges were not adequately described in the prior NPDES permit application upon which the current permit is based.
Major efforts are underway to resolve this matter. Going forward, once a database has been established for prompt reports, a target can be establistad; the intent being to reduce the number of reportable events over time.
The absence of NPDES Permit Exceedences reflects the units' ability to manage water quality activities in conformance with those permit conditions clearly expressed in the permit. This measure remains on track.
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. Completion of the training modules is expected by July 1998, whereas development of a documented EMS will progress over the course of 1998.
Conclusions
/'
During 1997 and the first half of 1998, Millstone Station has made significant
'(
progress in identifying and implementing environmental program enhancements.
Our current status is satisfactory. Baselines for certain key performance indicators are still being developed.
With regard to Unit 3 restart, potential air and water quality compliance issues were identified and corrective actions have been 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 rnanagement 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. The above discussion of these reviews indicates an ability of the station and Environmental Services to critically evaluate its own performance and implement continuous improvement. Longer-term programmatic improvements are also underway.
Regulatory compliance and program enhancements are being tracked to assess
(
performance and progress of improvement programs. Environmental
(
compliance performance is being sustained at a level which adequately supports the safe operation of Unit 3.
l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRM\\PM-2Q7. DOC l
L
 
MILLSTONE STATION UNIT 3 Key Performance Indicators
< i
 
Index I
(~h
(/
Key Performance Indicators Millstone Unit 3 KPls Pace Number KPl Title A-1....................
Condition Report Evaluation Timeliness A-2............................
Condition Report Method of Discovery A-3............
Overdue Corrective Actions A-4................................
Human Performance, Millstone 3 A-5...
On Line Work Order Status A-6...........................
Temporary Modifications A-7..........
Control Room and Annunciator Deficiencies A-8.....
Operator Work Arounds A-9.........
Condition Report Evaluation Quality Score Safety Conscious Work Environment KPis B-1.............................
Leadership Assessment (SCWE Element)
B-2........................
Culture Survey (SCWE Element)
B-3............................
NU Concerns and NRC Allegations Received, Millstone Station B-4.......
Millstone Employee Concerns Confidentiality Trend, Millstone l
B-5.......
Employee Concern Resolution Timeliness C
B-6....................
Employee Satisfaction With Employee Concerns Program B-7........................
Focus Area Action Plan Status, Millstone Station
\\"
B-8...................
Substantiated Concerns involving Potential Violations of 10CFR50.7 Oversiaht KPis C-1................
Status of Oversight Condition Reports, Millstone 3 C-2.............................
Nuclear Oversight Restart Verification Plan, Millstone 3 Additional KPls Procedure Compliance and Quality Indicators Peoe Number KPl Title D-1.....
Procedure Compliance, Millstone 3 D-2................
Unit 3 Closed CRs involving Deficient Technical Procedures AdditionalCorrective Action /Self AssessmentIndicators E-1........................
Median Age of Open Condition Reports NSclear Trainino Indicators F-1....
Executive Training Council Meeting j
F2.............................
Training Advisory Committee Meeting l
(f 3 F-3....
Curriculum Advisory Committee Meeting l
V)
F-4.........................
Simulator Availability 1
l l
l 1
 
Index P(
Key Performance Indicators Culture and Leadership indicators G 1..
Leadership Assessment G - 2............
Culture Survey Radioloalcal Protection Indicators H-1.
Cumulative RCA Entry Error Rate, Millstone Station H-2.....................
Rad Exposure H -3......
Self Reporting Culture Chart Security Indicators 1 1........
Control of Safeguards Information 1-2.................
Vehicle Control Inside the Protected Area 1-3........................
Security Badge Control 1-4......
Control of Visitors Inside the Protected Area Additional Work Control Indicators J - 1...........
Surveillance Test Program Schedule Performance j
J-2....
Overdue Preventive Maintenance AWOs i
J-3..
On-Line Schedule Performance I
Additional Operational Readiness indicators i
K-1........
Open Operability Determinations i
l l
I 1
s l
 
Condition Roport Evaluation Timeliness Millstone 3 - July 1998 greSS; Performance is not meeting management's expectations.
.0 35 -
ilInImlllh e
e e
e e
e e
e e
e e
g I
i i
I i
8 i
s l
5 Average Age of CR Evals l
Raw Date 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24'98 7/1/98 Average Age of CR Evale 26 30 29 31 35 29 29 31 36 34 34 34 Total CR Evals Regwred 98 86 91 124 45 98 115 89 69 102 88 61 Evals Completed within 30 days 71 66 70 90 41 84 89 67 44 72 70 46
,. Evals Completed within 30 Days 72 %
77 %
77 %
73 %
91 %
86 %
77%
75 %
64 %
71 %
80%
75 %
Definition Analysis! Action This indicator depicts the average age of Level 1 & 2 Condition Reports The average age of a CR evaluation over the last 12 (CRs) for which evaluations are still open, evaluations which were weeks is 31.5 days.
completed during the week being reviewed and the age of CR's that were originated during the week under review.
This KPI is showing a negative trend in the % of CRs evaluated witnin the 30 day requirement. After peaking Once issued, Condition Reports are evaluated to determine the
@ 91% on 5/13, the subsequent seven reporting corrective actions that are necessary to address the issue and prevent periods have shown an overall decrease in the number recurrence. The 30 day clock begins on the day the assignment is of evaluations completed within 30 days (86%,77%,
made and ends when the CR is received in the Corrective Action 75%,64%,71%,80% and 75% respectively).
l Department for review.
CR evaluation timeliness is not meeting management's j
expectations. The Unit Leadership meeting will provide I
a focused review of performance vs. goals.
" cal Comments l
The average time to complete a CR evaluation does not show an The expectation is that CR evaluations are completed
" verse trend, and the average time to complete a CR evaluation within 30 days. Due date extensions for evaluations are j
fdays.
the exception and only granted on a case by case
. pports SCWE Success Criterion #2 basis. The Average Age for 6/24 has been corrected.
j D;ti Source:
AITTSl Analysis by:
W. Rein x3707MPl Owner:
G. Winters x5491MP A1
 
1 l
Candition R3 port Mothod of Diccovery Millstone 3 - July 1998 rog(OSS:
Performance is satisfactory. Excluding the ICAVP data, the goal was achieved in 10 of the past 12 weeks.
50 %
g 40%
a 30 %
-i a
20 %
g G00d gi gl]
Goals 10%
{
10%
0%
i
!89 8
8 i
8 i
8 i
i i
i s
s 9
s 8
s s
s a
% Extemal + Event IC::Ol% External + Event -ICAVP Goal !
RawDats 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98
% External + Event if%
26 %
17%
20%
8%
8%
16 %
7%
1%
5%
1%
6%
% External + Event -lCAVP 3%
19%
13%
5%
6%
7%
8%
4%
1%
6%
1%
6%
Goal 10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
10% - 10%
Unit CRs 70 77 72 80 92 88 77 75 107 93 98 66 Internal Oversight CRs 15 10 5
6 6
9 10 13 11 11 9
8 External Oversight CRs 13 28 15 21 8
6 15 6
1 4
1 4
Event CRs 2
2 1
1 1
3 1
1 0
1 0
1 Total CRs 100 117 93 108 107 106 103 95 119 109 108 79 External + Event CRs 15 30 16 22 9
9 16 7
1 5
1 5
ICAVP 12 10 4
17 3
2 8
3 0
0 0
0 Definition Analysia/ Action This indicator depicts the percentage of Unit 3 CRs identified by including the ICAVP Discrepancy Report CRs had a external sources or events compared to the goal. Although large negative impact on the results. Percentages are displayed, special external assessments such as ICAVP were shown with and with out ICAVP included. Excluding the not factored in establishing the goal. CRs are categorized into ICAVP data, the goal was achieved in 10 of the 12 the following four areas:
weeks displayed.
Event Driven - Self-revealing, an event occurs External Oversight - Identified by the NRC, NCAT, INPO, etc.
Internal Oversight - Identified by PORC, Nuclear Oversight, NSAB, NSE, etc.
Self Identified - Supervisor observation, document review, self-l checking, etc.
It is desirable to have a low perce1tage of all CRs generated by external sources or events, and a high percentage generated by the line organization or internal oversight.
Gos!
Commente The goal is to have s 10% of issues (CRs) identified by external Errors found in data used for last report (6/24) have
} sources or events assuming a levelized NRC inspection effort.
l been corrected.
l Data Source:
AITTSl Analysis by:
W. Rain x3707MPl owner:
G. Winters x5491MP A-2 e
L-------- ------------------- ---
 
1 Overdus Corrective Actions Millstone 3 - July 1998 l
p YOg(OSS:
Performance is not meeting management's expectations. Management attention has increased in this area.
l l
7.00 %
6.50 %
6.00 %
g l
j 5.50%
l g "5.00%
g j",
Goals 3%
a J 3.50%
cond e 3.00%
5 2.50 %
2.00 %
0 1.50 %
# 1.00 %
0.50 %
0.00 %
l l
1 I
I I
I I
I I
I e
e e
e e
e e
e e
e m
5 0
3 5
S S
5 5
8 M% Overdue Goal l R'w Dats 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98
% Overdue 1.52%
3.10%
2.74 %
3.36 %
1.79%
2.83%
2.32%
6.06 %
3.48 %
4.71 %
4.06 %
6.71 %
'oal <; 3% of Total Open C/A 3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
Open Level 1 C/A 339 302 310 294 273 322 344 328 308 327 325 304 Open Level 2 C/A 2549 2470 2424 2503 2519 2537 2546 2497 2420 2453 2555 2514 Total Open C/A 2888 2772 2734 2797 2792 2859 2890 2825 2728 2780 2880 2818 Total Overdue C/A 44 86 75 94 50 81 67 143 95 131 117 189 Definition Analysis / Action This indicator depicts the percentage of the total corrective actions The Unit has met the goal of s 3% overdue Correctiva (C/A) that are overdue.
Actions 5 of the 12 weeks displayed with an overall average of 3.47%.
Corrective actions are developed to address issues and problems identified by Condition Reports (CRs). Overdue corrective actions The Unit's focus on Mode 2 related work affected the are ones that have not been completed by the scheduled due date.
Unit's ability to meet this goal during the month of June.
The monthly " bow" wave of due assignments (119 out it is desirable to have a low percentage of overdue corrective of 189 were due 6/30/98) is the major contributor to this actions relative to the total number of corrective actions that are weeks overdue ratio.
open.
l The Unit Leadership meeting has been revised to I
provide a focused review of performance vs. goals.
Goal Comments The goal is for the percentage of overdue corrective actions to be
< 3% of the total open corrective actions.
I I
Jupports SCWE Success Criterion #2 l
D 22 Source:
AITTSl Analysis by:
W. Rein x3707MPl Owner:
G. Winters x5491MP A-3
 
Human Performance Millstone 3 - July 1998 s
'j Progress:
Performance Is below the stated goal and management attention has increasedIn this area.
100%
Goal: 2 95% of Total I
95g,
90% -
KPI data current g
85%,
through the end of June 1998 80% -
Good 75% -
70% -
65% -
60%
55% -
50 %
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98
: M % Low Significance (Precursor) Errors Goalj I
Raw Dets j
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
% Low Significance (Precursor)
Errore 92%
91 %
93%
91 %
83%
86%
Goal 95%
95%
95%
95%
95%
95%
95%
95%
95%
95%
95%
95%
(
Human Error Precursor Events 112 107 81 102 76 69 Human Error Near Miss Events 8
11 6
10 16 11 l
Human Error Breakthrough Events 2
0 o
0 0
0 l
Total Human Error CR's 122 118 87 112 92 80 l
1000 Productrve Hours Worked 154.54 164 55 165.59 155 66 150.03 134 61 Definition AnalysisfAction This indicator depicts the percentage of human errors with low Although the total number of human performance significance relative to the total human errors identified, and compares errors has declined since the beginning of the the percentage to the unit goal. Human errors are identified through year, the character of those errors is more Condition Report evaluation, and the errors are categorized by significance level.
significant. Five Condition Reports in early April rompted a management assessment of the The most significant errors are called " breakthrough events", and are performance weakness and lessons learned.
l i
l characterized by a breakdown of all barriers. Breakthrough events result l
in consequential events such as plant transients, major equipment CR M3-98-2774 has been initiated to perform a damage, operation outside of the design bases, etc. "Near miss' events Common Cause Analysis to verify if an adverse involve the breakdown in multiple barriers, but have little consequence.
trend exists and provide the Unit Leadership As such, they represent a lower significance level. " Precursors
* involve Team with recommendations for improving the breakdown of few barriers, are caught earlier in the event chain, and erformance.
generally result in no significant consequences. Precursor events represent the lowest significance level.
It is destable to have a higher percentage of low significance human errors (precursor events) to total errors to allow for the implementation
)
of corrective actions at a lower threshold, thereby prevenbng more significant errors.
Gael Comments gj The goal is for the percentage of low significance errors (precursor events) to be > 95% of the total human errors l
identified.
AITTSl Analysis By:
W Rein x3707MPl Owner:l G Winters x5401MP Data Source:
i A4
 
On Lina Werk Ordsr Stctua Millstone 3 - July 1998 pd Progress:
Progress is satisfactory. The goals have been achieved.
1400 1200 -
1000-l l
_ E3 g d
4 600 -
Goal (Total)r 500 ga ram
=
=
,4 g
B G
E E
E 400 -
f 200 -
Goal (PRA)s 350 0
'^
h h
h fk h
k h
h h
4 5
8 5
E h
1 M
5 5
l MPRA Risk Significant AWOs EE30ther AWOs -m-Work Off/G0al(Total AWOs) -m-W0rk Off/ Goal (PRA AWOs) l RawDets --
4/8/98 4/1548 4"2248 4f29S8 5698 5/1348 5/2048 5/27S8 6/348 6/1048 6/1798 6/2448 7/1/98 Non-PRA Risk Sigruficant AWOs 318 317 322 279 248 244 244 238 210 212 212 210 240 I
PRA Risk Significant AWOs 416 416 423 358 314 306 289 293 241 237 229 236 251 Work oft / Goal (PRA AWOs) 395 386 377 368 359 350 350 350 350 350 350 350 350 Total AWO Backlog 734 733 745 637 562 550 533 531 451 449 441 446 491 Workoft/ Goal (Total AWOs) 614 591 568 546 523 500 500 500 500 500 500 500 500 DeRnition AnalystalAc60n This indicator depicts the number of on line Corrective Maintenance The goals have been been achieved.
(CM) Automated Work Orders (AWOs), and the portien of those associated with Probabilistic Risk Assessment (PRA) risk significant syst ms.
PRA Risk Significant systems are systems required to protect the raictor core or mitigate the consequences of an accident.
Work awaiting post maintenance testing or closure is not included in this KPl. Also excluded aa AWOs for support work, such as insulation removal, outage Work, and Preventative Maintenance or SurvIll'anco AWOs, as well as AWOs not associated With power block equipment. Power Ascension AWOs are not included and are tricked by a separate KPl.
i i
Oce*
Commente Th2 goal is to have s 500 Total On-Line Corrective Maintenance KPI data is current through July 1,1998 Os. Of thess 500, no more than 350 Will be PRA risk significant Os.
I Dets Source:
P. O Johnson x5519MP! Analysis by:
J Legerx2391MP! Owner:
C. Schwarz x0491MP A5
 
Tcmpercry Mcdificcti:ns Millstone 3 - June 1998 1
OOgreSS:
Performance is tracking to satisfactory. We willbe one (1) above our goal of g 15 temp mods for a shortperiod.
30 25 20 15
=
=
5
+
s 9
0 s
s 8
i s
s s
e a
{
ClllI:3 Temp. Mode. < 1 Cycle m e'emp Mode. > 1 Cycle QOutage Support
-s-Total Work Oft / Goal Raw Deen 4/15/98 4/22/98 4/29/98 6AS/98 6/1M8 500/98 6/27/98 6/198 6/10/98 6/17/98 6/24/98 7/1/98 Temp. Mode. < 1 Cycle 10 10 10 10 10 10 11 11 11 11 11 12 Outage Support 3
4 4
4 4
3 2
0 0
0 0
0 Temp. Mode. > 1 Cycle 5
5 5
5 5
5 4
4 4
4 4
4 l
Total Installed 18 19 19 19 19 18 17 15 16 15 15 16 l
Total work Off/ Goal 17 17 17 15 15 15 15 15 15 15 15 15 DeRnielen Analynia/ Action
; indicator depicts the total number of Temporary Modifications to We are above our goal of s 15 temp mods.
l unent plant design, the portion that are " Outage Support" (directly d to physical work to plant equipment in an outage condition), and the Of these sixteen (16) temporary modifications nine (9) are in various l
portion that have been in place longer than one cycle, that is before stages of design to make them permanent, two (2) will be in until RFO6, 4/14/95 (mode 3 prior to RFO5).
and four (4) are waiting for parts.
Temp Mod 3-98-033 was just installed to rnonitor feed pump vibration i
A temporary modification is a modification to the plant that is short-term and is expected to be installed for a short duration.
in nature and not part of the permanent plant design change process.
j Goal Commente The goalis to have s 15 Temporary Modifications installed.
Data Source _
J Cunnmoham x4372l Anetysis by:
S Stncker 5409l owner:
G Seder x5381Mp 1
l l
1m I
I V
A-6 E-______.__________.________
 
l l
Control Room and Annunciator Doficionciac Millstone 3 - June 1998
,rh (O) Progress:
Performance is satisfactory. The goal of Control Room and Annunciator Deficiencies < 10 is met, with one approved deficiency greater than six
\\
months old.
1 30 l
25
(
U 20 f
Good 15 h
Goal (Total): <10 Y
l 15 a'
w I
m u
g g
j}
{
'q g
5 4
0 s
a g
a a gg s
s s
g s
a a
a a
s s
a i
s R
R s
i 0
s siiS i
i s
% Def. > 6 Mos. Old Def. < 6 Mos. Old Goal (Total) l l
RawDets 4/1298 4/1998 4/26S8 5/3/98 5/1048 5/17S8 5/24 S8 5/3148 6/748 6/1498 6/2148 6/28 S8 Def. 3 6 Mos. Old 0
2 1
1 0
0 0
1 0
0 0
1 Def. 4 6 Mos. Old 7
11 10 8
7 7
6 6
2 2
3 4
Total Deficiencies 7
13 11 9
7 7
6 7
2 2
3 5
Goal (Total) 10 10 10 10 10 10 10 10 in 10 10 10 I
l Definition Analysis / Action This indicator depicts the number of Control Room and The database of Control Panel Deficiencies (CRP)
Annunciator deficiencies that exist, relative to Unit 3 goais for deficiencies was reviewed with a more conservative both number and age.
view being taken toward classification of items as deficiencies, which accounted for the large increase in Control room and annunciator deficiencies are control room late March.
instruments, recorders, indicators, and annunciators that I
function improperly and could challenge the ability of The goal of Control Room and Annunciator Deficiencies operators to monitor and control plant conditions.
< 10 is met, with one approved deficiency greater than six months old.
l i
l Goals Comments 9
The goal is to have fewer than ten control room and Repairs that are complete, but await documentation annunciator deficiencies prior to entry to Mode 2. No closeout or retest under specific plant conditions are not deficiencies shall be more than six months old, without unit included in the total.
officer approval.
Data Source:
L. Palone x4737MP l Analysis by:
M A King x5537l owner:
J R Beckman x5361MP A.7 j
 
Opcrater Work Arounds Millstone 3 - June 1998 O
Ogress; Pro ~ress is satisfactory. There are three Operator Work Arounds awalting Post MaInte.,ance Testing. New criteria Work Arounds are shown in addition to the goal.
l 25 20 m
j15
\\
I Good l
10 m
o.
E l
l e
a m
S Y
0 l$=b b
b b
b k
s s
s 8
s s
s s
S a
a s
s s
s W/A > 6 Mos. Old W/A < 6 Mos. Old i iNew Criteria W/A Goal i Raw Data 4/12/98 4/19/98 4/26/98 5/3/98 5/10/98 5/17/98 5/24/98 5/31/98 6/7/98 6/14/98 pS8 6/28/98 IOperatorWork Arounds 10 10 10 10 10 9
9 9
9 9
15 15
> 6 Mos. Old 9
9 9
9 9
8 8
8 8
8 8
8 W!/A < 6 Mos Old 1
1 1
1 1
1 1
1 1
1 1
1 New Criteria W/A 6
6 Goal 10 10 10 10 10 10 10 10 10 10 10 10 Definition Analysis! Action Opsrator Work Arounds (W/A) are conditions which require an The work on Operator work-arounds is on track.
operator to work with equipment in a manner other than original Operations' KPI goal for work-arounds is to be at ten or d: sign intended, less at startup. Of the original population (required for restart), there are currently 9 outstanding and three are Operator Work Arounds have potential to:
awaiting retest. The work-off rate supports startup efforts.
* Impact safe operation during a plant transient
* impose significant burdens during normal operation The procedure in effect in April of 1996 froze the work-
* Crea nuisance conditions due to recurring equipment around population. The initial goal was set at "less than d ficiencies 10' for the original population. This goal will be met for
* Distract operators from noticing recurring conditions.
that original frozen population. However, it should be noted that beginning in 1998, a new procedur6 was put in it is desirable to have a small number of operator work arounds, place to control work-arounds and additional items began and to limit the time such work arounds persist.
to be processed as necessary to support operations.
These additional work-arounds are now shown on the This indicator depicts the number of operator work arounds that graph and not counted towards achievement of the goal.
exist, relative to Unit 3 goals for both number and age.
roel Comments
'he goal is to have no more than ten Operator Work Arounds prior Repairs that are complete, but awaiting retest under l
l:ntry to Mode 2. No deficiency shall be more than six months specific plant conditions are not included in the total.
v d without Unit Officer approval. This does not include the "new" Work Arounds.
Data Source:
L. Palone x4737MP l Analysis by:
K. Kirkman x5090l Owner:
J. R. Beckrnan x5361MP A8
 
Condition Roport Evaluation Quality Score l
Millstono 3 - July I
rogreSS:
Performance is satisfactory.
I 4 00 3 50 oal2 3.0 3 00 2 500 e
2.00 1.50 l
Good 0.50 0.00 5
s s
5 s
s 8
s s
s a
M Average Quality Score Goal l
RawOsta 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 Average Quality Score 3.60 3.14 2.50 2.89 3.33 3.40 3.64 3.20 3.67 3.00 3.40 3.82 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 Total Reviewed 5
7 4
9 9
10 11 10 6
6 10 11 Accepted 4
4 1
4 6
7 9
6 5
3 7
10 Accepted with Comrnent 1
3 3
5 3
3 2
4 1
3 3
1 Rejected 0
0 0
0 0
0 0
0 0
0 0
0 Rejection Rate 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Definition Analysis / Action This indicator reflects the quality of condition report (CR)
Average Quality Scores are consistently above the evaluations presented to the Management Review Team (MRT).
minimum acceptable score of 2.0, with most scores Each evaluation is reviewed for the adequacy of the proposed plan above the desired 3.0 quality rating.
to address the issues identified by the CR. Point values are l
assigned to each evaluation as follows:
The MRT is continuing to provide constructive feedback Accepted - 4 points to the line departments on areas where evaluations need Accepted with Comments 2 points improvement.
Rejected - O points l
l A weighted average Quality Score is then calculated:
(# Eva! X 4 oointsi+ (# EvalsWC X 2 ooints)
Total # Evals Reviewed Where:
# Evals = The # of evaluations accepted with out comment,
# EvalsWC = The # of evaluations accepted with comments, Total # Evals Reviewed = The total # of evaluations reviewed.
Goal Comments q
The goal is to achieve an average quality score a 3.0 on a scale of 0 4.0.
Supports SCWE Success Criterlon #2 D:ta Source:
AITTSl Analysis by:
W. Rein x3707MPl Owner:
G winters x5491MP A-9
 
Lcadorchip Assessmant (SCWE Elamont)
Millstone - June 1998
'1 (O Progress:
Progress is satisfactory. The June 1998 Leadership Assessment results indicate that the goal continues to be met.
100.0 %
q 90.0% -
Goal 90%
2 80.0%.
f 70.0% -
$ 60.0% -
b 50.0%-
en a
j 40.0% -
A 5
I 30.0% -
20.0% -
10.0% -
0.0%
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
% Employees Willing to Raise issues to Mgnt.
Leadership Goal i Raw Data Jul 97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98
% Employees Wilhng to Raise issues to Mgnt.
97.9 %
98.7 %
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 %
O 1
Definition '
AnalysisfAction 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 l
employee concerns.
Assessment is under evaluation.
This indicator is considered a valuable data point in I
evaluating the confidence and willingness of Millstone employees to raise issues to 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.
l l
Goal Comments The Goal is a 90% of the employees surveyed to report a Data is current through June 1998.
willingness willing to raise concems to their supervision.
O()
Supports SCWE Success Criterion #1 Data Source:
Leadership Assessrnentl Analysis oy:
M. Gentry x5728MPl Owner:
M. Gentry x5728MP B1 t
 
Culturo Survay (SCWE Ebmant) 1 Millstone - June 1998 1(m Progress:
Performance is considered satisfactory. Other short-term Indicators, L
Including ECOP survey results provide additional evidence of 1
performance quality.
100.0 %
90 0% -
l Goal 90%
2 80.0%.
< 70 0% -
f 60.0% -
50 0% -
g 40 0% -
l 2 30.0% -
Good 20.0% -
10.0% -
0.0%
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
!M% Employees Agree That SCWE Exists Culture Goal i Raw 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
% Ernployees Agree
['
That SCWE Exists 82 0%
86 6%
i 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%
Definition AnalysisfAction This indicator depicts the percentage of employees The June 1998 Culture Survey results fall short of the surveyed, by means of the Pil 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 1998 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 concems 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 used 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 to be determined.
Safety Conscious Work Environment.
When Culture Survey data is considered in conjunction with other indicators, including more recently administered Employee Concems Oversight Panel l
(ECOP) surveys, progress in this area is satisfactory.
t Goal Comments The goal is for > 90% of the employees surveyed to report Data is current through June 1998.
(qJ a willingness to raise concems to their supervision.
v Supports SCWE Success Criterion #1 Data Source:
Culture Survey l Analys/s by:
M Gentry x5728MPl Owner:
M. Gentry x5728MP B-2
 
f t
Sofoty Conaciouc Work Environment Empl3yees Willingn:33 to Ral:3 C:nc:rns NU Concerns and NRC Allegations Received, Millstone Station I(N l\\*) Progress: Performance is satisfactory. The number of allegations to the NRC remains at a Iow level while the number of concerns received by ECP is high.
l i
40 35 l
Data current 30 through 7/1/98.
25 5 20 i
e d
j 1
s 15 i
10 i
A q
l
{
S i 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 l
-e-NU Rec'd NRC Rec'd l
Row Onte 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 27 20 23 20 17 18 NRC Received 4
6 4
4 2
6 NU Rec'd YTD 27 47 70 90 107 125
,9 NRC Rec'd YTD 4
10 14 18 20 25 DeHnition AnalvelalAction This indicator depicts the number of concerns received each The increasing number of concerns submitted to the ECP month by the Millstone Employee Concerns Program (ECP) suggests growing employee confidence in the ability of i
relative to the number of allegations associated with Millstone the Millstone ECP to provide an effective means by which
?
issues or problems which have been submitted to the NRC concerns can be resolved. The average number of during the same time period.
concerns received per month from June through j
November 1997, was 14. The average number for
{
The Millstone Employee Concems Program (ECP) accepts December 1997 through May 1998 was 24, a 60%
concerns related to a wide variety of issues, including nuclear increase over the 1997 norm.
safety or quality, management, industrial safety, security and The total number received from Millstone employees was other topics. Concerns may be submitted by current or former 17 for June. One NRC referral was received on June 19, employees and contractors. NRC allegations regarding 1998. No new concerns were received for the month of Millstone issues may be submitted by the general public, July as of 7/1/98. Five allegations regarding Millstone for current or former employees and contractors or members of the the month of June were received by the NRC.
NRC. Concems may also be filed concurrently with the Data on concerns received by the NRC are reported twice Millstone ECP and the NRC in the same time period.
per month (mid and end).
~-b
.pogg :
; Comments :
NU has not established a specific goal with respect to concerns Data current through 7/1/98.
l r:ceived. However, it is desirable to have a small number of allegations submitted to the NRC and a larger number submitted to the ECP as a measure of employee confidence in NU resolution systems.
Supports SCWE Success Criterlon #1 Data Source:
C. Mhalko x4541MP l Analysis by:
C Mihalko x4541MPl Owner:
E. Morgan x4335MP B-3
 
Millstena Employca Concarna Confid nticlity Trcnd Millstcn3 St ti:n - July 1998
/
\\
\\
:YOgreSS:
The willingness of employees to raise concems is satisfactory. Less than 35% of Concemed Individuals requested confidentiality or are anonymous for 1998.
40 35 Data current through 7/1/98.
30 1 25 1
20 4
)15 10 mN 3
s
/
5 N
O 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 u Anonymous and Confidentiality Requested l ggi m
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Received by Month 27 20 23 20 17 18 Anonymous 7
3 6
7 2
6 Confidentiality Requested 3
6 0
2 1
3 Confidentiality Waived 15 12 16 11 14 10
*/. Anon. and Confidentiality Req 37.0*4 40.0 %
26.1 %
45.0%
17.6%
44 4 %
Defkdion Anaksin/ Action This indicator depicts the number of concerns which are reported to Less than 35 percent of concerns have been filed the Millstone ECP anonymously, and those for which confidentiality anonymously or requesting confidentiality since the is requested, relative to the total number of concerns received.
beginning of 1998. Based on the June 1998 numbers, the percent trend appears to be flat with the exception of Each individual submitting a concern may request or waive the March and May numbers. Our analysis of the confidentiality. Anonymous concerns are also submitted.
concerns data did not reveal any specific reason why this pattern occurred. ECP monitors this closely for any Concerns requesting confidentiality or anonymity are reviewed to adverse trend.
d termine (1) if there is a significant change in either the number or percentage of concerns filed anonymously or requesting Eight of the eighteen concerns received as of the end of l
confidentiality, (2) if any categories show discernible changes in June were either anonymous or requested confidentiality.
I make-up or source of the concerns, and (3) if any new " focus areas" No new concerns were received for the month of July as are identified.
of 7/1/98. The proportion waiving confidentiality (55.6%)
is consistent with the nine month ECP average of 61%.
: a. gogl2 m
Tha goal is to show no adverse trends in requests for confidentiakty Data current through 7/1/98.
or anonymity, based upon an analysis of the concerns and data.
The confidentiality status of two concerns received in January could not be determined since the employees
{
}
have left the site. The confidentiality status of one Supports SCWE Success Criterion #y concern received in March remains unknown.
l Analysis by:
C. Mihalko x4541MP l Owner:
E. Morgan x4335MP Defa Source:
C Mihalko x4541MP l
I B-4 L_________________________._
 
Employco Concerns Resolution Timeliness 1
Millstone Station - July 1998 togress:
Progress Is satisfactory. The improved timeliness of employee concems resolution achieved during the past year Is being sustained.
90 80-70<
60-g
<i!lllllllll t:
,,,,s I,,,
a,,
s sa sss**sll2 s
a s ss a
lE Average Age l ReevDets >
4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 7/8/98 trage Age 65 61 67 49 47 45 52 44 43 39 47 23 Jpen < 45 Days 22 16 21 18 23 24 17 15 17 24 19 15 Open > 45 Days 20 25 19 15 14 18 20 7
9 10 12 3
Concerna Under Investigation 42 41 40 33 37 42 37 22 26 34 31 18 DeRnMon 8
?
AnalysisfAction This indicator depicts the average age of concems under The average age of concems under investigation decreased investigation. Concems under investigation represent significantly from 6/24/98. This is due to older concems being Employee Concerns Program (ECP) work in progress, closed. The average age of concems is trending downward in including data gathering and analysis.
1998; however, ECP will continue to monitor this parameter.
Comments:
Data current through 7/1/1998.
g!
The goal is for the average age of unresolved concerns to how no adverse trend.
Supports SCWE Success Criterion #3 0:t2 Sourcer C. Mihalko x4541 MPl Analysis by:
C. Mihalko x4541 MPl Owner:
E. Morgan x4335MP B-5
 
Employca Satisfaction with ECP Millstena Station - Juns 1998 (m'tProgreSS:
Progress is satisfactory. A majority of employees surveyed who have G
used the ECP expressed a willingness to use the ECP again.
l 100 % -
90% -
g f)
S 80% -
Data is current through 3/31/98.
3 70% -
3 s
T 60% -
l k
i llg 50% -
1 l
f 40% -
Good l 30% -
20% -
l w 10% -
r
(
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 l
l E LHC Survey Results E ECOP Survey Results 1 Raw Data Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 LHC Results: % of fmployees Who Would Use ECP Again 63%
50%
83%
i ECOP Results: % of Employees Who Would l
Use ECP Again 75%
90%
l l
Definition Analysis / Action l
This indicator depicts the percentage of employees who have The LHC data shows an improving trend in employee used the Employee Concerns Program (ECP) for concems satisfaction with the ECP, although sample size is r: solution and report a willingness to use the program again.
relatively small. The ECOP percentages confirm LHC This data is obtained by means of surveys and interviews data and represent the larger sample population.
conducted by Little Harbor Consultants (LHC) and the l
Employee Concems Oversight Panel (ECOP).
In late March ECOP completed a survey of l
employees who have used ECP. The vast majority
(>90%) indicated that they would use ECP again, l
l 1
i Goal Comments A substantial majority of employees who have used the Data is current through 3/31/98.
i ECP to indicate that they would use the program again.
l l
Supports SCWE Success Criterion #3
\\
D*ta Source:
LHC/ECOPl Analysis by:
M. Gentry x5728MP l Owner:
D. B. Arnerine XO437MP t
B-6
 
1 1
I l
Focua Arm Action Plan Stttua i
Millstone Station - July 1998 1
(mh Progress:
Progress is satisfactory. Resolution of all focus areas is proceeding as expected.
y/
25 j 20
.6
$15l II0
~
Good i
i u.
t
]5 y
0 s
v l
8 5
s s
s a
s s
G 4
~
lGOverdue Action Plans ROpen Focus Areas l Rsw Dois 4/23/98 4/30/98 5/7/98 5/14/98 5/21/98 5/28/98 6/4/98 6/11/98 6/18/98 6/25/98 7/2/98 7/9/98 Open Focus Areas 8
8 8
8 8
8 8
8 8
8 8
Overdue Action Plans 0
0 0
0 0
0 0
0 0
0 0
Focus Areas 33 33 33 33 33 33 33 33 33 33 33 Action Plans in Place 8
8 8
8 8
8 8
8 8
8 8
Action Plans Completed 25 25 25 25 25 25 25 25 25 25 25 Action Plans To Develop 0
0 0
0 0
0 0
0 0
0 0
DeRnition Analy8is/ Action This indicator depicts the number of focus areas currently identified and All open Focus Areas have action plans in place.
the status of action plans to correct identified weaknesses. A Focus Area is defined as an area of personnel interaction where a Safety Several focus areas have been closed out and Conscious Work Environment is challenged or does not exist, assessment of others is still required before final close out.
l The following indications are used to identify the Focus Areas within the
)
Millstone organization:
Within the next few weeks this indicator will change to a Leadership Assessment score less than 4.0 (" Effective") in either the be more responsive of SCWE status.
Employee Concems area or the Overall score.
I
* 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 ascond indicator.
* Employee Concems Program - Significant or multiple occurrences 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.
* NRC loentified areas based on investigation.
Gont Comments e
The goalis to have the number of focus areas steady or declining at r: start with no overdue action plans.
Supports SCWE Success Criterion #4 Data flource:
A. Elms x5388MPl Analysis by:
A. Elms x5388MPl owner:
D. B Amerine XO437MP B-7
 
Subatcntictod Cencarno invelving Pat ntial Violations of 10CFR50.7 Millstone Station - July 1998
(
lrOgreSS:
Performance is satisfactory. There were no substantiated concerns involving v
aIIeged violations of 10CFR50.7 since August 1997.
I 40 l
l Data current 30 through 7/1/98.
l I
l j25 d 20 3
Good 15
)
10 N
5-0 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l M # Substantiated Potential 10CFR50.7 Concerns Total Concerns Received
-*-# Alleged 10CFR50.7 HIRD Concerns gg
:q
+
?
Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Total Concerns Recolved 27 20 23 20 17 18
# Alleged 10CFR50.7 HIRO Concerns 10 7
4 3
2 4
# substantiated Potential 10CFR50.7 Concerns 0
0 0
0 0
0 Total # of HIRD Concerns Received 16 11 11 10 4
7
% HIRO Concerns 59 %
55%
48%
50 %
24 %
39%
% Alleged 10CFR50.7 HIRD Concerns 37%
35%
17%
15%
12%
22%
5 w,_,, ~.
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 H RD Intimidation, Retaliation or Discrimination (HIRD), including those based issues, importantly, from December 1,1996 through on race, sex, and national origin. It depicts the number of potential and June 10,1998, only three concerns have been substantiated HIRD concems involving alleged 10CFR50.7 violations substantiated as involving a potential violation of r lative to the total number of concems received.
10CFR50.7, and all three are related to a single event (MOVs). Four alleged 10CFR50.7 concerns were 10CFR50.7 is a federal law which provides for the protection of received in June 1998 and are currently under individuals engaged in protected activities. An example of a protected investigation.
actrvity is when an individual identifies an issue that he/she believes impacts any aspect of activities at the Millstone Site that are regulated Open 10CFR50.7 concerns receive the highest by the NRC, and communicates that concern to co-workers, investigative priority. Site management continues to supervisors, the Employee Concems Program (ECP), the NRC, educate, address and when appropriate, discipline Congress, or the media.
any personnel involved in such activities.
l l
L:" '
Comane he goal is that substantiated concerns involving potential violations of Data current through 7/1/98.
OCFR50.7 are infrequent and haridled responsibly.
Supports SCWE Success Criterion #4 Data Source:
C. Mihalko x4541 MP l Analysis by:
C. Mihaiko x4541 MPl Owner:
E. Morgan x4335MP 8,8
 
Statua of Ovcrcight Condition Rcporto i
Millstono 3 - Juns 1998 l
(A)
Progress:
Progress is not meeting management expectations. oversight management will continue to monitorperformance.
50 40 Data thru 30 Good
\\
20 0
t i
I l
l l
l l
1 l
I Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 98 97 97 97 97 97 98 98 98 98 98 98 O Level 1 CRs >30 days old without approved CA Plan E Level 2 CRs >30 days old without approved CA Plan RawData Jub97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97 Jan-98 Feb-98 Mar 98 Apr-98 May-98 Jun-98 Open 67 31 28 31 38 45 31 33 19 45 42 50
[^s Total 1 &2 >30 days 1
6 3
2 6
25 9
6 3
17 7
15
(
I Level 1/>30 days 2/1 4/2 2/1 1/0 2/1 5/1 5/4 4/2 2/1 4/2 4/3 12/5 Level 2/>30 days 65/0 27/4 25/2 30/2 36/5 40/24 26/5 29/4 17/2 41/15 33/4 38/10 Definition Analysis / Action This graph displays the status of open Condition Reports Oversight will continue to monitor performance in (CRS) initiated by Nuclear Oversight for adverse, discrepant, completing Condition Report evaluations on time.
or other conditions needing improvement.
An Open Condition Report is one for which the evaluation for deportability and operability, failure mode and/or root cause has not been performed, or, has been performed, but not yet approved.
Goal Comments No Level 1 or 2 CRs open > 30 days without approved l
extensions.
M. Baldini x4456l Analysis by:
J Beauchamp X2113l Owner:
I Q Data Source:
J Streeterx43co C-1
 
Nuclear Oversight Restart Verification Plan Key issues Status - Millstone 3 greSS:
AII areas are considered satisfactory (green) with the exception of Engineering, Conduct of Operations and Mode Changes.
l 2/6/98 l 2/20/98 l 3/6/98 l 3/20/98 l 4/3/98 l 4/17/98 l 5/1/98 l 5/15/98 l 5/29/9 KEYISSUES Le:darsh SelfAssessment Y-
.Y Y
Corrcctive Action NSAB/Ove ht R Co ration Man ment Proc: dural Qualit dherence Y
Y Work Control /Planni Y
Y Y.
Y Y
Y Y
to Co Ilance SCWE Y-Y Y
Y Y
Emsr_qency Pre Y
Radiation Prciection S:curity Envin;;nmentalMonito Traini Y
Y Y
Y Y
Y' Y
^ ducto tions Y
Y Y
RSIGHTASSESSMENTAREAS Maint nancell&C C
Fire Protection Y'
Y Mat: rials Y
Y Y
Y Y
Y Y
Y Engineering Y
Y Y
Y Y
Y
'Y Y
Y Mods Chances *
(Mode 2 assessment began 5/1)
Y Y
Y Y
Each of the above listed issues are assessed based on a set of attributes derived from NU, INPO and NRC documents which provida standards, objectives and inspection guidance. In general, the color corresponds to following scores. Colors will normally change after two periods of consistent performance. NOTE: Nuclear Oversight management may determine that a diffsrsnt color is more appropriate based on its best judgment.
Satisfactory (GREEN) 70-100 I
-I improvement needed (YELLOW) 20-69
*All Mode 2 issues must be resolved to be rated
" Green" Significant weakness (RED) 019 An issue which has not been assessed (BLUE)
W s-~..
9-,..
C-2
 
Proccdura Complicnca Millstone 3 - July 1998 m()j Progress:
Progress is satisfactory.
/
1.00 l
0 80 '
KPl data current 1 080-through the end of
* 0 70 June 1998 o
2" 0.60 -
Goal < 0.5 g 0.50 -
20'4 '
Good l
l 0.30 -
l d 0.20 -
0.10 -
0.00 E
3 3
8 8
8 8
8 8
8 8
8 8
8 8
8 5
k k
4 4
I I
8
% Total Non Compliance Errors /1000 hrs Goal l Raw Data Oct-97 Nav-97 Dec 97 Jan-98 Feb-98 Mar-98 Apr.98 May-98 Jun-98 Total Non Compliance Errors /1000 hre 0.47 0.37 0.75 0.48 0.32 0.25 0.40 0.29 0.37 i
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 0.13 0 09 0.20 0.11 0.06 0.05 0.05 0.03 0.05 Admin Procedure Non-Compliance Errors /1000 hrs 0.34 0.28 0.55 0.37 0.26 0.20 0.35 c.27 0.32 HOURS WORKED (1000 HRS) 105.56 127.21 94.50 154.54 164.55 165.59 155.66 150.03 134.61 Technical Procedure Non-Compliance 14 12 19 17 10 8
8 4
7 Administrative Procedure Non Compliance Errors 36 35 52 57 43 33 55 40 43 Total Non Compliance issues 50 47 71 74 53 41 63 44 50 Definition AnalysisfAction 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 has resulted in a lowering of the threshold categories; non-compliance with technical procedure-these errors fpr reporting administrative procedure are associated with operational or maintenance procedures or work noncompliance. However, the Unit orders and are generally continuous or generallevel of use procedures; continues to meet the goal of < 0.5.
{
non-compliance with administrative procedure-these errors are
{
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 hours worked.
1 l
Gast Comments The goal is for procedure compliance errors (CRs) to be < 0.5 errors per thousand man hours.
j j
V l Analysis Sy:
Data Source:
AITTS B Rein x3707 MP owner:
G. Winters x5491MP D1
 
CR0 involving D3ficiant Tcchnicci Prccadurm Millstone 3 - July 1998 (o' Progress: Progress is satisfactory. A favorable performance trend which began after the Q,/
System Specific Assessment reviews, continued through the first half of 1998.
45 40 Data currerlt through July 23,1998 33
, 30 monthly g
trending g 25 5 20 GOOD 1 15
?
f 10 Goal < 5/ month bb_
bbl 0
U 0
0 02 03 04 Q1 O2 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun
'96
'96
'96
'97
'97 97 97 97 97 97 97 98 98 98 98 98 98 i M Upgraded IIZ:I:3Non Upgraded Goal i Raw Data Unit 3 Jul 97 Aug 97 Sep 97 Oct 97 Nov 97 Dec 97 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 upgrided 10 7
3 0
0 0
1 0
0 0
0 0
'en Upgraded 2
2 1
0 0
0 0
0 0
0 0
0 efinition AnalvelsfAction This indicator depicts the number of condition reports (CRs)
Following a peak in second quarter 1997 which gInerated as a result of procedure deficiencies. A review to resulted from SSA discovery efforts, the total number d:termine 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 10 procedures from the following departments: Operations, months, and remaining at zero for 8 of the last 9 Maintenance, instrument and Control, Engineering, and unit specific months.
Ch:mistry and Health Physics procedures.
The procedure upgrade effort for Unit 3 has been CRs involving administrative procedures and failed administrative completed.
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.
Goal The goal is to have no more than 5 CRs per month initiated as a result of procedure deficiencies.
Comments Data current through July 23,1998 i
Unit 3 Upgraded Procedures = 1244 Unit 3 Non-Upgraded Procedures = 0 Total No. of Unit 3 Level 1 CRs = 2 hotal No. of Unit 3 Level 2 CRs = 76 T
otal 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 D'ta Source:
AITTSl Analysis by: R Bireley/T. Kutterrnan x5421MPl Owner:
T. Kirkpatrick x6204MP l
D-2 l
 
1 Madian Aga 6f Loval1 & 2 Condition Rcports Millstone 3 - July 1998 j
f Progress:
Performance is not meeting the stated goal and additional management
's action is being taken.
l l
325 300 275 250 v
22s 200
=
=
=
=--
g
* 175 k150 GOOD 125 100 75 f
50 25 0
E h
h 6
4 5
5 5
8 S
N I-+-Level 1 CR Median Age -G-Level 2 CR Median Age j RawDets 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 7/8/98 7/15/98 7/22/98 7/29/98 Level 1 CR Median Age 245 245 245 261 251 242 237 243 249 250 245 0
Level 2 CR Median Age 190 100 190 198 202 201 200 202 213 213 222 0
Ext. Ider.t. Lvf 1 Med Age 155 155 155 176 176 190 197 204 211 218 225 0
(
Est ident Lvl2 Med Age 147 146 146 125 125 139 146 153 160 167 174 0
Int. Ident. Lvl 1 Med. Age 194 194 194 215 215 204 211 218
_225 212 219 0
Int. ident Lvl 2 Med. Age 208 208 208 200 202 211 217 223 230 237 244 0
Total Open CRs 3009 3068 3109 3146 3220 3275 3372 3432 3404 3403 3392 0
Open Level 1 CRs 231 233 236 238 240 246 253 249 250 254 258 0
Open Level 2 CRs 2778 2835 2873 2908 2980 3029 3119 3183 3154 3149 3134 0
CRs Open >120 Days 1017 1037 1060 1080 1136 1184 1267 1267 1269 1276 1295 0
Open level 1 >120 Days 114 118 119 121 124 132 142 138 139 140 147 0
Open Level 2 >120 Days 903 919 941 959 1012 1052 1125 1129 1130 1136 1148 0
Deninition.
AnalyslalAction This indicator depicts the median age of open Level 1 and 2 Current performance is not meeting the stated goal.
Condition Reports (CRs).
The median age of open Level 1 CRs has remained relatively flat and the median age of open Level 2 CRs l
is slowly increasing. Management will analyze the I
reason (s) for this adverse trend and take appropriate actions to correct those deficiencies.
1 I
l Goel Comments p
The goalis to have the median age of Level 1 & 2 CR's decline j
[
over time.
j N
I 1
AITTSl Analysis byt B. Ren x3707MPl Owner:
Data Source:
G Wnters x5491MP E1
 
Exocutivo Training Council Msting Millstone - June 1998
\\ilgteSS:
The Executive Training CouncII meeting frequencyis satisfactory.
6 ETC Meeting data through I
s 6/30/98 l
1 Better 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 l M Executive Training Council Meetings
" Goal Raw Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Executive Training 1cil Meetrigs 2
1 4
4 Gal 1
1 1
1 Definition Analysis /Acklon i
This indicator depicts the Executive Training Council (ETC)
No action required. ETC meeting frequency exceeds the l
meeting frequency. The function of the ETC is to:
established goal.
l Communicate management's commitment to safety, high standards, and the effective use of training to help improve i
workar performance, Provide management oversight of the Millstone training i
programs accredited by the National Academy for Nuclear Training, thereby demonstrating proper stewardship of the l
rcsources our company has provided.
j Communicate management's commitment to high quality, arformance-based training utilizing a systematic approach to j
l p
l training, thereby directly contributing to nuclear safety while supporting the proper emphasis on improved achievement of agreed upon schedules.
I Establish and monitor site training goals and performance I
indicators, thereby communicating the high standard necessary for sala, effective operations.
Review major changes to common site training programs.
Comments goalis 1 ETC meeting per quarter.
ETC Meeting data through 6/30/98 ETC was established in April 1997 Data Source: ETC Meeting Minutes l Analysis by:
J. Althouse x2916MPl Owner:
J. Cantrell x2600MP F-1 u____
 
Training Advisory Committso Meeting Millstone - June 1998 c gress:
Training Advisory Committee meeting frequency is satisfactory.
14 13 12 TAC Meeting data through 11 6/30/98 10 gg9 g
8-7-
Goal 2 3 Meetings per Otr.
og e-g 5
o 4
Better 3
 
==
= - - - - - - -
2 1
0 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 l
MTraining Advisory Commatee Meetings
" Goal f
R*w Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Training Advisory Committee
' ' *ggs 11 14 6
4
/
GoJ 3
3 3
3
's Definition AnalysisfAction This indicator depicts the Training Advisory Committee (TAC)
No action required. Unit TAC meeting frequency is tracking to meeting frequency. The function of the TACs is to provide meet the goal.
senior management oversight of Nuclear Training policies and programs and ensure the implementation of the SAT process.
Each Unit has had at least one meeting each quarter.
TACs assess training accomplishments relative to Unit goals, maintain the future focus on changing training needs and Unit 3 has had four TAC meetings cancelled during the months of industry requirements, and set the strategic direction for training May and June due to start-up priorities.
programs at the Unit level.
l 7 001 Comments The goal is 3 TAC meetings per quarter, which is equivalent to 1 TAC Meeting data through 6/30/98
,IAC meeting per Unit per quarter.
I\\
Dats Source: TAC Meeting Minutes l Analysis by:
J. Althouse x2916MPl Owner:
J. Cantrell x2600MP F-2 l
 
Curriculum Advisory Committee Mseting Millstone - June 1998 O}rOgreSS:
Curriculum Advisory Committee meeting frequency is not meeting estabilshed management goals.
160 1
Goal 2 55 CAC Meeting data f
140 120 Meetings per Otr.
through 6/21/98 l
100 1
80 -
g A
?. $
40 Better 20 0
3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 MCurriculum Advisory Commitee Meetings
" Goal R:wDats l
3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Curriculum Advisory Committee Meetings 126 143 106 32 Goal 55 55 55 55 Definition Analysis / Action This indicator depicts the Curriculum Advisory Committee (CAC)
The 2nd quarter performance is not on track to meet meeting frequency. The function of the CACs is to establish the established goal of 55 CAC meetings per quarter, effective training qualNtion prograrns and ensure the appropriate design, development, and implementation of SAT-Not all CACs have fulfilled their requirement to meet based training programs. CACs review, recommend, and approve each quarter. Training Advisory Committees (TACs) various actions related to new and existing training programs, have been informed of this adverse trend. TACs have re-inforced the meeting frequency requirement with Station Procedure TO-1, Personnel Qualification and Training station management.
attachment 13, establishes the conduct of CAC meetings. CACs l
are required to meet at least quarterly. CACs are chaired by a l
member of station management.
Goal Comments The goalis 55 CAC meetings per quarter which is equivalent to 1 CAC Meeting data through 6/21/98 C smeeting per CAC per quarter.
1 l
D:ta Source:
CAC Meeting Minutes l Analysis by:
J Althouse x2916MPl Owner:
J. Cantrell x2600MP F-3
 
Simulator Availability Millstone-June 1998 gresS:
Simulator availability is satisfactory.
Simulator Availability data through 6/30/98 1000*'
Goal > 99%
4 98 Be er
~' ' ! '
98.0% -
3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 M Availability MP1 Availabildy MP2 Availability MP3 Goal Raw Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 i
Availability MP1 100 00 %
99.37 %
99 70 %
99 70 %
Availability MP2 99 43%
99 77 %
99 60 %
99.90 %
"vailabildy MP3 99 88 %
99 94 %
100 00%
99.40 %
l Goal 99 00 %
99 00 %
99.00 %
99.00 %
l Definition Analysis / Action i
This indicator depicts the simulator availability for all three No action required. Simulator availability for Units 1,2 & 3 is Millstone Units.
above goal.
i l
l l
Gon!
Cominents The goal is to rnaintain greater than 99.00% availability for each Simulator Availability data through 6/30/98
't Simulator through Unit restart.
l I
Data Source:
J. Cataudella x2603MP l Analysis by:
J. Althouse x2916MPl Owner:
J. Cantrell x2600MP F4
 
Millstono Station Lead rship Asscssment June 1998 Progress:
AII categories are slightly down from the Winter 97 survey.
/mI Extraordinary 8.00 7.00 Very Effective 6.00 y
g 5.00 Effective r
4.00 v
i 1
l 3.00 Good j
Somewhat Effective y,gg Inettective 1.00 Communications Leadership Performance Development Employee Concerns
* I EWinter-96 O Summer-97 O Winter-97 O Summer-98 l
* category added in Summer 97 l
Raw Data Winter-96 Summer 97 Winter.97 Summer-98 Winter-98 Communications 4.77 5.61 5.75 5.72 Leadershp 4.95 5.77 5.88 5.84 Performance 4.42 5.29 5.34 5.31 D:velopment 4.64 5.45 5.54 5.53 Employee Concerns 6.11 6.19 6.15 Definition Definition (continued)
The Leadership Assessment is a management tool for evaluating The primary purpose of the Leadership Assessment is to the relative strengths and needs of individual management provide meaningful information 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 questions are posed to employees regarding leadership evaluated at an organizational level to trend improvement performance in four separate categories: Communications, in management performance.
Leadership, Performance Accountability, and Development; a fifth category for evaluating performance relative to Employee Concerns was added to the assessment in the Summer of 1997.
Analysis / Action R sponse 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).
l
?
Goal Conunents The organizational goal is to show improving trends in all categories.
Darm Source:
Leadership Assessment l Analysis by:
J Gorski x0462MPl Owner:
J Gorski x0462MP G -1 u______________._________..._._________
 
Millstons Station Cultural Survey Juno 1998
[9 agyegg:
Results from the June 1998 Culture Survey show a slight decrease in 7
the Adjusted Culture Index. Overall, the data Indicates a sustaining of the positive culturalImprovement observed over the last year.
25.00 20.00 15.00 Goal = 13.0 10.00 -
l Good 5.00 0.00 Jun-96 Oct-96 Jun-9~7 Nov-9'1 Jun-98 l
WAdjusted Culture Index wwcara Jun-96 Oct-96 Jun-97 Nov-97 Jun-98 djusted Culture Index 11.60 11.46 12.88 13.07 12.99 Jumber of Partic: pants 1026 1240 1487 1926 2066 Goal 13 13 13 13 13 Definition Analysis / Action NU originally contracted Performance Improvement Despite the slight decrease (< 1%) in the Adjusted International, Inc. (Pil), formerly FPl, 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 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 Watch List plants. A Cl of Lateral Integration, Simple Work Processes, and Strong greater than 14 indicates a strong probability 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 l
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 effor 's and monitoring is fully appropriate.
Goal Comments l
UU has established a goal to achieve an Adjusted Cultural index of 13.0.
D:ts Source:
Culture Survey Analysis by:
M. Gentry x5728MPl owner:
E. V. Fries x5458MP G-2
 
RCA Docimetry Daficiencios Chart Millstone - June 1998 OgYOSS:
Performance in this area is satisfactory.
50000 45000 KPl data is current as of June 4oooo 30,1998.
35000 Goal s 1 error per 25,000 July Aug.
Sept.
Oct.
Nov.
Dec.
Jan.
Feb.
Mar.
Apr.
May June
'97
'97
'97
'97
'97
'97
'98
'98
'98
'98
'98
'98 l M Cumulative RCA Entries per 1 Error Goal. < 1 Error per 25,000 Entnes l Raw Dets '
July '97 Aug. '97 Seot. '97 Oct. '97 Nov. '97 Dec. '97 Jan. '98 Feb. '98 Mar. '98 Apr. '98 May '98 June'98 Cumulative RCA Entries per i Error 22,419 25,282 24,431 26,893 29,024 32.263 34.463 36,312 36,528 35,201 36,377 37,487 Goat: < 1 Error per 25,000 Entries 20,000 20,000 20.000 20,000 20,000 20,000 20,000 20.000 20,000 20,000 20,000 25,000 Cumulative RCA Entnes 448.378 505.640 586.345 672.336 754.624 838.838 896.043 944.117 986.266 1,020 816 1.054.945 1.087.129 Cumulative RCA Entry Errors 20 20 20 24 25 26 26 26 26 27 29 29 Definition Analysla/ Action This indicator depicts the number of Radiological The cumulative RCA entry rate shows a positive (improving) trend from Controlled Area (RCA) entries per error. The January 1997 through June 1998.
Cumulative RCA Entry Error Rate is defined as the ratio of Total Error Events to Total RCA Entries. Error events To allow chart clarity above, the data as shown represents the last 12 are any instance in which an individual enters the RCA month period. The cumulative data from Jan.1997 to June 30,1998 without a Thermal Luminescent Device (TLD) and/or an shows over 1 million RCA entries have occurred. During the first 6 months Electronic Dosimeter, of 1998 we have leveled off at approximately 1 dosimetry error per 37,000 RCA entries.
Actions taken in June of 1997 to enhance the RCA entrance procedure through the use of mechanical, one-way " turnstiles" have eliminated a prevalent " human factors" deficiency in the entry procedure. The two RCA dosimetry events occurring in 1998 were in RCA entry points that do not have mechanical turnstiles installed because of their low traffic volume.
l Additional turnstiles, however, have now been installed at low RCA traffic areas to maximize RCA dosimetry compliance.
Goal Comments Th3 current goal is to have s 1 error per 25,000 RCA KPl data is current as of June 30,1998.
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 7.
elevated to insure the establishment of a " continual self-improvement" l
culture.
Data Source:
C. R. Pairner x52'6MP Analysis by:
M Wood x5049MPl owner:
W Novelos x2158MP H1
 
1998 Exposuro Summary 1
Millstone 3 - June 1998 l
p' Ogress:
Performance in this area is satisfactory.
;O 60 55-1998 Goalis s 51 rem 50-45-40-35" Exposure data is g 30-through June 30,1998 25-20-15-M N
O I
I I
I I
I I
I I
I 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 Cumulative Exposure Cumulative Goal l
RawDats 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 4209 8.082 11.826 14.480 21.770 22.500 Cumulative Goal 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000
. >finition Analysla/ Action This indicator depicts the cumulative radiation exposure for the The cumulative exposures are tracking well within the year (person-rem year to date) vs. the cumulative radiation levels needed to maintain doses as low as reasonably exposure goal for the year for Millstone Unit 3.
achievable (ALARA).
This goal represents the level of exposure which the Health Physics department strives to stay below in order to maintain occupational exposures as low as reasonably achievable (ALARA).
Goal Comments The Goalis to have s 51 rem of total radiation exposure for Exposure data is through June 30,1998
'it 3 in 1998.
I
}
l Data Source:
D. Evans x0080MPf Analysis by:
C. R. Palmer x5256MPl Owner:W. F. Nevetos x2158MP H-2
 
i Self Reporting Culture Chart Millstone - June 1998 i
VTOgYOSS:
Performance in this area is satisfactory.
Goal > 75% events self-identified KPI data is current as of June 30,1998.
f 100 %
j 8W.
3 A
60% -
Bt G00d 40%
20%
0%
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May JOn 97 97 97 97 97 97 98 98 98 98 98 98 l M% of Self-identified Events Goal > 75% self-identified events l Raw 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
% of SeN-identNied Events 100 %
100 %
100 %
100 %
100 %
100 %
100 %
100 %
100%
100 %
100 %
100 %
al > 75% seN-identNied evants 75%
75 %
75%
75%
75%
75%
75%
75%
75%
75%
75%
75%
Self identified Events 0
0 4
1 1
0 0
0 1
2 0
0 Nuclear Oversight identsfled 0
0 0
0 0
0 0
0 0
0 0
0 NRC Identified 0
0 0
0 0
0 0
0 0
0 0
0 Total Eventt 0
0 4
1 1
0 0
0 1
2 0
0 De6nition Analysis / Action 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. During this of a culture in which personal' ownership'of the Radiation period, all dosimetry events have been identified and Protection Program is demonstrated through the number of self-reported by workforce personnel rather than Nuclear identified deficiencies.
Oversight or Nuclear Regulatory Commission reports.
The measure is considered meeting the KPI goal when the l
number of self identified events are > 75% of the total numt.er 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.
Goal Comments -
l The goal is for > 75% of all dosimetry deficiencies to be self.
KPi data is current as of June 30,1998.
identified.
C. R. Palmer x5256MPl Analysis by:
M Wood x5049MPl owner:
Data Source:
W. Novelos x2158MP H-3
 
Control of Safoguarde information Millstone Site - June 1998
,m b
{ V g(OSS:
Control of safeguards Information is satisfactory.
5 Data is current through 4,
June 30,1998 1998 Goals 3 events for the year Good
/
1 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 MCumulative Safeguards Events Goal Raw Dets Jan-98 Feb-98 Mar-98 Apr-98 May 98 Jun-98 Jul-98 Aug-98 Sep-98 Oct 98 Nov-98 Dec-98
' mutative Safeguards Events 0
1 1
1 2
2 Goal 3
3 3
3 3
3 3
3 3
3 3
3 Safeguards Events (Monthly) 0 1
0 0
1 0
Definition Analysis / Action This indicator depicts the cumulative number of events where The 1998 goal to have no more than 3 events per year Saf: guards 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 two quarters of 1998 two events have occurred.
on information obtair ed from Security Reports and Condition in February a CAD drawing was found to be improperly R ports.
controlled. This drawing was later declassified to non-safeguards status. In May a safeguards document being used for training purposes was left uncontrolled.
Both events were considered to be isolated incidents.
The Security Department will continue to monitor the program and investigate additional actions for improvement.
Goal
\\
Comments The goal is to have no more than 3 safeguards events per year.
Data is current through June 30,1998 l
I l
Da1 Source:
Security and Condition Reports l Analysis by:
M. Skorupski x4905l Owner:
M. Skorupski x4905 1-1 k
 
t Vchicla Contral incida tho Protccted Arca Millstone Site - June 1998
\\
lOgYOSS:
Performance is satisfactory.
v 14 ~
12 Data is curront through 10 June 30,1998 f
Good T
1998 Goals 6 events for the year V 6 Y
4-2 0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 08 98 98 98 98 98 98 98 98 98 98 98 l
m Cumulative Vehicle Events Goal Raw Dets Jan-98 Feb-98 Mar 98 Apr 98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98
- umulative Vehicle Events 1
1 1
3 4
4 Goal 6
6 6
6 6
6 6
6 6
6 6
6 Vehicle Events 1
0 0
2 1
0 Definition Analyela/ Action This indicator depicts the cumulative number events where The station urrently has 66 vehicles inside the v:hicles were not controlled properly in accordance with station Protected Area as Designated (61) and Temporary procedures. Events involve keys left in unattended vehicles.
Designated (5) Licensee Vehicles. An average of 8 This data reflects the actual number of events based on Non licensee Vehicles enter and exit on a daily basis, information obtained from Security Reports and Condition An average of 47 totalvehicle transactions occur R ports.
through VAP daily.
l l
l Goal Comments The goal is to have no more than six vehicle events per year.
Data is current through June 30,1998 I
Da'1 Source:
Security and Condition Reports l Analysis by:
M. Gelinas ext. 4258l Owner:
M Gelinas ert. 42s8 l2 L__-___-_______-___
 
l Sccurity Badga Control l
Millstone 3 - June 1998 gress:
Progress is satisfactory.
j 14 KPl data is current through I
s 12 June 30,1998 l
. 10 S
[g Goals 8 l
Good 1
I I
m 6 E
O I
I I
I I
I I
l l
l l
l Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 08 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l
m Security Badge Control Evtc ts Goal RawDets Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 sep 98 Oct 98 Nov 98 Dec 98 7
7 4
3 4
7
'rity Bad e Control Evente 9
Gul 8
8 8
8 8
8 8
8 8
8 8
8 Szcurity Badge Control Events 7
14 18 21 25 32 (Total)
~
Definition Analysia/ Action l
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.
Insido the Protected Area. This indicator reflects the actual number of events. The data is obtained from Security Reports (SRs) and Condition Reports (CRs).
l Goal Commente '
The goal is to have s 8 events per month for 1998.
Station population has steadily decreased from 4875 on 1-1-98 to 4095 on 6-30-98.
s Source:
SRs/CRsl Analysis by:
M Klein x4376MPl Owner:
M. Klein x4376MP l-3
 
i Centrcl cf Vicitors incida tho Protocted Area i
Millstone 3 - June 1998 greSS; Progress is satisfactory.
4 l
i l
\\
l KPI data is current through 3
g June 30,1998 w3 j
4 8o Good 4
i (j,
Goal s 1 li 0
0 0
0 0
. I t
I i
i i
i l
I i
i Jan 9F Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l
Visitor Control Events
- Goal RawDatn 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 Goal 1
1 1
1 1
1 1
1 1
1 1
1 Visitor Control Events Total) 0 0
2 2
2 5
Definition Analysia/ Action This indicator depicts the number of events where visitors or All five incidents involved situations where escorts and visitors escorts committed violations of the security escort exited the Protected Area tumstiles in reverse sequence -leaving requir:ments. This indicator reflects the actual number of the visitor unescorted in the Protected Area for a brief period in everits. 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 escort'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 l
include responsibility acknowledgement 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.
Goal-Comments The goal is to have s 1 event per month for 1998.
The average number of events / month for the first two quarters of 1998 is below the goal of no more than one event per month.
l I
Data Source:
sRs/CRal Analysis by:
M. Klein x4376MPl Owner:
M. Klein x4376MP l
l-4
 
1 Survoillanco Toot Program Schedule Performance
{
Millstone 3 - June 1998 I
YOgreSS:
Performance is satisfactory.
1 i
1 i
100 %
,3 a
Goal 190%
g g
80%
d g{,os j
l 70%
l 50 %
Good E 40%
)
30 %
e
)
10%
0%
I k
k k
h f
k e
s s
s s
s s
s
~
u l M % Completed Prior to Grace Period Goal l Raw Date '
4/1548 4/22/98 479S8 54/98 5/13S8 5/2048 5/2748 6G98 6/10S8 6/1748 6/24 S8 7/198
% Completed Prior to Grace Period 100 %
95%
78 %
87%
64 %
92%
88 %
91 %
85%
96 %
95%
0%
Goal 90 %
90%
90 %
90%
90 %
90 %
90%
90 %
90 %
90 %
90 %
90%
Completed Pnor to Grace Period 132 56 29 47 25 44 28 31 28 26 19 0
Tests Completed as Scheduled 132 59 37 54 39 48 32 34 33 27 20 0
l Definition AnalysisfAction This indicator depicts the percentage of surveillance tests performed prior An effort is ongoing to get surveillance tests scheduled to entering the grace period. The grace period is defined as 25% of the and performed as specified in the 12 week work week Technical Specification (Tech Spec) surveillance frequency. (e.g. Tech planning schedule.
Spec surveillance frequency = 31 days, grace period is 25% of 31 days =
7 days)
Poel Comments "he goalis to complete z 90% of surveillance tests prior to entering the The data displayed represents the previous week's
{
IS% grace period.
schedule performance.
PMMSl Analysis by:
R. Rothgeb x5241MPl Owner:
Datt Source:
C Schwarz r0491MP J-1 a
 
Ovardua Provantivo Maintanonca AWOa Millstone 3 - June 1998 m
J Progress:
Progress is satisfactory.
i'\\,
40 30 -
Good g
g 20-E 10-g
,E.
M0 0
0 0 0 0 0
0 0
Goal = 0 5
I l1 5 i I8 5
8 8
i 5
! II a
s s
5 s 008 E l ~!
8 s
e s
s s
s a
s l
AWOs Overdue Work-Off/ Goal l
Raw Dets 4/848 4/1648 4!22S8 429/98 6AB4B 6/13/98 6/20/98 SG7/98 6/3/98 6/10/98 6/17/98 6G4S8 AWOs Overdue 0
0 0
0 0
0 0
0 0
0 0
0 Workett/ Goal 3
2 1
7 N., j)
,(
Definition Analysis / Action This indicatoe depicts the number of Overdue Preventive There are 0 overdue PMs.
Maintenance (PM) Automated Work Orders (AWOs).
Overdue PMs due to scheduling will continue to occur due to lead time for deferrals and the transition from an Restart is defined as " Ready to Enter Operational Mode outage schedule to the on-line Work Week schedule 2", which is the point at which Commission approval is required.
Management will continue to monitor this parameter.
This data is being analyzed and addressed on a daily
: basis, i
i l
Goni Comments The goal is to have zero overdue PM AWOs prior to restart.
lA\\
L_)
Data Source:
D. A. Bannet x3062MPl Analysis by:
R. M Chnuelecki x6122l Owner:
J R Beckman x5361MP J-2
 
On Lino Schcdulo Performance Millstone 3 - July 1998 O (OSS Qg Performance is not meeting current management expectations.
% Work Activities Started on Time
% Work Activities Completed on Time 100 %
100 %
90% -
90*/. -
80%
Goal 75% g 80 %
Goalz 70%
70 %
70 %
60% -
60 %
SO% -
Sc%
40 %
40%
30% -
Good 30 %
Good 20%
20%
10%
10%
0%
0%
m m m e e
m S" $ $
e e
e e e e m 5
$S 5 SS*E S
5 9 3 5 SS"E l
M Percent Started Goal (starts) l I
MPercent Completed l
Goal RawData 4/25/98 5/2/98 5/9/98 5/16/98 5/23/98 5/30/98
&G/98 6/13/98 6/20/98 6/27/98 7/4/98 7/11/98 Percent started 71 %
72%
75%
66%
73%
75%
83%
66%
66%
70%
82%
l Goal (starta) 75%
75%
75%
75%
75%
75%
75%
75%
75%
75%
75 %
75%
Total Scheduled to Start 139 176 173 229 258 234 297 223 223 256 160 Total Suded 98 126 130 150 188 175 247 148 148 179 131 Percent Completed 69%
71 %
72%
61 %
70%
72%
84%
65%
65%
67 %
77%
Goat IO%
70%
70%
70 %
70%
70%
70%
70%
70%
70%
70%
70%
Total Scheduled to Complete 139 174 187 230 234 235 269 201 201 233 160 Total Completed 96 124 135 141 164 170 225 131 131 155 123 Definition Analysis / Action '
This graph illustrates the performance of scheduled starts The goals for Work Activities Started and Completed on Time have j
and completions of work activities detailed in the on-line 12 not been consistently met due to emergent work activities and l
i wrik rolling PMMS AWO (automated work order) work plan.
rescheduling required to support the start-up and power ascension, j
l This is tracked on a weekly basis.
l The date is captured Friday before the work week and analyzed the Monday following the work week.
i l
''o01 Comments
> goals are that 75% of work activities are started on time Date indicates the end of the work week.
l 70% of work activities are completed on time (within work
,Dru Source:
P3 Schedule l Analysis by:
J. Leger X2391MPl owner:
C. Schwarr x0491MP J3 l
 
Rccovory Backlog - Opan Op3rability Datorminations Mllistone 3 - June 1998 O greSS Engineering will be resource loading the deferred items for the first quarter following entry into mode 2 (6/30 - 9/30).
l 50 40 b
M 30 Good O
i 1
1 0 20 oe l
l 0
5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 6/29/98 7/W98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 W26/98 l
5 Backlog Open ODs O New Open ODs I
R~w Dets 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 6/29/98 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 Backlog Open ODs 24 27 27 29 30 30 28 New Open ODs 0
0 0
0 0
0 0
Total Open ODs 24 27 27 29 30 30 28 l
l Definition Analysis / Action This indicator depicts the number of open Operability Engineering will be resource loading the deferred items for the first D: terminations (ODs). Open ODs tied to USQs remain open quarter following entry into mode 2 (6/30 - 9/30).
l l
until approved by the NRC.
l 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 quahfi d requirements.
l l
l J
Goal Commerts The Open OD recovery backlog will be dispositioned by entry v mode 2 following completion of Refueling Outage 06 plus onths.
j
{
D:t: Source: Operations OD Log & CR/AR Status l Analysis by:
R. McGuinness x6855MPl Owner:
G Swider x5381MP l
1 K1}}

Latest revision as of 20:45, 22 May 2025

Station/Unit 3,Second Quarter Performance Rept for Jul 1998
ML20237B478
Person / Time
Site: Millstone Dominion icon.png
Issue date: 07/31/1998
From:
NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20237B473 List:
References
NUDOCS 9808180322
Download: ML20237B478 (150)
v • d • e


Text

I 4- > ;,

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s. ;j HIILLSTONESTATION/ UNIT 3 i

SecondQuarter l

PerformanceReport 9

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JULY 1998 i

i 9808180322 980811 DR ADOCK 0500 3

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MILLSTONE STATION UNIT 3 Second Quarter Performance Report

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JULY 1998 l

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TABLE OF CONTENTS I

V Second Quarter Performance Report 1.

Performance Monitoring Report - Introduction.......................................1

11. Perfo rm an ce on Key i s s u e s...........................................................................

i 1. L e a d e rs h i p..................................................................................

......5 I

1

2. Safety Conscious Work Environment................................................ 8 j
3. S elf-As s e s s m en t................................................................................ 14
4. C o rre ctiv e Acti o n................................................................................ 1 6 5. O v e rs i g h t........................................................................................... 2 0
6. Config u ration M ana g em ent................................................................ 24
7. R eg ulato ry Com plianc e..................................................................... 29 8. T rai n i n g............................................................................................. 3 9
9. Ope rational P e rfo rm ance................................................................... 4 2
10. Wo rk Cont rol an d Plan ning................................................................ 47
11. Proced u re Quality and Adherence..................................................... 50

{

12. E m e rg e n cy Pl an nin g.......................................................................... 5 3 l

p)

(-

13. Radiological P rotectio n...................................................................... 57 1 4. S e c u ri ty............................................................................................. 61
15. Environ montal C omplia nce................................................................ 65 Appendix 1 Key Performance Indicators Millstone Unit 3 Safety Conscious Werk Environment Oversight Procedure Compliance and Quality AdditionalCorrective Action /Self-AssessmentIndicators Nuclear Training Culture and Leadership Radiological Protection Security Additional Work Control Configuration Management

( A.

Additional Operational Readiness

(

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()

PERFORMANCE REPORT i

l l

Introduction The successful efforts throughout the station which have raised performance for each of the sixteen Key issues to a standard supporting restart authorization must be maintained in the future. For each Key Issue, significant accomplishments were achieved through extensive, dedicated efforts. This level of performance is being sustained by carefully tracking the designated key performance indicator (KPI) data, supplementing the on-going efforts with directed self-assessments, and taking appropriate action if performance fails to meet or exceed management expectations.

' NSAB performance will be assessed by the Nuclear Group CEO. For each of the remaining 15 Key Issues previously established Success Criteria for recovery, related self-assessments planned for 1998 are listed, and the corresponding performance measures, including Key Performance Indicators (KPis), are identified.

I Success Criteria, modified to define sustaining performance, are included to reiterate l

the baseline for future performance. KPis provide an important indication of performance. He key concept is that KPis are a tool to:

V) i l

. Identify areas requiring focus or additional management attention; J

Identify barriers to success; and Identify improvement strategies.

Management uses the KPis to monitor performance against goals and expectations and to determine the need for remedial action. Reviews of the indicators are regularly performed. When performance is not meeting established standards or goals, the responsible individual provides an analysis as to why performance is deficient and takes action to bring performance back to the specified standard. KPis are provided l

weekly to Millstone senior management and monthly to the NU Board of Trustees.

Assessments are conducted routinely to verify acceptable performance and validate the information presented in the KPls. These self-assessments include, but are not limited to, those currently planned during 1998. Assessment topics may be added, substituted, deleted, or rescheduled as circumstances dictate during the course of the year. For some Key issues, the list of assessments includes a combination of self-assessments, monitoring activities by Nuclear Oversight, the Nuclear Safety Assessment Board, the Training Advisory Council, and " Window Annunciators".

1 Each of the 15 Key issues will be monitored through the remainder of 1998 and into mid-1999.

b Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_P E R F\\R M\\P M-207.D O C

--___----__________________________u

2 Nuclear Oversight Restart Verification Plan 0

During the second quarter of 1998, Nuclear Oversight continued monitoring the progress of Unit 3 recovery following the protocois of the Nucl ear Oversight Restart Verification Plan (NORVP). Key issues were assessed based on a set of attributes derived from NU, NRC and industry documents. Color codes were assigned to each key issue based on a scoring system (0-100) and best judgment. In general, the colors correspond to the following scores: Satisfactory " green"70-100, Improvement needed

" yellow" 20-69, Significant weakness " red" 0-19. (See KPI C-2)

The following chart summarizes the results of the NORVP for the Key issues for the second quarter of 1998:

Keyissue-NORVP Summary Leadership Leadership was rated as " green," (satisfactory) for all of the second quarter. Oversight noted good management controls for the recent PASS drill and good ownership and interactive dialog during strategic planning meetings. Improvement was needed to refocus line management attention to safety issues.

Self-Assessment Self-Assessment was rated as " green" throughout the second

(

quarter. Strengths were noted in the new Environmental Services

(

Group self-assessment program and the establishment of an Engineering Quality Review Board. Improvements were noted as being needed in the area of reporting results, not just activities, and following self-assessment outlines.

Safety Conscious Safety Conscious Work Environment improved from a " yellow" Work Environment (improvement needed), rating at the very beginning of the quarter to a " green" for most of the second quarter. Favorable progress was observed in all success criteria with recommendations for improvement noted in increasing line ownership of the Safety Conscious Work Environment process.

Corrective Action Corrective Action for Unit 3 was rated as " green" for the entire second quarter. Highlights included the development of the HP Work Observation program and line management attention to identifying issues. Increased attention was noted as being needed in the area of prioritizing deficiencies on the basis of safety significance.

Oversight Oversight (Recovery) was rated " green" in the second quarter.

Various organizations have shown interest in Nuclear Oversight participation and the role of Oversight in the recovery has been favorably acknowledged at public meetings. More attention was Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\P M-207. DOC

(

l l

j 3

1 Key lasue NORVP Summary

' O" noted as being needed to a training program for NO personnel.

Configuration Configuration Management was rated as " green" during the Management second quarter of 1998. Pluses were noted in the areas of identifying design inputs. Several productive CM meeungs were held to discuss Safety Evaluation Screenings and the graded approach to Configuration Management.

Procedure Quality Procedure Quality and Adherence was rated " green" during the and Adherence second quarter with several management initiatives designed to continue to enhance procedure effectiveness noted as pluses.

The need to include procedure review as a component of pre-job briefs was noted as an area needing improvement.

Work Control and Work Control and Planning was rated as " yellow" for the first half Planning of quarter but improved to " green" for the second half.

Improvements were noted in reducing preventive maintenance tasks, scheduling on-line activities on time, and reducing the on-line backlog.

Regulatory Regulatory Compliance was rated as " green" throughout the C]/

f Compliance second quarter. Reporting period highlights included the conduct of self-assessments and the closure of SIL packages. An attribute noted as needing attention or continuing improvement included ownership and involvement in safety evaluation screenings.

Emergency Emergency Preparedness was rated as " green" for the entire Preparedness second quarter. Response and call-in drills were conducted satisfactorily. The operability of the PASS system was resolved prior to entry into Mode 2. Oversight noted the need to maintain a

" questioning attitude" conceming the acceptability of equipment associated with the Emergency Plan.

Radiation Radiation Protection was rated as " green" for the entire second Protection quarter. Strengths were reported in the areas of self-assessments and raising standards for the threshold for CR documentation.

Security Security continued to be rated as " green" for the second quarter.

Security was noted as being pro-active in communicating safety and security reminders to the site. Security was noted as needing to maintain site awareness of proper badge control and visitor escort responsibilities.

m (V)

Environmental Environmental Monitoring was rated as " green" for the second Protection quarter. Positive attributes included clarifying ownership for Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM 207. DOC

4 Keyissue.

NORVP Summary

\\p i

V environmental programs and preparing a draft Master Manual covering environmental areas. Weaknesses included the need for better coordination and the need to take action to preclude EPA violations.

Training Training performance improved from " yellow" in the early part of the quarter to " green" at the close of the quarter. Training programs showed an improvement in verification of a number of Corrective Actions associated with a June 1997 audit.

Management expectations were met in the areas of Unit 3 Engineering training and support of rotational assignments with Nuclear Oversight.

Conduct of The Operator Readiness (Operational Performance) issue was Operations alternately rated " green" and " yellow" during the second quarter.

l The latest rating was " yellow" which underscored the attention l

needed to be given to completing corrective actions for I

configuration control events. Additionalline management and Nuclear Oversight attention has been placed on operator performance, and improvements have been noted.

All of the Key Issues were judged to be acceptable for entry into Mode 2 prior to the mode change to Mode 2.

The Nuclear Oversight Restart Verification Plan (NORVP) which addressed recovery issues for Unit 3 is being succeeded by the Nuclear Oversight Verification Plan (NOVP) which will cover recovery, restart and on-going operations at Millstone. The NOVP is designed to provide an integrated and rigorous Nuclear Oversight assessment of the readiness of Millstone to ceniact a safe recovery and reliable and event-free operations. The next quarterly submittal will report the results of the NOVP assessments.

l t

l Od i

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5 l

'n 1

()

Key issue: Leadership--

l 1

Success Criteria l

I The following Success Criteria are established and summarize the performance

{

baseline for this Key Issue:

l 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

,G The following self-assessments are currently planned for 1998:

b 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 will be used for the on-going monitoring of this Key Issue:

Leadership Assessment Pil Culture Survey Skip-Level Leadership Assessment A

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L____

6

(~'\\

V Second Quarter Status Leadership Assessment Instruments Assessment Title -

schedule.

Completed Revised Date (Y/N) schedule if Not Complete Nuclear Oversight Restart Bi-weekly Y

Verification Program Report (NORVP)

Leadership Assessment 2nd Y

Quarter Pil Culture Survey 2nd Y

Ouarter Assessment Results Leadership Assessment

/n\\

A Leadership Assessment was conducted at Millstone Station during May 1998.

O Results are based on 2066 assessmant forms from both employees and contractors. Preliminary results of the survey show that employee perception of leadership effectiveness has held steady since the survey was last administered

)

in November 1997. The overall effectiveness score was 5.76 in May 1998 versus 5.80 in November 1997. (A score between 4 and 5 is considered

" effective." Scores above 6 are evaluated as " superior.")

The leadership scores improved the most from the initial survey in the 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 May 1998 survey with the November 1997 survey in the five l

(5) creas evaluated, j

l The Leadership Assessment revealed several strengths in the ability of l

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 meet regularly with employees and to pay attention to personal development needs.

The May Leadership Assessment included a " skip" level survey to allow l

employees to assess a level of management above their direct supervision. At i

O Millstone, personnel tended to be more positive about their direct supervisor than

]

V about their skip level management. The " skip" level measurement resulted in an Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_P E R RR M\\P M-207.D O C l

l

7 overall lower score than that obtained for direct supervision, (5.56 vs. 5.76). Full analysis of the results of the " skip" level assessment is on-going.

Culture Survey The Millstone Culture Survey was completed in June 1998. Preliminary results 4

show that the " Culture Index" for Millstone employees has remained above the previously established goal of 13. (Culture Indices range from 1 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 12.67. 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 preliminary results also showed a 3.9 %

l increase with respect to employee perception of the Millstone Safety Conscious Work Environment.

Performance Measures Millstone Station Leadership Assessment KPI G-1 l

e Millstone Station Cultural Survey KPI G-2 e

V Conclusions Leadership Assessments and Cultural Surveys indicate that Millstone is continuing to maintain a focus on leadership and work environment issues.

l Preliminary results show that the gains made during the station recovery are being sustained as the station transitions from recovery to operations.

I

\\

f Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC

_ ----- -}

8 Key issue: Safety Conscious Work Environment l

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

Demonstrate that employees are willing to raise concerns Demonstrate that management is effective in evaluating, prioritizing and resolving employee issues Demonstrate that the Employee Concerns Program is effective in addressing i

issues raised by employees that are not resolved satisfactorily by other j

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

[V9 Independent Third Party Oversight Program, established by NRC Order Self-assessments The following self-assessments are currently planned for 1998:

Effectiveness of Selected Employees Concerns Comprehensive Plan Action Items - 1st Quarter Pil Culture Survey - 3rd Quarter Executive Review Board Effectiveness - 3rd Quarter HR Customer Feedback Surveys - 4th Quarter Personnel Performance Reviews - 4th Quarter Continu3us Monitoring by third party - Employee Concerns Oversight Panel j

Leadership Assessment -late 2nd Quarter Performance Measures l

The SCWE infrastructure includes the dedicated SCWE group (including the Key issue Manager), the Employee Concems Program, the Employee Concerns b'

Oversight Panel, and the Human Resources organization for NU Nuclear.

L.J Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RMiPM 207. DOC

l 9

i Importantly, each of these four groups work closely together under the direction N

of one Officer. The Independent Third Party Oversight Prograni(Little Harbor (j

l Consultants) will continue to function consistent with the terms of the October, l

1996 Order, and their recommendations and NU's responses are routinely updated. On-going performance monitoring includes:

l Leadership Assessment (SCWE Element)

Culture Survey (SCWE Element)

NU Concerns and NRC Allegations Received, Millstone Station Millstone Employee Concerns Confidentiality Trend, Millstone Station Employee Concern Resolution Timeliness Employee Satisfaction With Employee Concerns Program Focus Area Action Plan Status, Millstone Station Concems Alleging HIRD, Millstone Station Second Quarter Status Safety Conscious Work Environment.

Assessment instruments

,p The following assessments were completed during this period, i.e., second kj quarter of 1998 (April through June 1998). One assessment was scheduled to be

'i completed this quarter (Leadership Assessment), one assessment (Pil Culture Survey) was completed ahead of its scheduled time of 3rd quarter 1998. The individual results of the Culture Survey will be rolled out to the site during the 3rd quarter Both of these assessments contain a specific SCWE element. In addition, LHC provided ongoing assessment during this quarter.

l Assessment Title.

schedule Ccimpleted Revised Date -

(Y/N) schedule if Not Complete -

Leadership Assessment 2nd Quarter Y

1998 Culture Survey 3rd Quarter Y

Completed in 2nd 1998 Ouader LHC Ongoing Assessment Ongoing Y

Assessment Results l

l Leadership Assessment and Culture Survey p

The Culture Survey and Leadership Assessment results show that satisfactory performance is being sustained. The preliminary results show no new areas of concem. Our workforce has become more discerning in this area. In the l

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1

10 Leadership Assessment and Culture Survey we see our employees providing n

improving scores on SCWE and the Employee Concems Program (ECP). This i

)

is an indicator of sustained performance. With all the issues we have faced in getting Unit 3 on-line and reorganizing to support Unit 2, these results show we have improved the ability of the organization to respond and address emerging issues. These results also show that we can sustain initialimprovement and continue to improve. Specific Leadership Assessment results are shown below:

1.eadershio Assessment Overall Results by Cateaorv e Concerns 6.15 Leadership 5.84

  • Communications 5.72 Development 5.53 l

Performance Accountability 5.31 Overall Score 5.76 A score of 4 to 5 is evaluated as effective, between 5 and 6 is "very effective" and a score of 6 is evaluated as superior.

77 Specific strengths were identified in the SCWE area:

/

ls easy to approach and talk with 6.35 Does what is right 6.34 Respects and cares about me 6.14

  • Establishes an environment of trust 6.03
  • Gives me a chance to make decisions 6.21 Fosters a supportive workplace environment 6.36 Respects individuals with differing viewpoints 6.20 Will listen to my concerns 6.47 Does not react defensively to my concerns 6.18 Asks for my input to resolve concems 6.07 Would be my first choice to go to 6.35 Demonstrates sensitivity to concerns raised 6.43 The following areas, although still rated effective, were identified as areas for improvement:

+ Meets with me on a regular, ongoing basis 4.89

+ Works with me on personal development 4.62 G'

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m 11 Specific Culture Survey results are still being tabulated and will be rolled out in l

q the third quarter. The overall site SCWE indicator shows that 86.6% of l

t personnel agree that a SCWE exists in their area; this is up from the previous assessment of 82%. Preliminary results show a 3.9% increase with respect to employee perception of the Millstone SCWE, increasing from a rating of 3.07 to 3.19 out of a possible 4.0. The overall adjusted Culture Index for this survey was 12.99. This was divided into 13.17 for NU employees and 12.67 for contractors.

i The " skip" level survey is undergoing analysis to determine results and establish goals.

l l

I Little Harbor Consultants Assessment LHC's ongoing assessment during this quarter showed steady performance with improving trends in two areas: ECP performance and management's ability to j

deal with HIRD. On July 15,1998, LHC presented the results of their latest formal assessment of SCWE/ECP. LHC cited improved training, particularly the

" Quick Start" leadership training for new leaders, management's response to i

emerging issues, the improved ECP process for evaluating HIRD and l

10CFR50.7 issues, and the reduction of the ECP backlog as contributing to the improved performance ratings. LHC also noted that overall progress continues and that the SCWE had matured much faster than they would have expected, particularly in the HR area.

l

e Finally, we are planning an additional assessment for the second half of 1998 - a

'i self-assessment of leadership training.

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

Current Actual: 98.7%. This parameter most directly relates to the first success criterion and the current actual value reflects strong performance.

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

work area supports a willingness to raise concems.

Current Actual: 86.6%. Improved from 82% in November 1997. Although the current value is not at the long-term goal, we believe that the current level of willingness to express concems in the work environment, coupled with the results of the leadership survey showing a "very effective" rating for management in dealing with employee concerns, and the feedback from the ECOP survey supports a satisfactory rating for this criterion.

C

(

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12 Millstone Employee Concerns Confidentiality Trend, Millstone Station KPI (S

B-4

(

)

Goal:There is not an adverse trend in the number of concerns to ECP requesting confidentiality or anonymity.

Current Actual: Less than 35% of concems have been filed anonymously or have requested confidentiality since the beginning of 1998. Based on the June 1998 numbers, the trend appears to be flat with the exception of the March and May numbers. Our analysis of the concems data did not reveal any specific reason why this pattern occurred. ECP monitors this closely for any adverse trend.

NU Concerns and NRC Allegations Received, Millstone Station KPI B-3 Goal: There is not an adverse trend in the ratio of concems received by NU versus the number of allegations received by the NRC.

Current Value: There is no adverse trend. The number of concems received by NU has increased from 15 per month in mid-1997 to approximately 20 per month in the first six months of 1998. During this same period, the number of allegations received by the NRC has decreased from a peak of 12 to an average of four per month.

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

p Current Actual: The average age of unresolved concems has significantly i"j declined from approximately 45 days to 23 days. This shows an improving trend s

in the timeliness of resolving employee concerns.

Employee Satisfaction With Employee Concerns Program KPI B-6 Goal: A substantial majority of employees who have used ECP state they would use it again.

Current Actual: In January 1998, seventy-five (75%) of employees surveyed by ECOP stated that they would use the process again. January 1998 feedback from Little Harbor Consultants indicates that 83% of those surveyed would use the ECP again. In March 1998, the Employee Concems Oversight Panel conducted a survey that concentrated on personnel who had used the program in the last six months. This survey indicated 90% of the people surveyed would use the program again. This is particularly significant because ECP did not substantiate a number of the respondents concerns. These personnel stated that they felt they had been treated well and would use the program in the future.

Additional second quarter data indicates this level of satisfaction continues.

Focus Area Action Plan Status, Millstone Station KPI B-7 l

Goal: The number of areas where it has been determined that one or more of I

the attributes of a Safety Conscious Work Environment is challenged or lacking does not indicate an adverse trend.

p Current Actual: The cumulative number of " focus areas" from program inception j

to June 30,1998 is 33. Of these,26 areas have had their action plans completed Millstone Station / Unit 3 Second Quarter Performance Report j

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i 13 and closed. Six of the 25 are awaiting independent effectiveness reviews. The remaining 7 are in progress. These focus areas were assessed to identify r(rm']

potential barriers to Unit 3 restart. The results of this assessment indicated that these focus areas presented no barrier to Unit 3 restart. NU has added personnel I

trained in organizational behavior to increase attention to this area. In many cases, proactive responses to potential " focus areas" have successfully prevented the creation of new " focus areas." We believe we have prevention and detection occurring with increasing frequency and remediation of areas that have been allowed to occur declining in frequency.

t I

Concerns Alleging HIRD, Millstone Station KPl B-8 Goal: The number of concerns alleging HIRD does not show an adverse trend Substantiated 10CFR50.7 concerns are infrequent and handled responsibly.

Current Actual: The number of concems alleging 10CFR50.7 HIRD continues to trend downward. There have been no substantiated concerns involving alleged violations of 10CFR50.7 since August 1997.

Conclusions Our performance monitoring and second quarter assessments demonstrate steady, improving performance, with no indication of any backsliding. We continually look for areas to refine and improve. Our workforce is not only empowered in the area of SCWE, it is also well educated, maturing, and more l

lp capable of responding to emerging events.

l l

I i

h i

O l

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14 f3d Key lasue:cSelf-Assessment-l Success Criteria The following Success Criteria wera previously established and summarize the performance baseline for this Key Issue:

Achieve greater than 90% of self-identified issues No programmatic issues identified by intemal and/or external oversight Self-Assessments The following self-assessments are currently planned for 1998:

Station Self-Assessment Program Quarterly Performance " Windows" Conduct of Self-Assessment Nuclear Oversight Restart Verification Plan (NORVP)

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

Condition Report Method of Discovery - By Unit

/O V

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15 O

Second Quarter Status

.Self-Assessment.

Assessment Instrument Assessment Title schedule Completed

- Revised -

Date (Y/N) schedule if Not.

Complete Quarterly Self-Assessment of June 1998 Y

Performance " Windows" OSTl-NRC Inspection Report April 1998 Y

50-423/97-83 Assessment Results The following summarizes the results of the self-assessment activities:

In June 1998, the Millstone Performance Windows assessment rated self-assessment as satisfactory as compared to the INPO 97-002 criteria.

NRC Operational Safety Team inspection (OSTI) noted at the May 5,1998 V

exit meet;ng that "... Self-Assessment programs have been significantly strengthened and are acceptable for restart."

Performance Measures Condition Report Method of Discovery - Unit 3 KPI A-2: The Unit 3 performance data was negatively affected by the number of ICAVP Discrepancy Repart CRs. Since June 3,1998, externally generated CRs have decreased and self-identified issues have achieved the goal of greater than 90% As of July 1, 1998 self-identified issues are 94% of the total Unit 3 CRs.

Conclusions An environment reflecting a questioning attitude and self-identification at Millstone continues to improve. The self-assessment program and performance are determined to be at a satisfactory level to support the safe operation of Unit 3.

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1 I

16 (m

1 i

Key lasue: Corrective. Action" d

i Success Criteria l

l The following Success Criteria are established and summarize the perfonnance baseline for this Key Issue:

I Demonstrate that a low threshold exists for identifying conditions adverse to l

quality by increasing the ratio of Level 2 and 3 CRs to Level 1 CRs The ratio of self-identified to extemally identified conditions adverse to quality continues to increase i

High quality corrective action plans are provided within 30 days of l

e identification Corrective actions are completed in accordance with a schedule established in the action plan Corrective actions are effective in resolving the issuo Adverse trends are resolved in six months of identification and do not recur O

Self-Assessments O

The following self-assessments are currently planned for 1998:

Monthly Unit Trend Reports Quarterly Unit Trend Reports Quarterly Station-wide Integrated Trend Report Quarterly Self-Assessment of each unit Corrective Action Program Annual Assessments of each department corrective action performance Semi-Annual Nuclear Oversight Corrective Action Program Audit Nuclear Oversight Restart Verification Plan (Monthly)

HPES Effectiveness - 2nd Quarter Operating Experience Program Effectiveness - 3rd Quarter Station Corrective Action Program Effectiveness - 3rd Quarter Performance Measures l

Trend reports track corrective action system key parameters on a monthly and f g) quarterly basis for each unit as well as for the station.

The following performance measures will be used for the on-going monitoring of V

this Key issue:

l l

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17 Human Performance (as measured by the number of precursor, near miss and breakthrough event Condition Reports (CRs) per 1,000 man-hours worked)

Timeliness of Screening CRs for Operability and Deportability Action Plan Development Time for Level 1 and Level 2 CRs Action Plan Quality Median Age of Open CRs l

Overdue Corrective Actions Recurrence of Significant Conditions Adverse to Quality l

l Second Quarter: Status Corrective' Astion' Assessment instruments The following assessments of Unit 3 performance in the area of Corrective Action were scheduled during the second quader of 1998.

Assessment

Title:

Schedule Completed

. Revloed,

- Date :

-(Y/N)=

LSchedule if O-

. Not.

!,b

^

Complete l

Monthly Unit Trend Reports Monthly Y

Quarterly Unit Trend Reports 6/98 Y

l Quarterly Station Wide Integrated Trend 6/98 Y

Report Quarterly Annunciator Window Unit 6/98 Y

Corrective Action Program HPES Effectiveness 6/98 Y

Assessment Results l

Monthly / Quarterly Trend Reports Monthly and quarterly trend reports for Unit 3 indicate that the areas of operations configuration control, performance of safety evaluations, implementation of the action tracking program, and human error require continued rnanagement attention because the adverse trends in these areas have not been satisfactorily resolved.

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i 18 Quarterly Station-Wide Integrated Trend Report in

)

No Unit 3 specific trends were identified in the Unit Trend Report Quarterly Annunciator Windows l

Overall organizational performance of Unit 3 with respect to corrective actions was satisfactory at the end of the second quarter. Two areas, condition report evaluation timeliness and age of open consition reports, did not meet expectations for the second quarter in a row. The Unit Director has placed these areas under weekly focus.

HPES The Unit 3 HPES Coordinator has been reassigned leaving a gap in this function temporarily. The position has subsequently been refilled. Although not specific to Unit 3, three areas for improving the HPES program at Millstone were identified in the self-assessment:

Identify an executive sponsor for the HPES program Integrate HPES activities across the station Assign a full-time HPES coordinator to each unit An action plan is under development.

b) f~

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

The ratio of Level 2 and 3 to Level 1 CRs during the second quarter of 1998 remained nearly constant. The percentage of Level 1 CRs fluctuated around 4% during the quarter consistent with the end of the first quarter.

During the quarter, the percent of self-identified CRs continued to increase.

The goal of greater than 90% self-identified CRs was achieved throughout the month of June. KPI A-2 Action Plan development median age for Level 1 and 2 CRs has slowly increased throughout the quarter, falling short of the goal of completing evaluations in less than 30 days. KPI A-1 Action plan quality remaine above the goal of 3 on a scale of 0 to 4. KPI A-9 m

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1 l

l 19 l

/m D)

The median age of open Level 1 and Level 2 CRs at the end of June is indicated below and shown on KPl E-1. The stated goal is a declining trend.

Time in Days i

CR Level 1 CR Level 2 All CRs 243 202 Oversight initiated 218 223 Externally initiated 204 153 The median age for Level 1 CRs has remained flat during the quarter while the median age for Level 2 CRs has slowly increased. This adverse trend will be analyzed and corrective actions taken.

Overdue corrective actions showed an increase during the quarter. This was symptomatic of the focus on completing restart required actions which had a floating due date and were not included in the calculations. Senior management intervention has been taken and the trend has been reversed, although not yet meeting the operational objective of less than 1% overdue corrective actions. KPI A-3 Human Performance KPl shows that the total number of Unit 3 human performance errors has declined over the quarter, however, the number of v

near misses remained about the same. KPI A-4 Conclusions The focus of activity during the quarter was on restart activities. Those CRs l

related directly to restart were acted upon promptly. The remaining CRs received less attention. Senior management has refocused attention and taken action to reverse those indicators that are not trending toward station goals.

I

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20 (m)

K. ey issue: Oversight g

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

Majority of problems are self-identified Oversight Condition Reports are addressed in a timely manner Self-Assessments The following self-assessments are currently planned for the remainder of 1998:

Third Quarter Performance Evaluation: Oversight Training Effectiveness (TQ1)

Audits and Evaluation: Benchmark Millstone typical number of audits / assessments performed by similar plants / stations to meet

(.

requirements. (Artificial Island, Palo Verde and North Anna)

(

Programs: CA Effectiveness in NO Performance Evaluation: Follow-up to 1997 4th Quarter Performance e

Evaluation Self-Assessment in Work Control Process Fourth Quarter Programs: SA Process in NO Programs: Revised NOVP Process

+

Audits and Evaluation: Oversight Training Effectiveness (TQ1)

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

Condition Report Method of Discovery Status of Oversight Condition Reports, Millstone Unit 3 OV Millstor.c Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S US_PE R RR M\\P M-207.DO C

21 Ob

'Second Quarter Status Oversight Assessment instruments Assessment Title

. schedule

. Completed -

Revised

. Date

' (Y/N).-

schedule if.

Not '

Complete Nuclear Safety Engineering:

2nd Y

Operating Experience Program Quarter 98 (Vendor Information Tracking)

Recovery Oversight: Issues 2nd Y

Resolution Quarter 98 Audit & Evaluation: Training 2nd Y

Effectiveness Quarter 98 Performance Evaluation: Personnel 2nd Y

Qualification and Training Quarter 98 Performance Evaluation:

2nd Y

Continuing Training for Quality Quarter 98 Control Personnel Performance Evaluation:

2nd Y

'\\

IAT(Independent Assessment Quarter 98 Team) Recommendation i

implementation l

Joint Utility Management 2nd Y

Assessment (JUMA)

Quarter 98 l

Performance Evaluation: Customer 2nd N

In-process Satisfaction Quarter 98 Nuclear Safety Engineering:

2nd N

In-process Customer Satisfaction Quarter 98 Audit & Evaluation: Programmatic 2nd N

Canceled Assessment Comparing Quarter 98 Commitments Audit & Evaluation: Process 2nd N

Deleted Assessment Comparing Audit Quarter 98 Process to Other Utilities Assessment Results 1

l Nuclear Safety Enaineerina - Vendor Information Tracking (MP2)

This assessment determined that vendor information items received by NU have been adequately reviewed and dispositioned for Millstone 2.

p Department interfaces within the VETIP (Vendor Equipment Technical Information Program) are working, but procedures need to be improved.

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~

i 22 Additionally, program measures for vendor interfaces and in-house io accounting need enhancements.

I Recoverv Oversiaht - Issues Resolution i

The assessment revealed the need to assure a consistent Analysis &

Programs management understanding of the details and requirements of issue resolution, and the need to consistently distribute weekly reports.

Audits and Evaluation -Training Effectiveness l

'The assessment indicated that familiarization training has been i

implemented, although deficiencies were identified. The assessment I

noted that administrative improvements are needed to assure required training is not missed, and to assure audit performance feedback is evaluated for training value.

Performance Evaluation - Personnel Qualification and Training The assessment determined that the training program satisfies requirements, although documentation supporting that conclusion is incomplete. Another weakness was the need for implementation guidance for the continuing training program.

,p)

.t!V Performance Evaluation - Continuing Training for QC Personnel The assessment concluded that continuing training has been effective i

and beneficial to the performance of inspection activities. Noteworthy was that some training involved a mix of inspectors and workers which fostered an improved mutual respect of each other's roles and responsibilities. The assessment pointed out the need to equalize opportunities to attend available training.

i Performance Evaluation -lAT Recommendation implementation The assessment revealed that Performance Evaluation is placing its strategic focus on the issues most critical for the unit restarts, presentations to management have improved, and meetings with the NRC l

are rnore effective. It also revealed areas that need enhancement such as more management emphasis on following up cn recommendations, implementation efforts, communications, anc -,ending time with staff members.

OG Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PER F\\R M\\PM-2Q7. DOC

23 JUMA - Joint Utility Management Assessment The annual Joint Utility Management Assessment (JUMA), as required by the Northeast Utilities Quality Assurance Program (NUQAP) Topical Report, was performed during the week of June 22,1998. This assessment is designed to assess the effectiveness of Oversight in the implementation of the NUQAP in compliance with regulatory and licensing commitments. The team also evaluated the readiness of Nuclear Oversight to function as an operation quality organization and assessed the adequacy of corrective actions arising from past JUMA recommendations. The JUMA Team concluded that significant improvements had been made in Oversight's ability to perform its intended function. Areas for improvement were identified regarding corrective action effectiveness, communications, teamwork and trust, and Oversight work product quality.

i Performance Measures Indicator:

Condition Report Method of Discovery - Millstone 3 KPI A-2 Status:

The goal of less than 10% identified by events and extemal sources was achieved and maintained in May and June.

g Indicator:

Status of Oversight Condition Reports - Millstone 3 KPl C-1 Status:

Performance has not been tracking to satisfactory since March.

Conclusions i

l Critical 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. The timeliness of line actions in developing and approving corrective action plans for condition leports initiated by Nuclear Oversight has not been tracking to satisfactory since March. Senior management has refocused attention on those indicators trending away from station goals.

I MiHstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R F\\R M\\PM-207. DOC

24

')

Key issue: Configuration Management:

l (V

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

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 Self-Assessments During the second quarter of 1998, the Unit Configuration Management (CM)

Teams for Units 2 and 3 were re-assigned under the Manager, Programs and

[d Engineering Standards. This re-organization brings together these two teams 1

along with the Engineering Assurance Group (EAG) and the Design and Configuration Control (D&CC) Group.

This new organization allows for the monitoring of Configuration Management programs, processes and procedures under one department. The main focus of EAG will be the evaluation of processes (Design Control Manual, NCR process, Safety Evaluation process,'etc.) to ensure high standards are in place and implemented to maintain LB/DB.

The main focus of the CM Teams is to evaluate products (i.e., design change records, calculations, procedures, etc.) to ensure configuration control is maintained between the Licensing basis and Design basis, and physical plant.

The D&CC Group is the custodian for the key programs, process, and procedures pertaining to Configuration Management. Included are the Design Control Manual, the Temporary Modification procedure, and common design specifications.

The self-assessment plan for the remainder of 1998 reflects this re-organization (O]

with the consolidation of assessments. The assessments are as follows:

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25 p

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

MP3 Technical Specification Review (3 CMT-98-001, dated 4/29/98) l Corrective Action Effectiveness Review (CM Related)(PES-SA-98-002, dated l

l 6/9/98)

{

Corrective Action Effectiveness Review (Departmental) (PES-SA-98-017, dated 6/8/98) l Third Quarter Attention to Engineering Quality (PES-SA 98-039, dated 7/10/98) l MP3 Engineering Qualification Record Status (PES-SA-98-041, dated 7/5/98)

Calculations (PES-SA-98-009, dated 7/10/98)

PDDS Relief Valve Setpoints (PES-SA-98-003, ongoing)

Review of Minor Modifications (U2-CMT-98-004/3CMT-SA-98-04)

Review of Material issue and Control Processes (3CMT-SA-98-06, ongoing) l Foudh Quader Review of Design Change Records / Minor Modifications (PES-SA-98-007)

Review ot T; "porary Modifications (PES-SA 98-008)

Corrective Actions Effectiveness Review (U2-CMT-98-005/3CMT-SA-98-05)

Performance Measures l

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

Temporary Modifications Control Room and Annunciator Deficiencies Operator Work Arounds Configuration Management Annunciator Windows Configuration Management Training Configuration Management Related Self-Assessments Configuration Management Related Condition Reports l

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26 (G'

Second Quarter Status:

Configuration Management l

Assessment instrument Assessment Title schedule Date Completed Revised 1

(Y/N) schedule if i

l Not Complete ESAR PES-97-020 DCR/MMODS 2nd Quarter 98 Y

Review of MP3 Technical 2nd Quarter 98 Y

Specification 3CMT-98-001 Section 6.0 PES Corrective Action Program 2nd Quarter 98 Y

Effectiveness PES-98-SA-002 Self-Assessment Report 2nd Quarter 98 Y

PES-SA-98-017 MP3 Engineering Attention to 2nd Quarter 98 Y

l Engineering Quality PES-SA-98-039 MP3 Engineering Department 2nd Quarter 98 Y

Engineering Qualification Record Status i

PES-SA-98-041 MP2 and MP 3 Calculations 2nd Quarter 98 Y

PES-SA-98-009 Assessment Results ESAR PES-97-020 "DCR/MMOD"(Follow up) The overall effectiveness of the corrective actions from Self-Assessment PES-ESAR-97-020 (Design Change Records / Minor Modifications) is acceptable. A strength was observed in the area of management receptiveness to the associated corrective actions. This follow-up assessment identified that training initiated as a result of corrective actions requires follow-up reinforcement to have lasting effectiveness.

3CMT-98-001, " Review of MP3 Technical Specification Section 6.0" This assessme it determined if plant procedures properly implement the Administrative Controls Section (Section 6.0) of the Millstone Unit 3 Technical Specifications. A general trend identified a lack of recognition by the responsible I

procedure and program owners on how their programs and procedures are tied to Technical Specifications. Training for the program and procedure owners has been identified to reverse this trend.

l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S._P E R F\\R M\\P M-207.DO C

i 27 PES SA 98-002," Corrective Action Program Effectiveness" This O

assessment concentrated specifically on: closure of assignments from Level 1

)

and Lrvel 2 CRs and AITTS closure notes, assignment completion on or before s"

due date, RP4 procedure compliance and CR initiator contact. It was determined that the PES Corrective Action Program is satisfactory, and the performance criteria was met.

PES-SA-98-017,"Self-Assessment Report" Three randomly selected CRs processed within a past 3-month period were reviewed. The scope included content compliance with RP4, investigation and corrective action plans to ensure they satisfy the intent of the condition reported, ensure the CR initiator was contacted and determine if required supporting information/ documentation was included in the CR package. It was concluded that the investigation and ~ action plans adequately address the items specified by the CR and the initiators were contacted. Necessary supporting documentation was included with the CR packages.

PES-SA-98-039,"MP3 Engineering Attention to Engineering Quality" In support of the management intervention currently under development to raise the performance standard of " attention to engineering quality," Unit 3 Design Engineering and Technical Support products were reviewed to determine compliance with appropriate procedures. It was determined that many of the documents reviewed do not satisfy the performance criteria, and did not meet n

management expectations. Immediate compensatory measures were taken: An

,'"j Engineering Quality Review Board was implemented and emphasis was placed on the roles and responsibilities of the Independent Reviewer.

PES-SA-98-041, "MP3 Engineering Department Engineering Qualification Record Status" The assessment evaluated the MP3 Design Engineering group for compliance with TO-1 " Personnel Training and Qualification." Multiple cases of personriel performing work without properly documented qualification records were identified. The Engineering Directorimmediately reemphasized his expectation to each applicable supervisor that quality work was not to be performed without appropriate personnel qualifications.

PES SA-98-009, "MP2 and MP3 Calculations" The assessment evaluated performance and compliance with the calculation process as defined in the Design Control Manual (DCM). The calculation process as defined in the DCM is adequate. Additionally, expectations to ensure that calculations are properly completed, revised, controlled and indexed were met. Minor deficiencies were noted and are currently being addressed.

l f3)

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28 O

Performance Measures Indicator:

Summary Configuration Management KPI Status:

The Programs and Engineering Standards Department is enhancing the Configuration Management (CM) KPis to focus more on CM attributes critical to an operational unit versus a unit in the recovery mode. These enhancements are designed for long term monitoring of CM and will provide more efficient integration with the Corrective Action process to more effectively drive CM improvement initiatives. Therefore, the CM KPis will not be issued this period, but will be reissued next period in their new format.

l Conclusions l

Self-assessments completed through June indicate satisfactory implementation of processes to maintain configuration management. These areas are receiving appropriate management attention. Performance with respect to configuration l

s management is assessed to be at a satisfactory level which supported the restart i

of Unit 3 and its continued safe operation.

I 1

l t

l 4

.(v Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PE R RR M\\PM-207. DOC L

29 Q

Key.lssue:1 Regulatory Compliance l

&j 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' e, and communications are complete, I

accurate, and timely i

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

Effectiveness of Corrective Actions Related to the Key issue of Regulatory Compliance-COMPLETE Effectiveness / compliance with RAC 08," Regulatory Communication and

,q Docketed Correspondence" - COMPLETE I

PV Effectiveness / compliance with RAC 01, " Licensing Basis Management"-

Revised to 3rd Quarter Effectiveness / compliance with RAC 06, Regulatory Commitment Management Program"- Substituted by effectiveness review of corrective actions associated with Root Cause Evaluation for CR-M3-98-2293 Effectiveness / compliance with RAC 03, " Changes and Revisions to Final l

Safety Analysis Reports"- Substituted by PES-98-001, "MP 3 Engineering FSAR Change Requests Assessment."

Effectiveness / compliance with RAC 13, " Organizational Changes" - Revised to first quarter 1999 Effectiveness / compliance with RAC 05, "10CFR50.72 Notification, 10CFR50.73 and 10CFR50.9(b) Deportability determinations, and Licensee Event reports"- Postponed to 1999 Effectiveness / compliance with RAC 02, " Technical Specification Change Requests and Implementation of License Amendments"- Substituted by l

Oversight Assessment of License Amendment Request Implementation Department training / qualification effectiveness - 4th Quarter o

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30 D]

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

l Compliance Manaaement i

Licensee Event Reports l

Notices of Violation l

Inspection items 1

License Basis Manaaement Docketed Correspondence Technical Specification Change Requests FSAR Change Requests i

License Basis Condition Reports (Link to Corrective Actions Program)

Regulatory Commitments SehondlOOartsrSIatul &

7$$ddRegulatoryghi$hlikrimsd@

,p lt Assessment Results Nine (9) assessments were performed relating to the Key issue of Regulatory Compliance during the period April 1998 through June 1998. This brings the total to Twelve (12) assessments in this key area for the year-to-date. One assessment scheduled for completion during the second quarter was rescheduled. These assessments are tabulated and summarized below.

AssessmentTitlepy,+

,% p schedule Completed; -?:rhRevised;M

,w-wwg y

$ gjath

$/N)r tschedule'IfM 5

,39

y T uv WotiC6mpletel Effectiveness / Compliance with RAC 08, 2nd Quarter Y

N/A

" Regulatory Communication and 1998 Docketed Correspondence" (3RAC-SA-98-02) 50.54(f) Recovery Oversight Not Y

NA Assessment Report, "NRC Briefing previously Book Validation Process" scheduled (2 Assessments)

Effective / compliance with RAC 01, 2nd Quarter N

3rd Quarter

" Licensing Basis Management" 1998 1998 i

(3RAC-SA-03)

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l

)

31 gh iAssessmentTitleW 4

- Schedulet Completed 7:4Heviseda Date)b @ g(YIN) W.sSchedule:lfs

d a?

, y

p -

4 s

1 N ~~ b 1Not Complete:

Root Cause Evaluation for Condition Not Y

NA Report M3-98-2119," Organizational previously Changes Without Prior RAC 13 scheduled Evaluation" Root Cause Evaluation for Condition Not Y

NA Report M3-98-2293,"Non-Compliance previously to Millstone Station Procedures RAC scheduled 06, " Regulatory Commitment Management Program" and RAC 08, l

" Regulatory Communications and Docketed Correspondence" 50.54(f) Recovery Oversight Not Y

NA Assessment Report,"MP3 Licensing previously j

Bases Activities" scheduled MP3 Engineering FSAR Change 1st Quarter Y

NA Requests Assessment 1998 PES-SA-98-001 Review of MP3 Technical Specification 1st Quarter Y

NA Section 6.0 - Administrative Controls 1998 ESAR 3CMT-98-001 50.54(f) Recovery Oversight Not Y

NA Assessment of Unit 3 Unreviewed previously Safety Questions (USO) submittals scheduled Assessment Results EffectivenessfCompliance with RAC 08, " Regulatory Communication and Docketed Correspondence"(3RAC-SA-98-02)- This assessment evaluated the effectiveness of the procedure related to the preparation of complete, accurate, and timely regulatory correspondence. This assessment concluded that the procedure was effective. Information provided in submittals reviewed was found to be materially complete and accurate. In addition, correspondence was provided to the NRC in a timely manner. Areas for enhancements were identified and are being addressed as part of the corrective action program. The enhancements were in the areas of improved proofreading and clear expectations for processing and maintaining validation packages which support statements of facts in correspondence.

50.54(f) Recovery Oversight Assessment Report, "NRC Briefing Book Val /dation Process"-Two assessments of the correspondence validation process were conducted by Recovery Oversight for the April 23,1998 and May 22,1998 NRC Briefing Books. The assessments concluded that validation packages were prepared and reviewed in accordance with RAC 08," Regulatory Communications and Docketed Correspondence," and that the validation y

process helped ensure that statements of fact were complete and accurate. In addition, some improvements in the effectiveness of the process were realized MlHatone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER F\\R M\\P M-2Q7.DO C

1 32

(

with the May 22nd issue. Oversight's recommendations for process enhancements are being captured in conjunction with corrective actions and addressed as part of the self-assessment of RAC 08 (see above).

Root Cause Evaluation for Condition Report M3-98-2119, " Organizational Changes Without Prior RAC 13 Evaluation"- On April 21,1998, Condition l.

Report M3-98-2119 was initiated by the subject matter expert for RAC 13 when a potential adverse trend was noticed. Some organizational changes appeared to be implemented prior to completion of an evaluation to ensure that regulatory requirements are met. This evaluation is required by station procedure RAC 13,

" Organizational Changes." The root cause was inadequate ownership for the LB l

organizational structure. Two significant factors that contributed to this condition were unclear expectations regarding what specific actions should be taken to properly review organizational changes for regulatory impacts and a lack of understanding of the portion of the organization that is described in LB documents. A total of fourteen RAC 13 evaluations were reviewed to determine the extent of condition. Three of the fourteen did not adhere to the RAC 13 procedure. Of those three, two were found to be regulatory noncompliant.

These two have since been addressed and compliance was restored. The issue I

was primarily procedural adherence with the new RAC 13 which represents a l

higher standard for the station. RAC 13 is being revised to establish clear ownership of the LB organizational structure and to delineate specific actions required for reviewing organizational changes for regulatory impact. Also,

{

organizational charts used by the majority of nuclear personnel have been annotated to show the subset of the organizational structure which is part of the LB.

Root Cause Evaluation for Condition Report M3-96-2293, "Non-Compliance to Millstone Station Procedures RAC 06, " Regulatory Commitment j

Management Program" and RAC 08, " Regulatory Communications and Docketed Correspondence"- On May 1,1998, Condition report M3-98-2293 was initiated by Regulatory Affairs and Compliance to address procedural non-l compliance with two procedures that are key in the management of regulatory l

commitments. The root cause evaluation concluded that the risk of missing or undoing a regulatory commitment is low. This is substantiated by the fact that of the 910 commitments reviewed,99% were appropriately implemented as j

scheduled. The root cause determined that the cause of the procedural compliance issues was inadequate management oversight and ownership during the transition from a fragmented regulatory commitment management program j

to a new and integrated station program. Corrective actions have been taken to correct the procedural compliance issues. Remedial actions are being implemented that clarify regulatory compliance policy and expectations for commitment management. Long term actions are being developed for simplifying and improving the process functionality and program user interfaces.

[

50.54(f) Recovery Oversight Assessment Report, "MP3 Licensing Bases

\\

Activities"- Due to the significance of regulatory commitment management, this assessment, which was requested by the Regulatory Affairs and Compliance Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PE R F\\R M\\PM-207. DOC

33 Department, independently evaluated many of the same issues associated with the root cause evaluation of Condition Report M3-98-2293. The assessment concluded that the while there was the necessary framework needed to maintain an effective commitment management program, implementation of the program is a concern with respect to procedure adherence. Additional clarification and instruction is warranted. Corrective actions have been taken and are continuing to provide both clarification of program requirements and more detailed implementing instructions in response to both Condition Report M3-98-2293 and this Recovery Oversight assessment. It should be noted that Recovery Oversight considered the corrective actions taken and planned in this area sufficient to address the issues identified in their report and the results of the assessment were factored into CR M3-98-2293. There were no issues found relative to commitment conformance.

MP3 Engineering FSAR Change Requests Assessment (PES-SA-98-001) -

This assessment evaluated selected MP3 Final Safety Analysis Report Change Requests (FSAR-CRs) prepared in conjunction with Unit 3 design changes and the Configuration Management restoration effort in response to the NRC 10CFR50.54(f) letter. This assessment concluded that the improved process to maintain the FSAR (an element of the licensing basis) is functioning adequately and FSAR changes are being properly made. The review showed that previous i

recommendations to enhance the FSAR change process have been l

incorporated in the improved procedure. In addition, evidence of strong l

ownership of the FSAR-CR process was found, resulting in satisfactory program performance. Minor deficiencies categorized as either " administrative / attention to detail" errors or " procedure non-compliance" errors were found. These errors are considered minor considering the volume of FSAR-CRs processed in 1997 (viz.,618) None of the errors affect the FSAR content or the determination of whether the FSAR change constitutes an Unreviewed Safety Question.

Review of MPS Technical Specification Section 6.0 - Administrative Controls (ESAR 3CMT-98-001) - This review was a corrective action from a Level 1 Condition Report (CR M3-97-4644), whose Root Cause Evaluation concluded that there was "a failure to clearly assign ownership for the implementation of this portion of the Licensing Basis." The purpose of the review was to ensure that requirements of the Administrative Controls of the Unit 3 Technical Specifications were being properly implemented through plant procedures and programs. This review confirmed the Root Cause Evaluation conclusion that there was a lack of recognition by the implementing procedure and program owners that the activities being implemented related to specific Technical Specification requirements in Section 6.0. Seventeen (17) Condition Reports (CRs) were initiated during this assessment (7 of which were written by the procedure or program owner who implemented a Section 6.0 requirement).

Required actions to support Mode 2 have been completed. items deferred past O

Mode 2 are for enhancement of the procedures. The majority of the remaining actions are scheduled to be completed by the end of this year.

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34 50.54(f) Recovery Oversight Assessment of Unit 3 Unreviewed Safety m

Questions (USO) Submittals - An assessment of selected Unreviewed Safety Questions (USO) was conducted to determine if the NGP 3.12, " Safety Evaluation" and subsequently RAC 12, " Safety Evaluation Screens and Safety Evaluations," procedural process was effectively implemented, whether the process was applied when appropriate, whether supporting documentation had been appropriately compiled and intemally evaluated, and whether the documentation effectively addresses the identified issue. Significant changes to the Safety Evaluation process have recently been impleritented to address weaknesses in the previous process. RAC 12 became effective March 1,1998 and replaced NGP 3.12 Rev.10. This assessment concluded that the safety evaluation (SE) process in place, once implemented, provides adequate actions to identify USO issues. It was also concluded that RAC 12 provides an effective process to identify USQs and document the evaluation / assessment criteria, and is applied effectively when used. Four USO determinations were reviewed and were found to have effectively documented and evaluated the issues, and provided supporting information to facilitate PORC/SORC review and the NRC evaluation of the conditions as docketed in the Proposed License Amendment Request (PLAR). The review and approval sign off process establishes effectiva measures to enhance quality and provides a clear accountability chain. One area of concem centers on the issue that intemal processes to initiate SE screens or SE's was not effectively invoked for two of the reviewed issues. NRC questions initiated the SE/USO process for those issues. Engineering is

,b currently evaluating actions to respond to this concem, iV I

Performance Measures l

l In addition to the above assessments, monitoring of performance against the Success Criteria was conducted using Unit 3 windows and Key Performance Indicators (KPI's).

Regulatory Performance Monitoring at Millstone Station is performed by Regulatory Affairs and focuses more globally on station performance. The KPI's have been used l

to assess Unit 3's readiness to restart as well as to provide data for trending and identification of emerging problems. The following summarizes Regulatory Compliance KPI's for the period from April 1998 to June 1998 for Unit 3. Since the last report, the KPI focus has shifted to an operational focus and a goal of excellence while still assuring there is no backsliding from the restart performance threshold. (See figure RAC-1 for a summary.)

Success Criterion 1 Contribmors Assessments Results - The assessments discussed above show that the processes for maintaining the licensing basis are functioning satisfactorily, however, procedure compliance issues are higher than expected and are receiving management focus to ensure quality and adherence to high standards. However, Millstone Station / Unit 3 Second Quarter Performance Repor1 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRM\\PM-2Q7. DOC

35 since some of these procedures are new, it was expected that issues would arise and that the procedures would be appropriately improved based on user feedback.

The Effectiveness (Compliance with RAC 08, " Regulatory Communication and Docketed Correspondence" 3RAC-SA-98-02 assessment concluded that the procedure was effective and allinformation provided in submittals reviewed was found to be materially complete and accurate.

The 50.54(f) Recovery Oversight Assessment Report, "NRC Briefing Book l

Validation Process" assessments concluded that validation packages were l

prepared and reviewed in accordance with RAC 08, " Regulatory i

Communications and Docketed Correspondence," and that the validation process helped ensure that statements of fact were complete and accurate.

The Root Cause Evaluation for Condition Report M3-98-2119,

" Organizational Changes Without Prior RAC 13 Evaluation"has provided insights to provide added assurance that organizational changes remain compliant with the LB organizational structure documented in various LB documents such as the Technical Specifications.

Root Cause Evaluation for Condition Report MS-98-2293, "Non-Compilance to Millstone Station Procedures RAC 06, ' Regulatory Commitment Management Program' and RAC 08, ' Regulatory Communications and l

Docketed Correspondence'" concluded that the risk of missing or undoing a regulatory commitment is low, however, additional management attention and process improvements are being applied to further reduce this risk.

The independent review by the 50.54(f) Recovery Overs /ght Assessment Report, "MP3 Licensing bases Activities"also concluded that while the necessary framework needed to maintain an effective commitment management program is in place, implementation of the program is a concem. Additional clarification and instruction is needed and is being addressed as part of the corrective actions for Condition Report M3-98-2293.

MP3 Engineering FSAR Change Requests Assessment (PES-SA-98-001) concluded that the improved process to maintain the FSAR is functioning adequately and FSAR changes are being properly made.

The Review of MP3 Technical Specification Section 6.0 - Administrative Controls (ESAR 3CMT-98-001) determined the corrective actions necessary provide assurance of regulatory compliance by Mode 2. Required actions to support Mode 2 were completed.

50.54(f) Recovery Oversight Assessment of Unit 3 Unreviewed Safety Questions (USO) Submittals concluded that the cafety evaluation (SE) process in place, once implemented, provides adequate actions to identify USO issues and is implemented effectively.

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36 l

Success Criterion 2 Contributors q

Regulatory Commitments - For 1998, the commitment management process is functioning satisfactorily, however, implementation deficiencies were identified 4

and resr%d in 10 commitments completed after their due date. This represente about 1 percent of the 910 commitments that were fully implemented as scheduled. Commitments required to be completed for Modes 4,3 or 2 were i

met. Communicating, reporting and management attention to the commitment management program will continue.

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 of TSCRs. A schedule has already been provided for future submittals of TSCRs. Unit 3 performance is satisfactory.

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

Annual Report (10CFR50.59) and Revision 11 to the Unit 3 FSAR was completed on time. The implementation focus is now shifting to dispositioning l

the backlog of FSARCRs. Unit 3 performance is satisfactory.

i Licensee Event Reports (LERs) - The process for deportability determinations l

and LER preparation is functioning satisfactorily. Unit 3 performance is satisfactory.

The majority of Deportability Determinations requiring input from engineering and/or Regulatory Compliance 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 (LERs) are consistently being submitted on a schedule which meets the 30 day requirement and they are materially complete and accurate. The number of LERs associated with historical design issues is declining and performance is expected to trend toward the industry average. Unit 3 implementation performance is satisfactory.

Docketed Correspondence - The process for preparation of docketed l

correspondence is functioning satisfactorily. The standard for validation

- packages has been raised. There are some issues regarding procedural adherence with respect administrative items. Improvements to the process are currently being evaluated to administratively improve the handling of docketed i

correspondence. Overall, Unit 3 performance is satisfactory.

For the period from April 1998 to June 1998 over one hundred sixty (160) outgoing docketed correspondences were processed. The docketed correspondence is generally submitted in a timely fashion and the submittals are i,)

materially complete and accurate. However, there were a number of (V

administrative or typographical errors found. The results of the second quarter self-assessment to determine "The Completeness and Accuracy of i

l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER F\\R M\\PM-207. DOC l

t

37 Correspondence Provided to the NRC and the Effectiveness / Compliance of RAC

! (q 08, ' Regulatory Communication and Docketed Correspondence'" agree with the l

j V

above conclusion. A plan for remediation, which is being tracked by the corrective action program, was developed to address this issue. Improvement has already been noted. Unit 3 implementation performance is satisfactory.

Notices of Violations (NOVs) - NOV responses for Unit 3 have generally been submitted in a timely manner in response to NOVs received from the NRC.

Condition Reports are being generated at the time of the inspection exit meeting, or sooner, if known during the inspection period. This allows for an improved process for identifying root causes and the appropriate corrective actions corresponding to the applicable root causes. These actions are being properly tracked through the Corrective Action Program. Unit 3 performance is satisfactory.

As the corrective actions addressing past violations received during the Unit 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 - Submittal of closure packages to support Unit 3 startup is complete. Focus will now have to be on working with the NRC to reach closure on those packages which have been submitted. Subsequently, the focus will

! (9 need to be on submitting closure packages for those items greater than two lV years old, followed by those greater than 1 year old.

J License Basis Condition Reports (CRs) -The CRs issued to address the RAC l

processes were focused primarily on RAC 06, " Regulatory Commitment l

Management Program," RAC 08, " Regulatory communications and Docketed l

Correspondence," RAC 12, " Safety Evaluation Screens and Safety Evaluations,"

i and RAC 13, " Organizational Changes." This performance indicator provides an indication of trends requiring increased management attention. The majority of the CRs were Level 2 CRs, however, two were Level 1 CRs whose root causes i

were discussed in the self-assessment section above. The Level 2 CRs indicated either important issues to be addressed or that procedure enhancements are necessary. Both Level 1 CRs were an indication of j

procedure compliance and management oversight issues rather than process issues.

Conclusions I

Regulatory Compliance is satisfactory to support Unit 3 restart and continued g

safe operations.

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l 38 1'

Key Performance Indicators Success C iterson 1 Met iL Self Assessment f

Results (GREEN)

Success Cri trion 3 Met ik Cor tspo d nce FSAR Change Requests (GREEN)

' Licensee Event N

NRC inspection Reports items (GREEN)

(GREEN) l l

l Licens Basis Conditio.. Reports (GR 'EN)

GREEN Satisfactory l YElluGWJimprovement Necessary RED Not Satisfactory RAC Figure 1 1

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39 O

l Key 11ssue: 7 Training l 3

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

A high degree of success is to be achieved by the Unit 3 upgrade / initial license operator training class Nuclear Training programs are upgraded and ready for Unit 3 restart and operations. This is confirmed by Nuclear Training Management Self-assessment and by Nuclear Oversight.

Self-Assessments The fol!owing self-assessments are currently planned for 1998:

i Nuclear Training Department Procedures - 1st Quarter V

Shift Manager Qualifications - 1st Quarter Training Effectiveness 5.05/5.06 - 1st Quarter l

Systematic Approach to Training Effectiveness - 1st Quarter Feedback / Evaluation Process - 1st Quarter Corrective Action Effectiveness - 1st Quarter Procedure Compliance Effectiveness Review - 2nd Quarter TO1 Implementation - 1st Quarter 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 l

Changes (Unit 3) - 2nd Quarter l

Technical /ES Programs - 4th Quarter Review of Simulator Design Changes (Unit 2) - 2nd Quarter Performance Measures O

\\

i, The following performance measures will be used for the on-going monitoring of this Key issue:

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l

40 Executive Technical Council Meetings g

V Training Advisory Committee Meeting Curriculum Advisory Committee Meeting l

Simulator Availability I

Secorid Quader/ Status!

J iii # ~:

..JTralnind.jj Assessment Instrument t

Assessment Title schedule Completed Revised Date (Y/N)

Date TO 1 Implementation (New revision 1st Otr 1998 N

3rd Qtr l

became effective 7/10/98) 1998 Procedure Compliance Effectiveness-2nd Otr 1998 N

3rd Qtr Review 1998 l

Millstone Operator Training Programs 2nd Qtr 1998 Y

l INPO Accreditation Team Visit Non-Accredited Training Programs 2nd & 4th Otr N

4th Otr l p\\

1998 1998 l(

(only) l Process Computer and Simulator -

2nd Qtr,1998 Y

Impact of Plant Design Changes l

(Unit 3)

Review of Simulator Design Changes 2nd Otr 1998 Y

l (Unit 2)

Assessment Results INPO Accreditation Team Visit (ATV): To determine the status of Millstone's Operator Training Programs (Licensed Operator Initial Training, Licensed Operator Requalification Training, Non-licensed Operator Training, Shift Technical Advisor Training, and Shift Manager Training) with respect to the eight (8) accreditation objectives contained in ACAD-91-015, Accreditation Objectives and Criteria. The evaluation team consisted of both INPO personnel and NU peers. The evaluation team did not identify any weaknesses that were not self-l identified by Millstone in the Accreditation Self-Evaluation Report. The team evaluated the status of the eleven (11) Utility identified Weaknesses (UlW's) and defarmined that five (5) remain at the accreditation objective level and require

( ~.itinued attention. The other six (6) UlWs were determined to currently meet the accreditation objectives.

V Simulator Unit 3 Self-Assessment 98-006: Conducted to determine if the simulator group is receiving all pertinent items from the design process by a Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\S U S_PER RR M\\PM-207. DOC l

41 sampling using " Closure Tasks by ID No." for Millstone Unit 3 (MP3). This

.[

document represented a sampling of all items which were required for MP3 restart. The simulator group had received all but five documents, exceeding a 98% success rate. The items not received were determined to be of a minor nature and did not adversely affect training scenarios.

Simulator Unit 2 Self-Assessment 98-008: Conducted to evaluate the MP2 Simulator Certification Management System (SCMS) records for compliance with NSEM 5.01. This was accomplished by a review of 20% of all DR packages issued since the inception of the SCMS. The reviews showed that all DR packages were being maintained in accordance with NSEM 5.01 and that all DR packages not yet complete can be located.

i Performance Measures I

Indicator:

Executive Training Council Meeting KPI F-1 l

Status:

The Executive Training Council has been more active than the i

specified goal of one meeting per quarter.

I Indicator:

Training Advisory Committee Meeting KPl F-2 Curriculum Advisory Committee Not Meeting KPl F-3 i

Status:

The meeting frequency for the Training Advisory Committee (TAC) b has exceeded the goal of 3 TAC meetings per quarter. The Curriculum Advisory Committee (CAC) meetings have fallen behind the established goal of 55 CAC meetings per quarter. Training Advisory Committees (TACs) have been informed of this adverse trend. TACs have reinforced the meeting frequency requirement with station management.

Indicator:

Simulator Availability KPI F-4 Status:

The average Simulator Availability for the second quarter was 99.7%. All simulators exceeded the goal of 99%.

Conclusions Performance continues to improve throughout the training process. Involvement in the day-to-day training efforts by line personnel has fallen off due to the resource and time demands of startup and power ascension. Training performance is determined to be at a satisfactory level and fully supporting the continued safe operation of Unit 3.

O Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC

42

/#h b

Key issue:; Operational Performance l

I Success Criteria I

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

" Readiness for Operation" to " Operational Performance."

j l

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

Readiness Focus Complete the Licensed and Non-licensed Operator Training addressing changes to the plant and procedures, and provide required simulator training for normal start-up, operation, and abnormal conditions. Provide an opportunity for Operators to observe power operations.

Confirm, by Operations Management and Nuclear Oversight, that Operator Readiness will support the conduct of safe operation.

Confirm, by use of performance indicators, that operator burdens are

,O minimized.

~ (_)

Performance Focus Operational performance is consistent with established goals for excellence The plant is operated within the licensing basis and Technical Specifications Confirm, by use of performance indicators, that operator burdens are minimized Self-Assessments The following self-assessments are currently planned for 1998:

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

Management and Leadership (Unit 3) - 1st Quarter Culture Survey - 2nd Quarter Conduct of Operations (Unit 3) - 2nd Quarter Interface effectiveness between Operations and other departments (U,it 3) -

3rd Quarter EOP/AOP Operations Resource Support (Unit 3) - 3rd Quarter p

Configuration Control (Unit 3) - 4th Quarter Industry Recurring Operations Problem (Unit 3) - 4th Quarter V

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43 Effectiveness of Operations Department Corrective Action Program (Unit 3) -

0 4th Quarter Quarterly Assessment of Performance," Windows" l

Performance Measures The following performance measures will be used for the on-going monitoring of l

this Key Issue:

Readiness Foe s Temporary Modifications Operator Work-Arounds Control Room and Annunciator Deficiencies Open Operability Determinations Performance Focus Unplanned Automatic Scrams per 7000 Hours Critical Unplanned Safety System Actuations (ESFAS/RPS)

Safety System Performance - EDGs Safety System Unavailability - AFW and SI Systems Unit Capability Factor

(

Unplanned Capability Loss Factor Thermal Performance Fuel Reliability Chemistry Indicator Industrial Safety Accident Rate Unplanned Entry into LCOs Operator Errors (including procedure adherence and negative impact on core reactivity)

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC

r 1

l l

44 i

'SecondjQUartsrLStntiskMMR"[M Oberat'lonalPerfarmaricsM Assessment instruments Assessment Title Schedule Date Completed Revised (Y/N)

Date Conduct of Operations 2nd Quarter N

Third Qtr 98 1998 Nuclear Oversight Monthly Reports Monthly Y

Ouarterly Assessment of Performance, 1st Quarter 1998 Y

" Windows" Assessment Results Nuclear Oversight Restart Verification Plan, The monthly Nuclear Oversight Restart Verification Plan reports information which is evaluated bi-weekly.

Nuclear Oversight currently assigns Unit 3 Conduct of Operations a satisfactory O

grade with a cautionary note (" yellow" rather than " green") to underscore their concern based on ongoing efforts to complete corrective actions for configuration control events. Additionalline management and Nuclear Oversight attention has been placed on operator performance, which includes 24-hour coverage in the Control Room for unit restart and power ascension, and improvements in operator performance have been noted as the staff regains a better " operational 1

feel" for the plant following the extended shutdown period.

l Quarterly Self-Assessment. The Unit 3 line organization performs quarterly self-assessments (windows) of fourteen (14) departments including Operations.

During the second quarter of 1998, Operations was assessed as an overall

" white" (meets expectations / criteria). Thirty-eight (38) of the assessed areas which contribute to the overall window rating were evaluated as " green" (exceeds expectations / criteria) or " white." The exceptions include the following areas:

Surveillance Test was assigned a " red" (falls short of expectations / criteria, goals / criteria impacted) due to a surveillance that was missed in March; Logkeeping Practices were assigned a " yellow" (falls short of e

expectations / criteria, goals / criteria not impacted) as a result of weaknesses and areas for improvement identified during the period; Severe Accident Management and " Black Board" were " blue" (currently i

I unassessed or under development);

Mllistone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC

)

o-----________

45 I

Technical Specification Quality was evaluated as " yellow" due to greater than three condition reports (no Level 1's) for changes / clarifications required for Technical Specification conformity.

I NRC Operational Team inspection (OSTI). The NRC OSTI was conducted from April 1

13-24,1998. This inspectien was an independent, broad scope _ assessment of I

management controls, administrative programs, equipment and personnel and their l

readiness to support restart and safe operation of the Millstone Unit 3 facility. Specific l ~

to Operations, the OSTI team found that conduct of operations, procedures and procedure adherence, operator training and command and control to be generally good

- and were adequate to support plant restart. However, the team noted two operational events that occurred during heatup to Mode 3 and several plant equipment configuratiori issues which required root cause evaluation and implementation of corrective actions prior to plant restart. With the performance of these evaluations and l

associated corrective actions, the OSTI team determined that plant hardware, staff and management programs at Millstone Unit 3 were ready to conduct a safe plant restart and continued operation, i

Performance Measures Indicator:

Temporary Modifications KPl A-6 l

Status:

The number of Temporary Modifications is 16, one of which is required to support the restart. Of the remaining items,9 require l

design changes,4 are awaiting parts, and 2 will remain until the next refueling.

Indicator:

_ Operator Work Arounds KPI A-8 l

Status:

The Work-Around program is expanding in scope as the plant l

retums to power and different work-arounds are discovered.

l_

Eighteen work-arounds, including three awaiting retest, were listed l

as of the end of the second quarter of 1998. Three additional l

work-arounds have been added in July. New goals have been established as part of the unit backlog reduction program.

Indicator:

Control Room and Annunciator Deficiencies KPI A-7 Status:

The number of Control Room and Annunciator Deficiencies is ten.

These items are being aggressively worked as they are discovered on power ascension. The deficiency category is being expanded as part of the unit backlog to include the greater scope of equipment that would not be considered in a shut-down plant.

Indicator:

Open Operability Determinations KPl K-1 Status:

There are 28 open Operability Determinations for the unit.

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46

(.

Conclusions Significant issues noted during the second quarter included configuration control concems by NORVP; surveillance testing, logkeeping, severe accident management, blackboard, and Technical Specification quality issues by the Quarterly Self-assessment; and equipment configuration concems by OSTI.

Condition reports were written and compensatory actions taken to address the issues identified. These included extensive procedural reviews, field walk-downs of system line-ups, and reiteration of management's expectations for configuration control and procedure compliance. Long term corrective actions were initiated to prevent recurrence of the significant issues. Specifically, an overall program will be developed to integrate existing processes / programs into a total configuration control program.

The NRC Restart Assessment Panel (RAP) made a restart recommendation for l

Millstone Unit 3 to the Nuclear Regulatory Commission in June,1998, and the Commission recategorized the Unit to a Watch List Category 2 plant, thereby passing the final authority for authorizing restart to the Executive Director of Operations (EDO) and the Special Projects Office. Unit 3 notified the EDO that the Unit was ready to commence restart the end of June, along with the j

recommendation from the Special Projects Office to allow restart. The EDO approved restart with the condition that the Restart Plan, with power plateaus

(

and associated reviews, would be followed. Unit 3 began execution of the Restart Plan by bringing the plant to Mode 2 on June 30,1998 but then retumed to Mode 3 when Intermediate Range Nuclear instrumentation did not function properly. The Intermediate Range Nuclear instrumentation was repaired and Mode 2 was reentered within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

O Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER F\\R M\\P M-207. DOC

47 Key; issue Work Controliand!Pisndidg?.,,.

w gy g.

Success Criteria The following Success Criteria were previously 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 Preventive maintenance and surveillance activities are completed as scheduled Institution of an on-line work management process in a schedule adherence rate consistent with industry standards Self-Assessment The following self-assessments are currently planned for 1998:

O)

Work Management Training Issues and Compliance - 1st Quarter

(

Resource Loading Analysis -4th Quarter Procedure Usage and Compliance - Refueling Schedule - 2nd Quarter Maintenance Planning Effectiveness - 3rd Quarter Schedule Adherence - 3rd Quarter Work Management Corrective Action Program - 3rd Quarter INDUS Passport Automated Work Order (AWO) Software - 4th Quarter Maintenance AWO/ Procedure and Feedback Program Effectiveness - 4th Quarter Condition Report Process and Tracking Effectiveness - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key Issue:

l On-Line Corrective Maintenance Backlog Preventive Maintenance Tasks Overdue (b

N Surveillance Performance Schedule Performance Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_P E R RR M\\P M-207. DOC

l 48 Second.Q'uarterStittuhd31i idorliiContMliandplanningw,_

\\

Assessment Instruments h

[

WC-14 Work Control Self-Assessment 2nd Quarter Y

j l

Second Quarter Condition Reports 2nd Quarter Y

{

l Quarterly Assessment of Performance, 2nd Quarter Y

l

" Windows" l

l l

Assessment Results i

Second Quarter Condition Reports l

All condition reports from the second quarter were reviewed for their bearing on the recovery plan and success criteria. While several issues were identified, one i

significant issue conceming control of work associated with RCS*V132 represented a deficiency in awareness of requirements associated with high risk

/~3 activity. Related corrective actions have been implemented to prevent

h recurrence. Additionally, the review did not reveal any new trends representing l

issues which had not been previously identified.

l 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.

l I

l i

j

/

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49 O

Performance Measures Indicator:

On-Line Corrective Maintenance Backlog (On-Line Work Order Status) KPl A-5 Status:

The On-Line Corrective Maintenance Backlog has attained our established goal indicator:

Overdue Preventive Maintenance AWOs KPI J-2 Status:

Prevent:ve Maintenance tasks overdue remain at the established goal of zero indicator:

Surveillance Test Program Schedule Performance KPl J-1 Status:

Performance remains satisfactory on average Indicator:

On-Line Schedule Performance KPI J-3 Status:

The goal for work activities started and completed on time have not been consistently met due to emergent work activities and rescheduling required to support the start-up and power ascension.

Conclusions The tools required to monitor that performance are being maintained in this area.

The online scheduling starts have been evaluated for improving performance.

Performance is improving and should attain the goal next quarter.

L M!ilstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC

i 1

1 50

\\OV Kep; issue: tProcedure QuslitvfandjXdliersnc' ef gl Success Criteria The following Success Criteria are 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 acceptable l

Instances of not adhering to procedures remain at an acceptable level Self-Assessment 1

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

l Station Administrative Procedures Window - Quarterly lO Procedure Biennial Reviews - 1st Quarter l

Procedure Compliance - 2nd Quarter Station Qualified Reviewer - 3rd Quarter Master Manual - 4th Quarter t

1 Performance Measures 1

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 l

1 l

I f%

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51 O) i V

Second Quarter l Status;, * [ Procedure 0ualityfand dhnence/.

7 l

l t

l Assessment instrument 1

AssessmentTitle e schedule;

. Completed,- y; Revised)

o-v.

Date-

.(Y/N),c1

. Schedule'.if.?

Not Con plete:

l Biennial Review Status 1st Otr.

Y 1998 Procedure Compliance 2nd Otr.

Y 1998 Station Administrative Procedures Quarterly Y

Group Window for Procedures Quality Assessment Results Procedure Compliance l

O)

The Station Administrative Procedure Group completed a self-assessment l

" Procedure Compliance" for the second quarter of 1998. The assessment team looked at a programmatic issue, " Confined Space Entry," and detennined that i

when Management / Supervision is "part of the process" and sets the standards for all involved, Millstone processes do work and procedures are complied with.

Station Administrative Procedures Group, Window The Station Administrative Procedure Group Annunciator Window for Procedure l

Quality reported the following performance:

Station Qualified Reviewer Program " White"(Satisfactory) l Organizational Effectiveness " White" Administrative Procedure Process " White" Procedure Upgrade Project - Project Complete i

N.,

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\ SUS _PER RR M\\P M-207.DO C

52 y

Performance Measures Procedure Compliance Millstone Unit 3 KPI D-1. The total non-compliance errors /1000 hours has remained below the goal of 0.5 for Unit 3 since December of 1997 indicating satisfactory performance. The trend of maintaining performance has been demonstrated throughout the quarter.

Condition Reports involving Deficient Technical Procedures KPl D-2. The quality of technical procedures for Unit 3 and the Station is acceptable. The total number of procedure-related 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 This assessment shows that performance is being maintained. The technical accuracy of procedures and procedure compliance is improving at Unit 3 and across the station. Performance with respect to the success criteria established for procedure quality and adherence is at a satisfactory level.

Old i

i l

i O

l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRimPM-207. DOC

53 rs Key.lss'uet Emergency Planning (,

l t

Success Criteria l

l The following Success Criteria were previously established and summarize the performance baseline for this Key issue Demonstrate that Millstone Station has an effective Emergency Response 1

Organization Complete Emergency Preparedness Maintenance program improvement actions Self-Assessment I

i l

The following self-assessments are currently planned for 1998:

Effectiveness of Root Cause and Self-Assessment Corrective Actions - 1st Quarter

,Q Emergency Action Level Annual Review - 2nd Quarter V

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 performance measures will be used for the on-going monitoring of 1

this Key issue:

Station Emergency Response Organization l

Off-site Emergency Response interface / Activity l

Regulatory Compliance l

Conduct of Drills t

Station Emergency Plan & Procedures Industry Benchmarking Y

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54 f

lSecond;Qu.arter; Perform,.ances

.a E,m,ergency) Planning:

.,..m l

Assessment instrument Assessment Results

' AssessmentTitle

Schedulec (Completed JRevised( '

+

Date *.

-(Y/N)7-ScheduleIf Note w

O Completsi EAL Self-assessment 2nd Quarter N

Started-2nd 1998 Quarter Scheduled Completion-3rd l

Quarter Inventory of Response 2nd Quarter Y

Facilities and Equipment 1998 Emergency Response Drills 2nd Quarter Y

1998 Assessment Results Emergency Action Levels (EAL) Self-Assessment The start of the second quarter self-assessment on Emergency Action Levels was delayed until June it is currently in progress and is scheduled for completion by the end of July.

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

Emergency Response Drills l

A Unit 1 SERO drill was conducted on June 17,1998. All objectives selected for the drill were demonstrated and a number of new SERO members were qualified through participation in the drill. A critique was conducted where issues were identified and subsequently entered in the station corrective action process.

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER RR M\\PM-207. DOC

55 In addition, a Unit 3 Post Accident Sample System (PASS) drill was conducted on June 19th. This drill was observed and evaluated by the NRC to address outstanding Unit 3 restart issues. All objectives selected for the drill were met s

and there were no significant issues identified by the NRC. NU concluded and the NRC confirmed that the Unit 3 PASS was adequate for restart.

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 drills to satisfy qualification requirements and fill vacant positions. Selected SERO members are also being scheduled for training associated with Severe Accident Management.

Off-Site Response Offsite interface activities continued to be conducted. Routine monthly meetings between Millstone Emergency Planning Services Department (EPSD)

Management and staff were held with State of Connecticut OEM Director and staff to discuss 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 second quarter meeting was held on May 15th. It should also be noted FEMA has discussed an interest in attending future meetings.

I Regulatory Compliance One Notice of Violation (NOV) was received during the second quarter (April).

The NOV was associated with the PASS and resulted from the NRC Inspection conducted in February. A response to the NOV was issued. The NRC retumed to the site in June to evaluate a Unit 3 PASS drill and associated PASS documentation. NRC verified that the PASS was adequate for the restart of Unit 3.

Conduct of Drills Two drills were conducted during the second quaiter. A Unit 1 SERO drill was conducted on June 17th and a Unit 3 PASS drill June 19th. Selected objectives for both drills were met and areas for improvement identified. Improvement items are being tracked by the station corrective action process.

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i 56 Emergency Response Plan Approval was received in June from the NRC on Revision 24 to the Millstone Emergency Plan. The plan is scheduled to be implemented 60 days from the date of approval. Familiarization for affected SERO members on the changes j

made to the plan is in progress. This activity will be completed prior to plan implementation.

I i

A project to streamline emergency planning procedures was initiated and is scheduled for completion in October,1998. Severe accident management t

procedures are in the process of being developed for Units 3 and 2 and are l

scheduled to be completed by the end of August.

l Industry Benchmarking Millstone EPSD was involved in two industry benchmarking activities during the second quarter. The EPSD Manager attended the annual NEl conference in June and an EPSD staff member participated as part of a Duke Engineering team conducting an emergency planning audit at the Vermont Yankee site.

i Industry benchmarking on the subject of the PASS is scheduled to be l

conducted in the third quarter.

i l,

Conclusions

)

,k l

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 e,urveillances. 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.

I l

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57 I p()

, Key issue:J Radiological Protectioni 1

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

Nuclear Oversight Assessments of the Radiation Protection Program indicate l

satisfactory performance Demonstrate compliance and high standards l

Foster a culture of Radiation Protection Program ownership Achieve a going forward goal of zero incidence of High Radiation entry l

dosimetry events Achieve a goal of less than one event per 20,000 entries into any Radiologically Controlled Area Self-Assessments Igg The following self-assessments are currently planned for 1998:

(,)

Health Physics Equipment Program Assessment - 1st Quarter Radioactive Materials Shipment - 1st Quarter Mixed Waste - 2nd Quarter Radiation Protection Surveys (Unit 3) - 2nd Quarter l

Station ALARA Program Assessment - 3rd Quarter

{

Tool Decontamination in the Solid Radwaste Building - Process and Techniques - 3rd Quarter HP Training and Professional Development (Unit 2) - 4th Quarter i

Free Release of Materials in Warehouse #9 - Process and Techniques - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:

Cumulative RCA Entry Error Rate, Millstone Station i

Low Level Radioactive Waste Volume 6

Radiation Exposure j

O i

l Millstone Station / Unit 3 Second Quarter Performance Report l

08/10/98C:\\RWMiOTR LY\\S U S_PE R RR M\\P M-207.D O C l

1

58 O

Q)

Second Quarter l Performance

_ um Radiologi. cal: Protection %

Assessment Instruments I

Assessment Title schedule Completed.

Revised schedule 1 1

Date

.(Y/N)

If Not Complete?

l Radioactive Material Jan 1998 Y

N/A Transportation Training

  • Monitoring Equipment, April 1998 Y

N/A Engineering Controls, Respirators Mixed Waste April 1998 Y

N/A Confirmatory Monitoring April 1998 Y

N/A Radiation Protection Surveys June 1998 N

July 1998 (Unit 3)

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.

  • The Radioactive Material Transportation Training self-assessment was conducted in January 1998 but not reported in the previous report.

Assessment Results Monitoring Equipment, Engineering Controls, Respirators (HP98 HPSA-01,02,03)

This was a multi-unit team observation of three major components of the station radiological protection program. No significant adverse findings were listed in the radiological monitoring instrumentation area or in engineering control (i.e.

shielding, HEPA ventilation, etc.) area. The respirator program has several areas of improvement opportunities as detailed in station generated CRs.

Confirmatory Monitoring Mini-Assessment (3HP-98016)

This self-assessment looked at Unit 3 effectiveness of engineering controls, representative air sampling, and biologicalintake data for 1997. This l

assessment determined that no significant radionuclides uptakes occurred in i

1997 at Unit 3. This assessment listed areas of improvement for proper identification of air samples in the air sample logs to improve the usefulness of the information for assessment purposes.

(

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59 l

i Radioactive Material Transportation Training (NS 98-28)

A self-assessment of the Radioactive Material Transportation Training, (RMTT),

provided by a vendor was conducted January 17 through January 30. The RMTT program was determined to function effectively and no areas for improvement were identified. Significant strengths of this program included the excellent correlation between the course objectives / agenda and the test questions and between the training objectives and the training material.

Mixed Waste Self-Asa,essment (NS 98-21) l The mixed waste self-assessment conducted on April 21 and April 22 identified a number of potential 40 CFR (EPA) environmental compliance issues as well as program enhancement recommendations. Condition Report M3-98-2922 was initiated as a result of this assessment and 8 corrective actions were developed.

These are expected to be completed by the end of 1998 with an effectiveness review scheduled for completion by March 1999.

Performance Measures 1

Cumulative RCA Entry Error Rate, Millstone Station KPI H-1. The major l

radiological protection adverse condition identified in 1997 was the failure to assure that personnel had the required monitoring devices consisting of a

'O TLD and electronic dosimeter in the RCA envelope. Millstone Station V

underwent several improvement initiatives and management actions in 1997 to address this weakness. A. continualimprovement performance has been realized in dosimetry compliance during this period. Since July 1997 Millstone Station has met or surpassed its performance goal of less than one dosimetry infraction per 20,000 RCA entries. In 1998, Millstone station is averaging less than one dosimetry infraction per 37,000 RCA entries. The performance goal has now been raised to one infraction per 25,000 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. In the past 12 months, all dosimetry events have been reported by workforce personnel rather than Nuclear Oversight or Nuclear Regulatory Commission reports.

1998 Rad Exposure Summary KPI H-2. The 1998 cumulative radiation i

exposure for Millstone Unit 3 has been set at less than 51 rem. This goal l

represents the level of exposure which the Health Physics department strives to stay below in order to maintain occupational exposures as low as reasonably achievable (ALARA). To date, the cumulative exposures are tracking well within the ALARA goal.

lO l

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I 60 Conclusions g\\

l Nuclear Oversight has reported an event at Unit 2 conceming survey adequacy and monitoring for alpha activity. This resulted in an Event Review Team report with several proposed corrective actions.

A culture 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 self report infractions. An improvement has been realized in the Radiation Worker training program with the advent of improvement in the practical factor facilities and HP l

technician involvement in radiation worker training, j

Improved process centers for health physics functions has been accomplished by closing multiple entry points into the RCA and the installation of mechanical tumstiles 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 l

of a timed portal monitoring system at station exit points. Additionally, a truck i

contamination monitor is being installed as a first devise of its type at a US j

commercial nuclear utility during 1998. Millstone Station is maintaining an effective radiological protection program commensurate with safe nuclear l

O operations and industry standards of performance.

,b 1

I l

l l

l I

l J

V)

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61 l

lO

( )

Key 31ssue':; Securityi Success Criteria l

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

Security Alarm Response - 1st Quarter SSMR Process - 1st Quarter CAS/SAS Operation - 1st Quarter Personnel PA/VA Access Control - 1st Quarter

f)T Socurity Training Program - 1st Quarter k.

Station Qualified Reviewer implementation - 1st Quarter Security Weapons Testing / Surveillance / inspection - 1st Quarter l

Security Processing Center - 1st and 3rd Quarters Visitor Control - 1st and 4th Quarters Protection Security Personnel - 2nd Quarter Patrolling - 2nd Quarter Security Locks and Keys - 2nd Quarter 1&C Training and Qualification - 2nd Quarter Safeguards Information - 2nd and 4th Quarters l

Vehicle PA Access Control-2nd and 4th Quarters Fitness For Duty Center - 3rd Quarter Security Surveillance - 3rd Quaiter Contractor Termination - 3rd Quarter Application of Compensatory Measures - 3rd Quarter Performance Observation Program - 3rd Quarter Security Lighting - 3rd and 4th Quarters Security Report / Trending Analysis - 4th Quarter

(]/

Station Lock and Keys - 4th Quarter Security Emergency Response - 4th Quarter Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98 C :\\RW M\\QTR LY\\S U S._P E R F\\R M\\P M-207.D OC

62 V

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

Control of Safeguards Information Vehicle Controlinside the Protected Area Security Badge Control Control of Visitors Inside the Protected Area Second QuOterstattis; "i

uz.i

', [Sicurityd Assessment Instruments

% A'ssessmentTitle 34 7 !sc_hedulef [Compjetedj RHevised)

. +j 4: g #

,' % d !!

1 iDate!

W

^ ScheduleIfi:

a;, Qp. y@(Y/N)?M YJ 1Nsticompidteh

,a t

1 g;7 j

[')

I&C Training and Qualification 2nd Y

\\v/

Program Quarter 1998 Security Lighting 2nd Y

Ouarter 1998 Security Locks and Keys 2nd Y

Ouarter 1998 Vehicle Protected Area Access 2nd Y

Control Quarter 1998 Patrolling 2nd Y

I Quarter l

1998 l

Safeguards Information 2nd Y

Quarter 1998 O

s t

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTR LY\\SU S_PER F\\R M\\P M-207.DO C

63 1

Assessment Results Fourteen self-assessments were scheduled and completed during the first two quarters of 1998 - eight in the first quarter, and six in the second quarter. The j

self-assessments covered the topics shown above and resulted in

)

recommendations to enhance the respective programs. These self-assessments were documented under 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. A brief synopsis follows:

Second Quarter I&C Training - Technicians are knowledgeable of equipmont and repairs, l

good resource library available, Department Instruction addressing I&C j

Training needs complete revision.

l Security Lighting - Procedures dealing with Security Lighting are accurate and concise, recommendations focused on lighting level surveys and how they should be conducted.

Security Locks and Keys - Security and Operations personnel are knowledgeable of the program, recommendations focused on enhancements to existing procedure.

Q

. _ Vehicle Protected Area Access Control - New computer program in place and working, additional person assigned to duties at Vehicle Access Point, recommendations focused on enhancements to existing practices.

Patrolling - New patrolling practices implemented and working, recommendations focused on clarification on procedure wording.

Safeguards - Security and Non-Security custodians of Safeguards Information knowledgeable in program, recommendations focused on enhancing control of material in the Security Safeguards Work Center and Central Alarm Station.

1 Performance Measures Key performance indicators have been established for the following areas:

Control of Safeguards information KPl1 A goal of no more than three i

events was established for 1998 - a reduction from the 1997 total of ten j'

actual events. Two events have occurred during 1998 ( one in the 1st quarter, one in the 2nd quarter) causing this KPl to track satisfactorily.

Vehicle Controlinside The Protected Area KPl1-2-- A goal of no more h

than six events was established for 1998 - a reduction from the 1997 total of V

eight actual events. Four events have occurred during 1998 (one in the 1st l

I

. Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-2Q7. DOC

64 quarter, three in the second quarter) causing this KPI to be overall satisfactory with improvement needed.

N Security Badge Control KPl 1-3 A goal of no more than 96 events was e

established for 1998 - a reduction from the 1997 total of 141' actual events.

l Thirty-two events have occurred during 1998 (eighteen in the 1st quarter, 1

fourteen in the 2nd quarter) causing this KPI to track satisfactorily.

j Control of Visitors inside The Protected Area KPI l A goal of no more than 12 events was established for 1998 - a reduction from the 1997 total of j

25 actual events. Five events have occurred in 1998 (two in the 1st quarter, three in the 2nd quarter) causing this KPl to be overall satisfactory with

- improvement needed.

i 4

Conclusions j

This assessment shows 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 on l

track to meet our goal in security related events. Security programs are satisfactory and will support the restart of Unit 3 and continued safe operations.

,OV l

l I

l

\\

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC

l 1

65

/%

C)

Key lssueqEnvironmental Compliance; Success Criteria l

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

l l

The program and procedures that cover environmental requirements exist l

and are effective; and l

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

Self-Assessments i

The following self-assessments are currently planned for 1998:

Assess the adequacy of Environmental Roles and Responsibilities Manual -

2nd Quarter l n 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 t

i 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 l

appropriate / effective - 4th Quarter l

Performance Measures i

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

i Notices of Environmental Violation

)

NPDES Permit Exceedences Prompt Reports to the Department of Environmental Protection (DEP) t]

Spills O

Progress Against ISO 14000 Environmental Management Standard l

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C ARWM\\QTR LY\\S U S_P E R RR M\\PM-207,D O C L----------------------

I

(

66 O

Ne6ond;Qusrt'ehStatusr ~

r,[f Tsiivironmehtal"Complianc'eM Assessment instruments AssessmentTitles
Schedulen (Completed
Hovised>.a 3

m

-w Date:.,

l(Y/N)f > : Schedule if Not?

a

'Completoi o

gg Environmental Roles and April 1998 Y

Responsibilities Manual Effectiveness Air Quality Program Compliance June 1998 Y

and Procedural Effectiveness Environmental Correspondence June 1998 N

July 1998 and Commitment Tracking Effectiveness Nuclear Oversight Audit of Air Mar.1998 Y

Quality and Meteorology Root Cause Investigation of May 1998 Y

j tO Meteorological Program Issues Root Cause investigation of Water April 1998 Y

Ouality Parameters from EDAN Root Cause Investigation of June 1998 Y

Emission Source Permits Assessment Results Environmental Roles and Responsibilities Manual The Environmental Roles and Responsibilities Manual self-assessment evaluated the adequacy of the manualin clarifying, for affected managers, their respective environmental duties. The assessment indicated that the manual was a good first step in defining environmental ownership, but certain programs, such as meteorology which bridge multiple functions, still lack clear program ownership. Condition Reports are in place to address the gaps. As indicated below, the ownership issue has been resolved and, going forward, responsibilities will be further clarified as part of the site Environmental Program Manual Program Description under development.

(

Air Quality Program i

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/980:\\RWM\\QTR LY\\SU S_PER RR M\\PM-2Q7. DOC

1 67 i

The assessment of air quality compliance which included permits and related O

documentation indicated that significant improvement had taken place in the air quality program in the last twelve months and that for each major issue identified l

from our reviews there were action plans in place. For example, preparation of l

the required Clean Air Act Title V permit application and an Oversight Audit indicated emission sources for which permits had apparently not been obtained.

l As of June 30, all sources on site had operating authorizations in place as a l

result of corrective actions. Remaining areas of improvement include l

documentation and record keeping for emissions. A CR has been prepared to modify procedures and related forms to ensure proper records of fuel use and engine operation are kept and forwarded to Environmental Services for reporting i

to DEP.

Nuclear Oversight Air Quality Audit At the request of Environmental Services, Nuclear Oversight performed an audit of the station's air quality program including emission sources and meteorology.

i The review made a s'gnificant contribution toward improving each of these environmental prog.am areas. Sources of emicsions apparently without permits were identified art i authorizations were subsequently obtained from CT DEP as i

noted above. De1iciencies within the meteorological program, including tower l

operability, were inked to lack of clear program ownership and support.

Corrective actior,s are discussed below.

l (3

i V

Root Cause, Meteorology The root cause stemming from the above audit confirmed Oversight's findings i

with respect to the need to clearly identify program ownership. Additional issues to be resolved included revisions of associated procedures used by on and off-l site organizations and clarification of the design bases for the meteorological system including ties to tech specs and FSARs. Program ownership has subsequently been assigned to the Vice President Nuclear Work Services and the Manager Environmental Services. The tower has been returned to operable status in conformance with tech specs of all three units. Additional Action Requests from the root cause are underway.

Root Cause, Water Quality Parameters A CR indicated discrepancies in the use of the Environmental Data Acquisition Network (EDAN) cooling water flow data for the purpose of calculating radioactive effluent releases and resulting dose assessments. The flows used for dose assessments were not necessarily the pump design values and j

therefore were different than those reported to DEP for purposes of water quality monitoring. While this CR was classified as a level 2, Environmental Services undertook, on its own, the performance of a root cause considering the importance of the dose calculations and the fact that other EDAN data are used d

for NPDES permit compliance. As with the EDAN system as it relates to meteorology, there was not clear ownership for these data, nor effective Mbione Station / Unit 3 Second Quarter Performance Report 08/10f98C:\\RWM\\QTR LY\\ SUS _PERF\\R M\\PM-207 DOC

68 coordination among the various users. Environmental Services has now.

I assumed on-site EDAN ownership and has moved to resolve these issues b

through the CR process.

Root Cause, Emission Sources Requiring Permits l

The above audit of air quality compliance indicated that two sources of emissions had expired permits, that record retention for the purpose of emissions reporting i

was not well organized and that it was unknown whether the emissions sources l

on site met CT DEP opacity requirements. The root cause was attributed to a l

lack of management focus on these issues historically and a corresponding lack I

of clarity in respective roles and responsibilities. However, with the formation of the on-site Environmental Services organization in early 1997, accountability for programmatic development and support of implementation has been established. Further, as a result of this audit, related self-assessments and preparation of the Title V Clean Air Act Permit application, our knowledge of and our attention to permit issues and related monitoring of air sources at Millstone Station has increased dramatically. Action Plans are in place to address these issues. As indicated above, all sources in use on site now have authorizations and additional submittals to the CT DEP are planned to deal with longer-term permit issues.

O Performance Measures V

Ag79W T* ?

@wy Notices of Environmental Violations None None (one DEP audit thus farin 1998)

Number of Spill Reports TBD 8

Number of NPDES Exceedences 3

None ISO 140001 Progress (17)

Number of Elements EMS Action Plan Elements Complete in 1998 Complete,in review l

Training Programs Development Complete July 1998 Eight of ten modules developed to date Environmental Screeningin Key Complete in 1998 DCM,DC3,MP2-WC1, Procedures NGP 5.14, EPIP Reporting, complete T)rompt Reports to DEP TBD 15 The above environmental performance measures are a combination of 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 i

station procedures which control design modifications and physical work.

Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERF\\RM\\PM-207. DOC 1

69 Regulatory reporting requirements have led to several Prompt Reports to the

/s Department of Environmental Protection. These reports relate largely to the fact b

that the design bases of the plant discharges were not adequately described in the prior NPDES permit application upon which the current permit is based.

Major efforts are underway to resolve this matter. Going forward, once a database has been established for prompt reports, a target can be establistad; the intent being to reduce the number of reportable events over time.

The absence of NPDES Permit Exceedences reflects the units' ability to manage water quality activities in conformance with those permit conditions clearly expressed in the permit. This measure remains on track.

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. Completion of the training modules is expected by July 1998, whereas development of a documented EMS will progress over the course of 1998.

Conclusions

/'

During 1997 and the first half of 1998, Millstone Station has made significant

'(

progress in identifying and implementing environmental program enhancements.

Our current status is satisfactory. Baselines for certain key performance indicators are still being developed.

With regard to Unit 3 restart, potential air and water quality compliance issues were identified and corrective actions have been 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 rnanagement 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. The above discussion of these reviews indicates an ability of the station and Environmental Services to critically evaluate its own performance and implement continuous improvement. Longer-term programmatic improvements are also underway.

Regulatory compliance and program enhancements are being tracked to assess

(

performance and progress of improvement programs. Environmental

(

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

l Millstone Station / Unit 3 Second Quarter Performance Report 08/10/98C:\\RWM\\QTRLY\\ SUS _PERRRM\\PM-2Q7. DOC l

L

MILLSTONE STATION UNIT 3 Key Performance Indicators

< i

Index I

(~h

(/

Key Performance Indicators Millstone Unit 3 KPls Pace Number KPl Title A-1....................

Condition Report Evaluation Timeliness A-2............................

Condition Report Method of Discovery A-3............

Overdue Corrective Actions A-4................................

Human Performance, Millstone 3 A-5...

On Line Work Order Status A-6...........................

Temporary Modifications A-7..........

Control Room and Annunciator Deficiencies A-8.....

Operator Work Arounds A-9.........

Condition Report Evaluation Quality Score Safety Conscious Work Environment KPis B-1.............................

Leadership Assessment (SCWE Element)

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

Culture Survey (SCWE Element)

B-3............................

NU Concerns and NRC Allegations Received, Millstone Station B-4.......

Millstone Employee Concerns Confidentiality Trend, Millstone l

B-5.......

Employee Concern Resolution Timeliness C

B-6....................

Employee Satisfaction With Employee Concerns Program B-7........................

Focus Area Action Plan Status, Millstone Station

\\"

B-8...................

Substantiated Concerns involving Potential Violations of 10CFR50.7 Oversiaht KPis C-1................

Status of Oversight Condition Reports, Millstone 3 C-2.............................

Nuclear Oversight Restart Verification Plan, Millstone 3 Additional KPls Procedure Compliance and Quality Indicators Peoe Number KPl Title D-1.....

Procedure Compliance, Millstone 3 D-2................

Unit 3 Closed CRs involving Deficient Technical Procedures AdditionalCorrective Action /Self AssessmentIndicators E-1........................

Median Age of Open Condition Reports NSclear Trainino Indicators F-1....

Executive Training Council Meeting j

F2.............................

Training Advisory Committee Meeting l

(f 3 F-3....

Curriculum Advisory Committee Meeting l

V)

F-4.........................

Simulator Availability 1

l l

l 1

Index P(

Key Performance Indicators Culture and Leadership indicators G 1..

Leadership Assessment G - 2............

Culture Survey Radioloalcal Protection Indicators H-1.

Cumulative RCA Entry Error Rate, Millstone Station H-2.....................

Rad Exposure H -3......

Self Reporting Culture Chart Security Indicators 1 1........

Control of Safeguards Information 1-2.................

Vehicle Control Inside the Protected Area 1-3........................

Security Badge Control 1-4......

Control of Visitors Inside the Protected Area Additional Work Control Indicators J - 1...........

Surveillance Test Program Schedule Performance j

J-2....

Overdue Preventive Maintenance AWOs i

J-3..

On-Line Schedule Performance I

Additional Operational Readiness indicators i

K-1........

Open Operability Determinations i

l l

I 1

s l

Condition Roport Evaluation Timeliness Millstone 3 - July 1998 greSS; Performance is not meeting management's expectations.

.0 35 -

ilInImlllh e

e e

e e

e e

e e

e e

g I

i i

I i

8 i

s l

5 Average Age of CR Evals l

Raw Date 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24'98 7/1/98 Average Age of CR Evale 26 30 29 31 35 29 29 31 36 34 34 34 Total CR Evals Regwred 98 86 91 124 45 98 115 89 69 102 88 61 Evals Completed within 30 days 71 66 70 90 41 84 89 67 44 72 70 46

,. Evals Completed within 30 Days 72 %

77 %

77 %

73 %

91 %

86 %

77%

75 %

64 %

71 %

80%

75 %

Definition Analysis! Action This indicator depicts the average age of Level 1 & 2 Condition Reports The average age of a CR evaluation over the last 12 (CRs) for which evaluations are still open, evaluations which were weeks is 31.5 days.

completed during the week being reviewed and the age of CR's that were originated during the week under review.

This KPI is showing a negative trend in the % of CRs evaluated witnin the 30 day requirement. After peaking Once issued, Condition Reports are evaluated to determine the

@ 91% on 5/13, the subsequent seven reporting corrective actions that are necessary to address the issue and prevent periods have shown an overall decrease in the number recurrence. The 30 day clock begins on the day the assignment is of evaluations completed within 30 days (86%,77%,

made and ends when the CR is received in the Corrective Action 75%,64%,71%,80% and 75% respectively).

l Department for review.

CR evaluation timeliness is not meeting management's j

expectations. The Unit Leadership meeting will provide I

a focused review of performance vs. goals.

" cal Comments l

The average time to complete a CR evaluation does not show an The expectation is that CR evaluations are completed

" verse trend, and the average time to complete a CR evaluation within 30 days. Due date extensions for evaluations are j

fdays.

the exception and only granted on a case by case

. pports SCWE Success Criterion #2 basis. The Average Age for 6/24 has been corrected.

j D;ti Source:

AITTSl Analysis by:

W. Rein x3707MPl Owner:

G. Winters x5491MP A1

1 l

Candition R3 port Mothod of Diccovery Millstone 3 - July 1998 rog(OSS:

Performance is satisfactory. Excluding the ICAVP data, the goal was achieved in 10 of the past 12 weeks.

50 %

g 40%

a 30 %

-i a

20 %

g G00d gi gl]

Goals 10%

{

10%

0%

i

!89 8

8 i

8 i

8 i

i i

i s

s 9

s 8

s s

s a

% Extemal + Event IC::Ol% External + Event -ICAVP Goal !

RawDats 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98

% External + Event if%

26 %

17%

20%

8%

8%

16 %

7%

1%

5%

1%

6%

% External + Event -lCAVP 3%

19%

13%

5%

6%

7%

8%

4%

1%

6%

1%

6%

Goal 10%

10%

10%

10%

10%

10%

10%

10%

10%

10%

10% - 10%

Unit CRs 70 77 72 80 92 88 77 75 107 93 98 66 Internal Oversight CRs 15 10 5

6 6

9 10 13 11 11 9

8 External Oversight CRs 13 28 15 21 8

6 15 6

1 4

1 4

Event CRs 2

2 1

1 1

3 1

1 0

1 0

1 Total CRs 100 117 93 108 107 106 103 95 119 109 108 79 External + Event CRs 15 30 16 22 9

9 16 7

1 5

1 5

ICAVP 12 10 4

17 3

2 8

3 0

0 0

0 Definition Analysia/ Action This indicator depicts the percentage of Unit 3 CRs identified by including the ICAVP Discrepancy Report CRs had a external sources or events compared to the goal. Although large negative impact on the results. Percentages are displayed, special external assessments such as ICAVP were shown with and with out ICAVP included. Excluding the not factored in establishing the goal. CRs are categorized into ICAVP data, the goal was achieved in 10 of the 12 the following four areas:

weeks displayed.

Event Driven - Self-revealing, an event occurs External Oversight - Identified by the NRC, NCAT, INPO, etc.

Internal Oversight - Identified by PORC, Nuclear Oversight, NSAB, NSE, etc.

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

It is desirable to have a low perce1tage of all CRs generated by external sources or events, and a high percentage generated by the line organization or internal oversight.

Gos!

Commente The goal is to have s 10% of issues (CRs) identified by external Errors found in data used for last report (6/24) have

} sources or events assuming a levelized NRC inspection effort.

l been corrected.

l Data Source:

AITTSl Analysis by:

W. Rain x3707MPl owner:

G. Winters x5491MP A-2 e

L-------- ------------------- ---

1 Overdus Corrective Actions Millstone 3 - July 1998 l

p YOg(OSS:

Performance is not meeting management's expectations. Management attention has increased in this area.

l l

7.00 %

6.50 %

6.00 %

g l

j 5.50%

l g "5.00%

g j",

Goals 3%

a J 3.50%

cond e 3.00%

5 2.50 %

2.00 %

0 1.50 %

  1. 1.00 %

0.50 %

0.00 %

l l

1 I

I I

I I

I I

I e

e e

e e

e e

e e

e m

5 0

3 5

S S

5 5

8 M% Overdue Goal l R'w Dats 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98

% Overdue 1.52%

3.10%

2.74 %

3.36 %

1.79%

2.83%

2.32%

6.06 %

3.48 %

4.71 %

4.06 %

6.71 %

'oal <; 3% of Total Open C/A 3%

3%

3%

3%

3%

3%

3%

3%

3%

3%

3%

3%

Open Level 1 C/A 339 302 310 294 273 322 344 328 308 327 325 304 Open Level 2 C/A 2549 2470 2424 2503 2519 2537 2546 2497 2420 2453 2555 2514 Total Open C/A 2888 2772 2734 2797 2792 2859 2890 2825 2728 2780 2880 2818 Total Overdue C/A 44 86 75 94 50 81 67 143 95 131 117 189 Definition Analysis / Action This indicator depicts the percentage of the total corrective actions The Unit has met the goal of s 3% overdue Correctiva (C/A) that are overdue.

Actions 5 of the 12 weeks displayed with an overall average of 3.47%.

Corrective actions are developed to address issues and problems identified by Condition Reports (CRs). Overdue corrective actions The Unit's focus on Mode 2 related work affected the are ones that have not been completed by the scheduled due date.

Unit's ability to meet this goal during the month of June.

The monthly " bow" wave of due assignments (119 out it is desirable to have a low percentage of overdue corrective of 189 were due 6/30/98) is the major contributor to this actions relative to the total number of corrective actions that are weeks overdue ratio.

open.

l The Unit Leadership meeting has been revised to I

provide a focused review of performance vs. goals.

Goal Comments The goal is for the percentage of overdue corrective actions to be

< 3% of the total open corrective actions.

I I

Jupports SCWE Success Criterion #2 l

D 22 Source:

AITTSl Analysis by:

W. Rein x3707MPl Owner:

G. Winters x5491MP A-3

Human Performance Millstone 3 - July 1998 s

'j Progress:

Performance Is below the stated goal and management attention has increasedIn this area.

100%

Goal: 2 95% of Total I

95g,

90% -

KPI data current g

85%,

through the end of June 1998 80% -

Good 75% -

70% -

65% -

60%

55% -

50 %

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

M % Low Significance (Precursor) Errors Goalj I

Raw Dets j

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

% Low Significance (Precursor)

Errore 92%

91 %

93%

91 %

83%

86%

Goal 95%

95%

95%

95%

95%

95%

95%

95%

95%

95%

95%

95%

(

Human Error Precursor Events 112 107 81 102 76 69 Human Error Near Miss Events 8

11 6

10 16 11 l

Human Error Breakthrough Events 2

0 o

0 0

0 l

Total Human Error CR's 122 118 87 112 92 80 l

1000 Productrve Hours Worked 154.54 164 55 165.59 155 66 150.03 134 61 Definition AnalysisfAction This indicator depicts the percentage of human errors with low Although the total number of human performance significance relative to the total human errors identified, and compares errors has declined since the beginning of the the percentage to the unit goal. Human errors are identified through year, the character of those errors is more Condition Report evaluation, and the errors are categorized by significance level.

significant. Five Condition Reports in early April rompted a management assessment of the The most significant errors are called " breakthrough events", and are performance weakness and lessons learned.

l i

l characterized by a breakdown of all barriers. Breakthrough events result l

in consequential events such as plant transients, major equipment CR M3-98-2774 has been initiated to perform a damage, operation outside of the design bases, etc. "Near miss' events Common Cause Analysis to verify if an adverse involve the breakdown in multiple barriers, but have little consequence.

trend exists and provide the Unit Leadership As such, they represent a lower significance level. " Precursors

  • involve Team with recommendations for improving the breakdown of few barriers, are caught earlier in the event chain, and erformance.

generally result in no significant consequences. Precursor events represent the lowest significance level.

It is destable to have a higher percentage of low significance human errors (precursor events) to total errors to allow for the implementation

)

of corrective actions at a lower threshold, thereby prevenbng more significant errors.

Gael Comments gj The goal is for the percentage of low significance errors (precursor events) to be > 95% of the total human errors l

identified.

AITTSl Analysis By:

W Rein x3707MPl Owner:l G Winters x5401MP Data Source:

i A4

On Lina Werk Ordsr Stctua Millstone 3 - July 1998 pd Progress:

Progress is satisfactory. The goals have been achieved.

1400 1200 -

1000-l l

_ E3 g d

4 600 -

Goal (Total)r 500 ga ram

=

=

,4 g

B G

E E

E 400 -

f 200 -

Goal (PRA)s 350 0

'^

h h

h fk h

k h

h h

4 5

8 5

E h

1 M

5 5

l MPRA Risk Significant AWOs EE30ther AWOs -m-Work Off/G0al(Total AWOs) -m-W0rk Off/ Goal (PRA AWOs) l RawDets --

4/8/98 4/1548 4"2248 4f29S8 5698 5/1348 5/2048 5/27S8 6/348 6/1048 6/1798 6/2448 7/1/98 Non-PRA Risk Sigruficant AWOs 318 317 322 279 248 244 244 238 210 212 212 210 240 I

PRA Risk Significant AWOs 416 416 423 358 314 306 289 293 241 237 229 236 251 Work oft / Goal (PRA AWOs) 395 386 377 368 359 350 350 350 350 350 350 350 350 Total AWO Backlog 734 733 745 637 562 550 533 531 451 449 441 446 491 Workoft/ Goal (Total AWOs) 614 591 568 546 523 500 500 500 500 500 500 500 500 DeRnition AnalystalAc60n This indicator depicts the number of on line Corrective Maintenance The goals have been been achieved.

(CM) Automated Work Orders (AWOs), and the portien of those associated with Probabilistic Risk Assessment (PRA) risk significant syst ms.

PRA Risk Significant systems are systems required to protect the raictor core or mitigate the consequences of an accident.

Work awaiting post maintenance testing or closure is not included in this KPl. Also excluded aa AWOs for support work, such as insulation removal, outage Work, and Preventative Maintenance or SurvIll'anco AWOs, as well as AWOs not associated With power block equipment. Power Ascension AWOs are not included and are tricked by a separate KPl.

i i

Oce*

Commente Th2 goal is to have s 500 Total On-Line Corrective Maintenance KPI data is current through July 1,1998 Os. Of thess 500, no more than 350 Will be PRA risk significant Os.

I Dets Source:

P. O Johnson x5519MP! Analysis by:

J Legerx2391MP! Owner:

C. Schwarz x0491MP A5

Tcmpercry Mcdificcti:ns Millstone 3 - June 1998 1

OOgreSS:

Performance is tracking to satisfactory. We willbe one (1) above our goal of g 15 temp mods for a shortperiod.

30 25 20 15

=

=

5

+

s 9

0 s

s 8

i s

s s

e a

{

ClllI:3 Temp. Mode. < 1 Cycle m e'emp Mode. > 1 Cycle QOutage Support

-s-Total Work Oft / Goal Raw Deen 4/15/98 4/22/98 4/29/98 6AS/98 6/1M8 500/98 6/27/98 6/198 6/10/98 6/17/98 6/24/98 7/1/98 Temp. Mode. < 1 Cycle 10 10 10 10 10 10 11 11 11 11 11 12 Outage Support 3

4 4

4 4

3 2

0 0

0 0

0 Temp. Mode. > 1 Cycle 5

5 5

5 5

5 4

4 4

4 4

4 l

Total Installed 18 19 19 19 19 18 17 15 16 15 15 16 l

Total work Off/ Goal 17 17 17 15 15 15 15 15 15 15 15 15 DeRnielen Analynia/ Action

indicator depicts the total number of Temporary Modifications to We are above our goal of s 15 temp mods.

l unent plant design, the portion that are " Outage Support" (directly d to physical work to plant equipment in an outage condition), and the Of these sixteen (16) temporary modifications nine (9) are in various l

portion that have been in place longer than one cycle, that is before stages of design to make them permanent, two (2) will be in until RFO6, 4/14/95 (mode 3 prior to RFO5).

and four (4) are waiting for parts.

Temp Mod 3-98-033 was just installed to rnonitor feed pump vibration i

A temporary modification is a modification to the plant that is short-term and is expected to be installed for a short duration.

in nature and not part of the permanent plant design change process.

j Goal Commente The goalis to have s 15 Temporary Modifications installed.

Data Source _

J Cunnmoham x4372l Anetysis by:

S Stncker 5409l owner:

G Seder x5381Mp 1

l l

1m I

I V

A-6 E-______.__________.________

l l

Control Room and Annunciator Doficionciac Millstone 3 - June 1998

,rh (O) Progress:

Performance is satisfactory. The goal of Control Room and Annunciator Deficiencies < 10 is met, with one approved deficiency greater than six

\\

months old.

1 30 l

25

(

U 20 f

Good 15 h

Goal (Total): <10 Y

l 15 a'

w I

m u

g g

j}

{

'q g

5 4

0 s

a g

a a gg s

s s

g s

a a

a a

s s

a i

s R

R s

i 0

s siiS i

i s

% Def. > 6 Mos. Old Def. < 6 Mos. Old Goal (Total) l l

RawDets 4/1298 4/1998 4/26S8 5/3/98 5/1048 5/17S8 5/24 S8 5/3148 6/748 6/1498 6/2148 6/28 S8 Def. 3 6 Mos. Old 0

2 1

1 0

0 0

1 0

0 0

1 Def. 4 6 Mos. Old 7

11 10 8

7 7

6 6

2 2

3 4

Total Deficiencies 7

13 11 9

7 7

6 7

2 2

3 5

Goal (Total) 10 10 10 10 10 10 10 10 in 10 10 10 I

l Definition Analysis / Action This indicator depicts the number of Control Room and The database of Control Panel Deficiencies (CRP)

Annunciator deficiencies that exist, relative to Unit 3 goais for deficiencies was reviewed with a more conservative both number and age.

view being taken toward classification of items as deficiencies, which accounted for the large increase in Control room and annunciator deficiencies are control room late March.

instruments, recorders, indicators, and annunciators that I

function improperly and could challenge the ability of The goal of Control Room and Annunciator Deficiencies operators to monitor and control plant conditions.

< 10 is met, with one approved deficiency greater than six months old.

l i

l Goals Comments 9

The goal is to have fewer than ten control room and Repairs that are complete, but await documentation annunciator deficiencies prior to entry to Mode 2. No closeout or retest under specific plant conditions are not deficiencies shall be more than six months old, without unit included in the total.

officer approval.

Data Source:

L. Palone x4737MP l Analysis by:

M A King x5537l owner:

J R Beckman x5361MP A.7 j

Opcrater Work Arounds Millstone 3 - June 1998 O

Ogress; Pro ~ress is satisfactory. There are three Operator Work Arounds awalting Post MaInte.,ance Testing. New criteria Work Arounds are shown in addition to the goal.

l 25 20 m

j15

\\

I Good l

10 m

o.

E l

l e

a m

S Y

0 l$=b b

b b

b k

s s

s 8

s s

s s

S a

a s

s s

s W/A > 6 Mos. Old W/A < 6 Mos. Old i iNew Criteria W/A Goal i Raw Data 4/12/98 4/19/98 4/26/98 5/3/98 5/10/98 5/17/98 5/24/98 5/31/98 6/7/98 6/14/98 pS8 6/28/98 IOperatorWork Arounds 10 10 10 10 10 9

9 9

9 9

15 15

> 6 Mos. Old 9

9 9

9 9

8 8

8 8

8 8

8 W!/A < 6 Mos Old 1

1 1

1 1

1 1

1 1

1 1

1 New Criteria W/A 6

6 Goal 10 10 10 10 10 10 10 10 10 10 10 10 Definition Analysis! Action Opsrator Work Arounds (W/A) are conditions which require an The work on Operator work-arounds is on track.

operator to work with equipment in a manner other than original Operations' KPI goal for work-arounds is to be at ten or d: sign intended, less at startup. Of the original population (required for restart), there are currently 9 outstanding and three are Operator Work Arounds have potential to:

awaiting retest. The work-off rate supports startup efforts.

  • Impact safe operation during a plant transient
  • impose significant burdens during normal operation The procedure in effect in April of 1996 froze the work-
  • Crea nuisance conditions due to recurring equipment around population. The initial goal was set at "less than d ficiencies 10' for the original population. This goal will be met for
  • Distract operators from noticing recurring conditions.

that original frozen population. However, it should be noted that beginning in 1998, a new procedur6 was put in it is desirable to have a small number of operator work arounds, place to control work-arounds and additional items began and to limit the time such work arounds persist.

to be processed as necessary to support operations.

These additional work-arounds are now shown on the This indicator depicts the number of operator work arounds that graph and not counted towards achievement of the goal.

exist, relative to Unit 3 goals for both number and age.

roel Comments

'he goal is to have no more than ten Operator Work Arounds prior Repairs that are complete, but awaiting retest under l

l:ntry to Mode 2. No deficiency shall be more than six months specific plant conditions are not included in the total.

v d without Unit Officer approval. This does not include the "new" Work Arounds.

Data Source:

L. Palone x4737MP l Analysis by:

K. Kirkman x5090l Owner:

J. R. Beckrnan x5361MP A8

Condition Roport Evaluation Quality Score l

Millstono 3 - July I

rogreSS:

Performance is satisfactory.

I 4 00 3 50 oal2 3.0 3 00 2 500 e

2.00 1.50 l

Good 0.50 0.00 5

s s

5 s

s 8

s s

s a

M Average Quality Score Goal l

RawOsta 4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 Average Quality Score 3.60 3.14 2.50 2.89 3.33 3.40 3.64 3.20 3.67 3.00 3.40 3.82 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 Total Reviewed 5

7 4

9 9

10 11 10 6

6 10 11 Accepted 4

4 1

4 6

7 9

6 5

3 7

10 Accepted with Comrnent 1

3 3

5 3

3 2

4 1

3 3

1 Rejected 0

0 0

0 0

0 0

0 0

0 0

0 Rejection Rate 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Definition Analysis / Action This indicator reflects the quality of condition report (CR)

Average Quality Scores are consistently above the evaluations presented to the Management Review Team (MRT).

minimum acceptable score of 2.0, with most scores Each evaluation is reviewed for the adequacy of the proposed plan above the desired 3.0 quality rating.

to address the issues identified by the CR. Point values are l

assigned to each evaluation as follows:

The MRT is continuing to provide constructive feedback Accepted - 4 points to the line departments on areas where evaluations need Accepted with Comments 2 points improvement.

Rejected - O points l

l A weighted average Quality Score is then calculated:

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

Total # Evals Reviewed Where:

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

Goal Comments q

The goal is to achieve an average quality score a 3.0 on a scale of 0 4.0.

Supports SCWE Success Criterlon #2 D:ta Source:

AITTSl Analysis by:

W. Rein x3707MPl Owner:

G winters x5491MP A-9

Lcadorchip Assessmant (SCWE Elamont)

Millstone - June 1998

'1 (O Progress:

Progress is satisfactory. The June 1998 Leadership Assessment results indicate that the goal continues to be met.

100.0 %

q 90.0% -

Goal 90%

2 80.0%.

f 70.0% -

$ 60.0% -

b 50.0%-

en a

j 40.0% -

A 5

I 30.0% -

20.0% -

10.0% -

0.0%

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

% Employees Willing to Raise issues to Mgnt.

Leadership Goal i Raw Data Jul 97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98

% Employees Wilhng to Raise issues to Mgnt.

97.9 %

98.7 %

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 %

O 1

Definition '

AnalysisfAction 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 l

employee concerns.

Assessment is under evaluation.

This indicator is considered a valuable data point in I

evaluating the confidence and willingness of Millstone employees to raise issues to 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.

l l

Goal Comments The Goal is a 90% of the employees surveyed to report a Data is current through June 1998.

willingness willing to raise concems to their supervision.

O()

Supports SCWE Success Criterion #1 Data Source:

Leadership Assessrnentl Analysis oy:

M. Gentry x5728MPl Owner:

M. Gentry x5728MP B1 t

Culturo Survay (SCWE Ebmant) 1 Millstone - June 1998 1(m Progress:

Performance is considered satisfactory. Other short-term Indicators, L

Including ECOP survey results provide additional evidence of 1

performance quality.

100.0 %

90 0% -

l Goal 90%

2 80.0%.

< 70 0% -

f 60.0% -

50 0% -

g 40 0% -

l 2 30.0% -

Good 20.0% -

10.0% -

0.0%

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

!M% Employees Agree That SCWE Exists Culture Goal i Raw 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

% Ernployees Agree

['

That SCWE Exists 82 0%

86 6%

i 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%

Definition AnalysisfAction This indicator depicts the percentage of employees The June 1998 Culture Survey results fall short of the surveyed, by means of the Pil 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 1998 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 concems 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 used 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 to be determined.

Safety Conscious Work Environment.

When Culture Survey data is considered in conjunction with other indicators, including more recently administered Employee Concems Oversight Panel l

(ECOP) surveys, progress in this area is satisfactory.

t Goal Comments The goal is for > 90% of the employees surveyed to report Data is current through June 1998.

(qJ a willingness to raise concems to their supervision.

v Supports SCWE Success Criterion #1 Data Source:

Culture Survey l Analys/s by:

M Gentry x5728MPl Owner:

M. Gentry x5728MP B-2

f t

Sofoty Conaciouc Work Environment Empl3yees Willingn:33 to Ral:3 C:nc:rns NU Concerns and NRC Allegations Received, Millstone Station I(N l\\*) Progress: Performance is satisfactory. The number of allegations to the NRC remains at a Iow level while the number of concerns received by ECP is high.

l i

40 35 l

Data current 30 through 7/1/98.

25 5 20 i

e d

j 1

s 15 i

10 i

A q

l

{

S i 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 l

-e-NU Rec'd NRC Rec'd l

Row Onte 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 27 20 23 20 17 18 NRC Received 4

6 4

4 2

6 NU Rec'd YTD 27 47 70 90 107 125

,9 NRC Rec'd YTD 4

10 14 18 20 25 DeHnition AnalvelalAction This indicator depicts the number of concerns received each The increasing number of concerns submitted to the ECP month by the Millstone Employee Concerns Program (ECP) suggests growing employee confidence in the ability of i

relative to the number of allegations associated with Millstone the Millstone ECP to provide an effective means by which

?

issues or problems which have been submitted to the NRC concerns can be resolved. The average number of during the same time period.

concerns received per month from June through j

November 1997, was 14. The average number for

{

The Millstone Employee Concems Program (ECP) accepts December 1997 through May 1998 was 24, a 60%

concerns related to a wide variety of issues, including nuclear increase over the 1997 norm.

safety or quality, management, industrial safety, security and The total number received from Millstone employees was other topics. Concerns may be submitted by current or former 17 for June. One NRC referral was received on June 19, employees and contractors. NRC allegations regarding 1998. No new concerns were received for the month of Millstone issues may be submitted by the general public, July as of 7/1/98. Five allegations regarding Millstone for current or former employees and contractors or members of the the month of June were received by the NRC.

NRC. Concems may also be filed concurrently with the Data on concerns received by the NRC are reported twice Millstone ECP and the NRC in the same time period.

per month (mid and end).

~-b

.pogg :

Comments

NU has not established a specific goal with respect to concerns Data current through 7/1/98.

l r:ceived. However, it is desirable to have a small number of allegations submitted to the NRC and a larger number submitted to the ECP as a measure of employee confidence in NU resolution systems.

Supports SCWE Success Criterlon #1 Data Source:

C. Mhalko x4541MP l Analysis by:

C Mihalko x4541MPl Owner:

E. Morgan x4335MP B-3

Millstena Employca Concarna Confid nticlity Trcnd Millstcn3 St ti:n - July 1998

/

\\

\\

YOgreSS:

The willingness of employees to raise concems is satisfactory. Less than 35% of Concemed Individuals requested confidentiality or are anonymous for 1998.

40 35 Data current through 7/1/98.

30 1 25 1

20 4

)15 10 mN 3

s

/

5 N

O 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 u Anonymous and Confidentiality Requested l ggi m

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Received by Month 27 20 23 20 17 18 Anonymous 7

3 6

7 2

6 Confidentiality Requested 3

6 0

2 1

3 Confidentiality Waived 15 12 16 11 14 10

  • /. Anon. and Confidentiality Req 37.0*4 40.0 %

26.1 %

45.0%

17.6%

44 4 %

Defkdion Anaksin/ Action This indicator depicts the number of concerns which are reported to Less than 35 percent of concerns have been filed the Millstone ECP anonymously, and those for which confidentiality anonymously or requesting confidentiality since the is requested, relative to the total number of concerns received.

beginning of 1998. Based on the June 1998 numbers, the percent trend appears to be flat with the exception of Each individual submitting a concern may request or waive the March and May numbers. Our analysis of the confidentiality. Anonymous concerns are also submitted.

concerns data did not reveal any specific reason why this pattern occurred. ECP monitors this closely for any Concerns requesting confidentiality or anonymity are reviewed to adverse trend.

d termine (1) if there is a significant change in either the number or percentage of concerns filed anonymously or requesting Eight of the eighteen concerns received as of the end of l

confidentiality, (2) if any categories show discernible changes in June were either anonymous or requested confidentiality.

I make-up or source of the concerns, and (3) if any new " focus areas" No new concerns were received for the month of July as are identified.

of 7/1/98. The proportion waiving confidentiality (55.6%)

is consistent with the nine month ECP average of 61%.

a. gogl2 m

Tha goal is to show no adverse trends in requests for confidentiakty Data current through 7/1/98.

or anonymity, based upon an analysis of the concerns and data.

The confidentiality status of two concerns received in January could not be determined since the employees

{

}

have left the site. The confidentiality status of one Supports SCWE Success Criterion #y concern received in March remains unknown.

l Analysis by:

C. Mihalko x4541MP l Owner:

E. Morgan x4335MP Defa Source:

C Mihalko x4541MP l

I B-4 L_________________________._

Employco Concerns Resolution Timeliness 1

Millstone Station - July 1998 togress:

Progress Is satisfactory. The improved timeliness of employee concems resolution achieved during the past year Is being sustained.

90 80-70<

60-g

<i!lllllllll t:

,,,,s I,,,

a,,

s sa sss**sll2 s

a s ss a

lE Average Age l ReevDets >

4/15/98 4/22/98 4/29/98 5/6/98 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 7/8/98 trage Age 65 61 67 49 47 45 52 44 43 39 47 23 Jpen < 45 Days 22 16 21 18 23 24 17 15 17 24 19 15 Open > 45 Days 20 25 19 15 14 18 20 7

9 10 12 3

Concerna Under Investigation 42 41 40 33 37 42 37 22 26 34 31 18 DeRnMon 8

?

AnalysisfAction This indicator depicts the average age of concems under The average age of concems under investigation decreased investigation. Concems under investigation represent significantly from 6/24/98. This is due to older concems being Employee Concerns Program (ECP) work in progress, closed. The average age of concems is trending downward in including data gathering and analysis.

1998; however, ECP will continue to monitor this parameter.

Comments:

Data current through 7/1/1998.

g!

The goal is for the average age of unresolved concerns to how no adverse trend.

Supports SCWE Success Criterion #3 0:t2 Sourcer C. Mihalko x4541 MPl Analysis by:

C. Mihalko x4541 MPl Owner:

E. Morgan x4335MP B-5

Employca Satisfaction with ECP Millstena Station - Juns 1998 (m'tProgreSS:

Progress is satisfactory. A majority of employees surveyed who have G

used the ECP expressed a willingness to use the ECP again.

l 100 % -

90% -

g f)

S 80% -

Data is current through 3/31/98.

3 70% -

3 s

T 60% -

l k

i llg 50% -

1 l

f 40% -

Good l 30% -

20% -

l w 10% -

r

(

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 l

l E LHC Survey Results E ECOP Survey Results 1 Raw Data Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 LHC Results: % of fmployees Who Would Use ECP Again 63%

50%

83%

i ECOP Results: % of Employees Who Would l

Use ECP Again 75%

90%

l l

Definition Analysis / Action l

This indicator depicts the percentage of employees who have The LHC data shows an improving trend in employee used the Employee Concerns Program (ECP) for concems satisfaction with the ECP, although sample size is r: solution and report a willingness to use the program again.

relatively small. The ECOP percentages confirm LHC This data is obtained by means of surveys and interviews data and represent the larger sample population.

conducted by Little Harbor Consultants (LHC) and the l

Employee Concems Oversight Panel (ECOP).

In late March ECOP completed a survey of l

employees who have used ECP. The vast majority

(>90%) indicated that they would use ECP again, l

l 1

i Goal Comments A substantial majority of employees who have used the Data is current through 3/31/98.

i ECP to indicate that they would use the program again.

l l

Supports SCWE Success Criterion #3

\\

D*ta Source:

LHC/ECOPl Analysis by:

M. Gentry x5728MP l Owner:

D. B. Arnerine XO437MP t

B-6

1 1

I l

Focua Arm Action Plan Stttua i

Millstone Station - July 1998 1

(mh Progress:

Progress is satisfactory. Resolution of all focus areas is proceeding as expected.

y/

25 j 20

.6

$15l II0

~

Good i

i u.

t

]5 y

0 s

v l

8 5

s s

s a

s s

G 4

~

lGOverdue Action Plans ROpen Focus Areas l Rsw Dois 4/23/98 4/30/98 5/7/98 5/14/98 5/21/98 5/28/98 6/4/98 6/11/98 6/18/98 6/25/98 7/2/98 7/9/98 Open Focus Areas 8

8 8

8 8

8 8

8 8

8 8

Overdue Action Plans 0

0 0

0 0

0 0

0 0

0 0

Focus Areas 33 33 33 33 33 33 33 33 33 33 33 Action Plans in Place 8

8 8

8 8

8 8

8 8

8 8

Action Plans Completed 25 25 25 25 25 25 25 25 25 25 25 Action Plans To Develop 0

0 0

0 0

0 0

0 0

0 0

DeRnition Analy8is/ Action This indicator depicts the number of focus areas currently identified and All open Focus Areas have action plans in place.

the status of action plans to correct identified weaknesses. A Focus Area is defined as an area of personnel interaction where a Safety Several focus areas have been closed out and Conscious Work Environment is challenged or does not exist, assessment of others is still required before final close out.

l The following indications are used to identify the Focus Areas within the

)

Millstone organization:

Within the next few weeks this indicator will change to a Leadership Assessment score less than 4.0 (" Effective") in either the be more responsive of SCWE status.

Employee Concems area or the Overall score.

I

  • 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 ascond indicator.
  • Employee Concems Program - Significant or multiple occurrences 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.
  • NRC loentified areas based on investigation.

Gont Comments e

The goalis to have the number of focus areas steady or declining at r: start with no overdue action plans.

Supports SCWE Success Criterion #4 Data flource:

A. Elms x5388MPl Analysis by:

A. Elms x5388MPl owner:

D. B Amerine XO437MP B-7

Subatcntictod Cencarno invelving Pat ntial Violations of 10CFR50.7 Millstone Station - July 1998

(

lrOgreSS:

Performance is satisfactory. There were no substantiated concerns involving v

aIIeged violations of 10CFR50.7 since August 1997.

I 40 l

l Data current 30 through 7/1/98.

l I

l j25 d 20 3

Good 15

)

10 N

5-0 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l M # Substantiated Potential 10CFR50.7 Concerns Total Concerns Received

-*-# Alleged 10CFR50.7 HIRD Concerns gg

q

+

?

Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Total Concerns Recolved 27 20 23 20 17 18

  1. Alleged 10CFR50.7 HIRO Concerns 10 7

4 3

2 4

  1. substantiated Potential 10CFR50.7 Concerns 0

0 0

0 0

0 Total # of HIRD Concerns Received 16 11 11 10 4

7

% HIRO Concerns 59 %

55%

48%

50 %

24 %

39%

% Alleged 10CFR50.7 HIRD Concerns 37%

35%

17%

15%

12%

22%

5 w,_,, ~.

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 H RD Intimidation, Retaliation or Discrimination (HIRD), including those based issues, importantly, from December 1,1996 through on race, sex, and national origin. It depicts the number of potential and June 10,1998, only three concerns have been substantiated HIRD concems involving alleged 10CFR50.7 violations substantiated as involving a potential violation of r lative to the total number of concems received.

10CFR50.7, and all three are related to a single event (MOVs). Four alleged 10CFR50.7 concerns were 10CFR50.7 is a federal law which provides for the protection of received in June 1998 and are currently under individuals engaged in protected activities. An example of a protected investigation.

actrvity is when an individual identifies an issue that he/she believes impacts any aspect of activities at the Millstone Site that are regulated Open 10CFR50.7 concerns receive the highest by the NRC, and communicates that concern to co-workers, investigative priority. Site management continues to supervisors, the Employee Concems Program (ECP), the NRC, educate, address and when appropriate, discipline Congress, or the media.

any personnel involved in such activities.

l l

L:" '

Comane he goal is that substantiated concerns involving potential violations of Data current through 7/1/98.

OCFR50.7 are infrequent and haridled responsibly.

Supports SCWE Success Criterion #4 Data Source:

C. Mihalko x4541 MP l Analysis by:

C. Mihaiko x4541 MPl Owner:

E. Morgan x4335MP 8,8

Statua of Ovcrcight Condition Rcporto i

Millstono 3 - Juns 1998 l

(A)

Progress:

Progress is not meeting management expectations. oversight management will continue to monitorperformance.

50 40 Data thru 30 Good

\\

20 0

t i

I l

l l

l l

1 l

I Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 98 97 97 97 97 97 98 98 98 98 98 98 O Level 1 CRs >30 days old without approved CA Plan E Level 2 CRs >30 days old without approved CA Plan RawData Jub97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97 Jan-98 Feb-98 Mar 98 Apr-98 May-98 Jun-98 Open 67 31 28 31 38 45 31 33 19 45 42 50

[^s Total 1 &2 >30 days 1

6 3

2 6

25 9

6 3

17 7

15

(

I Level 1/>30 days 2/1 4/2 2/1 1/0 2/1 5/1 5/4 4/2 2/1 4/2 4/3 12/5 Level 2/>30 days 65/0 27/4 25/2 30/2 36/5 40/24 26/5 29/4 17/2 41/15 33/4 38/10 Definition Analysis / Action This graph displays the status of open Condition Reports Oversight will continue to monitor performance in (CRS) initiated by Nuclear Oversight for adverse, discrepant, completing Condition Report evaluations on time.

or other conditions needing improvement.

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

Goal Comments No Level 1 or 2 CRs open > 30 days without approved l

extensions.

M. Baldini x4456l Analysis by:

J Beauchamp X2113l Owner:

I Q Data Source:

J Streeterx43co C-1

Nuclear Oversight Restart Verification Plan Key issues Status - Millstone 3 greSS:

AII areas are considered satisfactory (green) with the exception of Engineering, Conduct of Operations and Mode Changes.

l 2/6/98 l 2/20/98 l 3/6/98 l 3/20/98 l 4/3/98 l 4/17/98 l 5/1/98 l 5/15/98 l 5/29/9 KEYISSUES Le:darsh SelfAssessment Y-

.Y Y

Corrcctive Action NSAB/Ove ht R Co ration Man ment Proc: dural Qualit dherence Y

Y Work Control /Planni Y

Y Y.

Y Y

Y Y

to Co Ilance SCWE Y-Y Y

Y Y

Emsr_qency Pre Y

Radiation Prciection S:curity Envin;;nmentalMonito Traini Y

Y Y

Y Y

Y' Y

^ ducto tions Y

Y Y

RSIGHTASSESSMENTAREAS Maint nancell&C C

Fire Protection Y'

Y Mat: rials Y

Y Y

Y Y

Y Y

Y Engineering Y

Y Y

Y Y

Y

'Y Y

Y Mods Chances *

(Mode 2 assessment began 5/1)

Y Y

Y Y

Each of the above listed issues are assessed based on a set of attributes derived from NU, INPO and NRC documents which provida standards, objectives and inspection guidance. In general, the color corresponds to following scores. Colors will normally change after two periods of consistent performance. NOTE: Nuclear Oversight management may determine that a diffsrsnt color is more appropriate based on its best judgment.

Satisfactory (GREEN)70-100 I

-I improvement needed (YELLOW) 20-69

  • All Mode 2 issues must be resolved to be rated

" Green" Significant weakness (RED) 019 An issue which has not been assessed (BLUE)

W s-~..

9-,..

C-2

Proccdura Complicnca Millstone 3 - July 1998 m()j Progress:

Progress is satisfactory.

/

1.00 l

0 80 '

KPl data current 1 080-through the end of

  • 0 70 June 1998 o

2" 0.60 -

Goal < 0.5 g 0.50 -

20'4 '

Good l

l 0.30 -

l d 0.20 -

0.10 -

0.00 E

3 3

8 8

8 8

8 8

8 8

8 8

8 8

8 5

k k

4 4

I I

8

% Total Non Compliance Errors /1000 hrs Goal l Raw Data Oct-97 Nav-97 Dec 97 Jan-98 Feb-98 Mar-98 Apr.98 May-98 Jun-98 Total Non Compliance Errors /1000 hre 0.47 0.37 0.75 0.48 0.32 0.25 0.40 0.29 0.37 i

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 0.13 0 09 0.20 0.11 0.06 0.05 0.05 0.03 0.05 Admin Procedure Non-Compliance Errors /1000 hrs 0.34 0.28 0.55 0.37 0.26 0.20 0.35 c.27 0.32 HOURS WORKED (1000 HRS) 105.56 127.21 94.50 154.54 164.55 165.59 155.66 150.03 134.61 Technical Procedure Non-Compliance 14 12 19 17 10 8

8 4

7 Administrative Procedure Non Compliance Errors 36 35 52 57 43 33 55 40 43 Total Non Compliance issues 50 47 71 74 53 41 63 44 50 Definition AnalysisfAction 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 has resulted in a lowering of the threshold categories; non-compliance with technical procedure-these errors fpr reporting administrative procedure are associated with operational or maintenance procedures or work noncompliance. However, the Unit orders and are generally continuous or generallevel of use procedures; continues to meet the goal of < 0.5.

{

non-compliance with administrative procedure-these errors are

{

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.

1 l

Gast Comments The goal is for procedure compliance errors (CRs) to be < 0.5 errors per thousand man hours.

j j

V l Analysis Sy:

Data Source:

AITTS B Rein x3707 MP owner:

G. Winters x5491MP D1

CR0 involving D3ficiant Tcchnicci Prccadurm Millstone 3 - July 1998 (o' Progress: Progress is satisfactory. A favorable performance trend which began after the Q,/

System Specific Assessment reviews, continued through the first half of 1998.

45 40 Data currerlt through July 23,1998 33

, 30 monthly g

trending g 25 5 20 GOOD 1 15

?

f 10 Goal < 5/ month bb_

bbl 0

U 0

0 02 03 04 Q1 O2 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun

'96

'96

'96

'97

'97 97 97 97 97 97 97 98 98 98 98 98 98 i M Upgraded IIZ:I:3Non Upgraded Goal i Raw Data Unit 3 Jul 97 Aug 97 Sep 97 Oct 97 Nov 97 Dec 97 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 upgrided 10 7

3 0

0 0

1 0

0 0

0 0

'en Upgraded 2

2 1

0 0

0 0

0 0

0 0

0 efinition AnalvelsfAction This indicator depicts the number of condition reports (CRs)

Following a peak in second quarter 1997 which gInerated as a result of procedure deficiencies. A review to resulted from SSA discovery efforts, the total number d:termine 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 10 procedures from the following departments: Operations, months, and remaining at zero for 8 of the last 9 Maintenance, instrument and Control, Engineering, and unit specific months.

Ch:mistry and Health Physics procedures.

The procedure upgrade effort for Unit 3 has been CRs involving administrative procedures and failed administrative completed.

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.

Goal The goal is to have no more than 5 CRs per month initiated as a result of procedure deficiencies.

Comments Data current through July 23,1998 i

Unit 3 Upgraded Procedures = 1244 Unit 3 Non-Upgraded Procedures = 0 Total No. of Unit 3 Level 1 CRs = 2 hotal No. of Unit 3 Level 2 CRs = 76 T

otal 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 D'ta Source:

AITTSl Analysis by: R Bireley/T. Kutterrnan x5421MPl Owner:

T. Kirkpatrick x6204MP l

D-2 l

1 Madian Aga 6f Loval1 & 2 Condition Rcports Millstone 3 - July 1998 j

f Progress:

Performance is not meeting the stated goal and additional management

's action is being taken.

l l

325 300 275 250 v

22s 200

=

=

=

=--

g

  • 175 k150 GOOD 125 100 75 f

50 25 0

E h

h 6

4 5

5 5

8 S

N I-+-Level 1 CR Median Age -G-Level 2 CR Median Age j RawDets 5/13/98 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 7/1/98 7/8/98 7/15/98 7/22/98 7/29/98 Level 1 CR Median Age 245 245 245 261 251 242 237 243 249 250 245 0

Level 2 CR Median Age 190 100 190 198 202 201 200 202 213 213 222 0

Ext. Ider.t. Lvf 1 Med Age 155 155 155 176 176 190 197 204 211 218 225 0

(

Est ident Lvl2 Med Age 147 146 146 125 125 139 146 153 160 167 174 0

Int. Ident. Lvl 1 Med. Age 194 194 194 215 215 204 211 218

_225 212 219 0

Int. ident Lvl 2 Med. Age 208 208 208 200 202 211 217 223 230 237 244 0

Total Open CRs 3009 3068 3109 3146 3220 3275 3372 3432 3404 3403 3392 0

Open Level 1 CRs 231 233 236 238 240 246 253 249 250 254 258 0

Open Level 2 CRs 2778 2835 2873 2908 2980 3029 3119 3183 3154 3149 3134 0

CRs Open >120 Days 1017 1037 1060 1080 1136 1184 1267 1267 1269 1276 1295 0

Open level 1 >120 Days 114 118 119 121 124 132 142 138 139 140 147 0

Open Level 2 >120 Days 903 919 941 959 1012 1052 1125 1129 1130 1136 1148 0

Deninition.

AnalyslalAction This indicator depicts the median age of open Level 1 and 2 Current performance is not meeting the stated goal.

Condition Reports (CRs).

The median age of open Level 1 CRs has remained relatively flat and the median age of open Level 2 CRs l

is slowly increasing. Management will analyze the I

reason (s) for this adverse trend and take appropriate actions to correct those deficiencies.

1 I

l Goel Comments p

The goalis to have the median age of Level 1 & 2 CR's decline j

[

over time.

j N

I 1

AITTSl Analysis byt B. Ren x3707MPl Owner:

Data Source:

G Wnters x5491MP E1

Exocutivo Training Council Msting Millstone - June 1998

\\ilgteSS:

The Executive Training CouncII meeting frequencyis satisfactory.

6 ETC Meeting data through I

s 6/30/98 l

1 Better 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 l M Executive Training Council Meetings

" Goal Raw Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Executive Training 1cil Meetrigs 2

1 4

4 Gal 1

1 1

1 Definition Analysis /Acklon i

This indicator depicts the Executive Training Council (ETC)

No action required. ETC meeting frequency exceeds the l

meeting frequency. The function of the ETC is to:

established goal.

l Communicate management's commitment to safety, high standards, and the effective use of training to help improve i

workar performance, Provide management oversight of the Millstone training i

programs accredited by the National Academy for Nuclear Training, thereby demonstrating proper stewardship of the l

rcsources our company has provided.

j Communicate management's commitment to high quality, arformance-based training utilizing a systematic approach to j

l p

l training, thereby directly contributing to nuclear safety while supporting the proper emphasis on improved achievement of agreed upon schedules.

I Establish and monitor site training goals and performance I

indicators, thereby communicating the high standard necessary for sala, effective operations.

Review major changes to common site training programs.

Comments goalis 1 ETC meeting per quarter.

ETC Meeting data through 6/30/98 ETC was established in April 1997 Data Source: ETC Meeting Minutes l Analysis by:

J. Althouse x2916MPl Owner:

J. Cantrell x2600MP F-1 u____

Training Advisory Committso Meeting Millstone - June 1998 c gress:

Training Advisory Committee meeting frequency is satisfactory.

14 13 12 TAC Meeting data through 11 6/30/98 10 gg9 g

8-7-

Goal 2 3 Meetings per Otr.

og e-g 5

o 4

Better 3

==

= - - - - - - -

2 1

0 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 l

MTraining Advisory Commatee Meetings

" Goal f

R*w Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Training Advisory Committee

' ' *ggs 11 14 6

4

/

GoJ 3

3 3

3

's Definition AnalysisfAction This indicator depicts the Training Advisory Committee (TAC)

No action required. Unit TAC meeting frequency is tracking to meeting frequency. The function of the TACs is to provide meet the goal.

senior management oversight of Nuclear Training policies and programs and ensure the implementation of the SAT process.

Each Unit has had at least one meeting each quarter.

TACs assess training accomplishments relative to Unit goals, maintain the future focus on changing training needs and Unit 3 has had four TAC meetings cancelled during the months of industry requirements, and set the strategic direction for training May and June due to start-up priorities.

programs at the Unit level.

l 7 001 Comments The goal is 3 TAC meetings per quarter, which is equivalent to 1 TAC Meeting data through 6/30/98

,IAC meeting per Unit per quarter.

I\\

Dats Source: TAC Meeting Minutes l Analysis by:

J. Althouse x2916MPl Owner:

J. Cantrell x2600MP F-2 l

Curriculum Advisory Committee Mseting Millstone - June 1998 O}rOgreSS:

Curriculum Advisory Committee meeting frequency is not meeting estabilshed management goals.

160 1

Goal 2 55 CAC Meeting data f

140 120 Meetings per Otr.

through 6/21/98 l

100 1

80 -

g A

?. $

40 Better 20 0

3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 MCurriculum Advisory Commitee Meetings

" Goal R:wDats l

3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 Curriculum Advisory Committee Meetings 126 143 106 32 Goal 55 55 55 55 Definition Analysis / Action This indicator depicts the Curriculum Advisory Committee (CAC)

The 2nd quarter performance is not on track to meet meeting frequency. The function of the CACs is to establish the established goal of 55 CAC meetings per quarter, effective training qualNtion prograrns and ensure the appropriate design, development, and implementation of SAT-Not all CACs have fulfilled their requirement to meet based training programs. CACs review, recommend, and approve each quarter. Training Advisory Committees (TACs) various actions related to new and existing training programs, have been informed of this adverse trend. TACs have re-inforced the meeting frequency requirement with Station Procedure TO-1, Personnel Qualification and Training station management.

attachment 13, establishes the conduct of CAC meetings. CACs l

are required to meet at least quarterly. CACs are chaired by a l

member of station management.

Goal Comments The goalis 55 CAC meetings per quarter which is equivalent to 1 CAC Meeting data through 6/21/98 C smeeting per CAC per quarter.

1 l

D:ta Source:

CAC Meeting Minutes l Analysis by:

J Althouse x2916MPl Owner:

J. Cantrell x2600MP F-3

Simulator Availability Millstone-June 1998 gresS:

Simulator availability is satisfactory.

Simulator Availability data through 6/30/98 1000*'

Goal > 99%

4 98 Be er

~' ' ! '

98.0% -

3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 M Availability MP1 Availabildy MP2 Availability MP3 Goal Raw Dets 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 i

Availability MP1 100 00 %

99.37 %

99 70 %

99 70 %

Availability MP2 99 43%

99 77 %

99 60 %

99.90 %

"vailabildy MP3 99 88 %

99 94 %

100 00%

99.40 %

l Goal 99 00 %

99 00 %

99.00 %

99.00 %

l Definition Analysis / Action i

This indicator depicts the simulator availability for all three No action required. Simulator availability for Units 1,2 & 3 is Millstone Units.

above goal.

i l

l l

Gon!

Cominents The goal is to rnaintain greater than 99.00% availability for each Simulator Availability data through 6/30/98

't Simulator through Unit restart.

l I

Data Source:

J. Cataudella x2603MP l Analysis by:

J. Althouse x2916MPl Owner:

J. Cantrell x2600MP F4

Millstono Station Lead rship Asscssment June 1998 Progress:

AII categories are slightly down from the Winter 97 survey.

/mI Extraordinary 8.00 7.00 Very Effective 6.00 y

g 5.00 Effective r

4.00 v

i 1

l 3.00 Good j

Somewhat Effective y,gg Inettective 1.00 Communications Leadership Performance Development Employee Concerns

  • I EWinter-96 O Summer-97 O Winter-97 O Summer-98 l
  • category added in Summer 97 l

Raw Data Winter-96 Summer 97 Winter.97 Summer-98 Winter-98 Communications 4.77 5.61 5.75 5.72 Leadershp 4.95 5.77 5.88 5.84 Performance 4.42 5.29 5.34 5.31 D:velopment 4.64 5.45 5.54 5.53 Employee Concerns 6.11 6.19 6.15 Definition Definition (continued)

The Leadership Assessment is a management tool for evaluating The primary purpose of the Leadership Assessment is to the relative strengths and needs of individual management provide meaningful information 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 questions are posed to employees regarding leadership evaluated at an organizational level to trend improvement performance in four separate categories: Communications, in management performance.

Leadership, Performance Accountability, and Development; a fifth category for evaluating performance relative to Employee Concerns was added to the assessment in the Summer of 1997.

Analysis / Action R sponse 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).

l

?

Goal Conunents The organizational goal is to show improving trends in all categories.

Darm Source:

Leadership Assessment l Analysis by:

J Gorski x0462MPl Owner:

J Gorski x0462MP G -1 u______________._________..._._________

Millstons Station Cultural Survey Juno 1998

[9 agyegg:

Results from the June 1998 Culture Survey show a slight decrease in 7

the Adjusted Culture Index. Overall, the data Indicates a sustaining of the positive culturalImprovement observed over the last year.

25.00 20.00 15.00 Goal = 13.0 10.00 -

l Good 5.00 0.00 Jun-96 Oct-96 Jun-9~7 Nov-9'1 Jun-98 l

WAdjusted Culture Index wwcara Jun-96 Oct-96 Jun-97 Nov-97 Jun-98 djusted Culture Index 11.60 11.46 12.88 13.07 12.99 Jumber of Partic: pants 1026 1240 1487 1926 2066 Goal 13 13 13 13 13 Definition Analysis / Action NU originally contracted Performance Improvement Despite the slight decrease (< 1%) in the Adjusted International, Inc. (Pil), formerly FPl, 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 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 Watch List plants. A Cl of Lateral Integration, Simple Work Processes, and Strong greater than 14 indicates a strong probability 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 l

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 effor 's and monitoring is fully appropriate.

Goal Comments l

UU has established a goal to achieve an Adjusted Cultural index of 13.0.

D:ts Source:

Culture Survey Analysis by:

M. Gentry x5728MPl owner:

E. V. Fries x5458MP G-2

RCA Docimetry Daficiencios Chart Millstone - June 1998 OgYOSS:

Performance in this area is satisfactory.

50000 45000 KPl data is current as of June 4oooo 30,1998.

35000 Goal s 1 error per 25,000 July Aug.

Sept.

Oct.

Nov.

Dec.

Jan.

Feb.

Mar.

Apr.

May June

'97

'97

'97

'97

'97

'97

'98

'98

'98

'98

'98

'98 l M Cumulative RCA Entries per 1 Error Goal. < 1 Error per 25,000 Entnes l Raw Dets '

July '97 Aug. '97 Seot. '97 Oct. '97 Nov. '97 Dec. '97 Jan. '98 Feb. '98 Mar. '98 Apr. '98 May '98 June'98 Cumulative RCA Entries per i Error 22,419 25,282 24,431 26,893 29,024 32.263 34.463 36,312 36,528 35,201 36,377 37,487 Goat: < 1 Error per 25,000 Entries 20,000 20,000 20.000 20,000 20,000 20,000 20,000 20.000 20,000 20,000 20,000 25,000 Cumulative RCA Entnes 448.378 505.640 586.345 672.336 754.624 838.838 896.043 944.117 986.266 1,020 816 1.054.945 1.087.129 Cumulative RCA Entry Errors 20 20 20 24 25 26 26 26 26 27 29 29 Definition Analysla/ Action This indicator depicts the number of Radiological The cumulative RCA entry rate shows a positive (improving) trend from Controlled Area (RCA) entries per error. The January 1997 through June 1998.

Cumulative RCA Entry Error Rate is defined as the ratio of Total Error Events to Total RCA Entries. Error events To allow chart clarity above, the data as shown represents the last 12 are any instance in which an individual enters the RCA month period. The cumulative data from Jan.1997 to June 30,1998 without a Thermal Luminescent Device (TLD) and/or an shows over 1 million RCA entries have occurred. During the first 6 months Electronic Dosimeter, of 1998 we have leveled off at approximately 1 dosimetry error per 37,000 RCA entries.

Actions taken in June of 1997 to enhance the RCA entrance procedure through the use of mechanical, one-way " turnstiles" have eliminated a prevalent " human factors" deficiency in the entry procedure. The two RCA dosimetry events occurring in 1998 were in RCA entry points that do not have mechanical turnstiles installed because of their low traffic volume.

l Additional turnstiles, however, have now been installed at low RCA traffic areas to maximize RCA dosimetry compliance.

Goal Comments Th3 current goal is to have s 1 error per 25,000 RCA KPl data is current as of June 30,1998.

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 7.

elevated to insure the establishment of a " continual self-improvement" l

culture.

Data Source:

C. R. Pairner x52'6MP Analysis by:

M Wood x5049MPl owner:

W Novelos x2158MP H1

1998 Exposuro Summary 1

Millstone 3 - June 1998 l

p' Ogress:

Performance in this area is satisfactory.

O 60 55-1998 Goalis s 51 rem 50-45-40-35" Exposure data is g 30-through June 30,1998 25-20-15-M N

O I

I I

I I

I I

I I

I 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 Cumulative Exposure Cumulative Goal l

RawDats 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 4209 8.082 11.826 14.480 21.770 22.500 Cumulative Goal 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000 51.000

. >finition Analysla/ Action This indicator depicts the cumulative radiation exposure for the The cumulative exposures are tracking well within the year (person-rem year to date) vs. the cumulative radiation levels needed to maintain doses as low as reasonably exposure goal for the year for Millstone Unit 3.

achievable (ALARA).

This goal represents the level of exposure which the Health Physics department strives to stay below in order to maintain occupational exposures as low as reasonably achievable (ALARA).

Goal Comments The Goalis to have s 51 rem of total radiation exposure for Exposure data is through June 30,1998

'it 3 in 1998.

I

}

l Data Source:

D. Evans x0080MPf Analysis by:

C. R. Palmer x5256MPl Owner:W. F. Nevetos x2158MP H-2

i Self Reporting Culture Chart Millstone - June 1998 i

VTOgYOSS:

Performance in this area is satisfactory.

Goal > 75% events self-identified KPI data is current as of June 30,1998.

f 100 %

j 8W.

3 A

60% -

Bt G00d 40%

20%

0%

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May JOn 97 97 97 97 97 97 98 98 98 98 98 98 l M% of Self-identified Events Goal > 75% self-identified events l Raw 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

% of SeN-identNied Events 100 %

100 %

100 %

100 %

100 %

100 %

100 %

100 %

100%

100 %

100 %

100 %

al > 75% seN-identNied evants 75%

75 %

75%

75%

75%

75%

75%

75%

75%

75%

75%

75%

Self identified Events 0

0 4

1 1

0 0

0 1

2 0

0 Nuclear Oversight identsfled 0

0 0

0 0

0 0

0 0

0 0

0 NRC Identified 0

0 0

0 0

0 0

0 0

0 0

0 Total Eventt 0

0 4

1 1

0 0

0 1

2 0

0 De6nition Analysis / Action 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. During this of a culture in which personal' ownership'of the Radiation period, all dosimetry events have been identified and Protection Program is demonstrated through the number of self-reported by workforce personnel rather than Nuclear identified deficiencies.

Oversight or Nuclear Regulatory Commission reports.

The measure is considered meeting the KPI goal when the l

number of self identified events are > 75% of the total numt.er 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.

Goal Comments -

l The goal is for > 75% of all dosimetry deficiencies to be self.

KPi data is current as of June 30,1998.

identified.

C. R. Palmer x5256MPl Analysis by:

M Wood x5049MPl owner:

Data Source:

W. Novelos x2158MP H-3

Control of Safoguarde information Millstone Site - June 1998

,m b

{ V g(OSS:

Control of safeguards Information is satisfactory.

5 Data is current through 4,

June 30,1998 1998 Goals 3 events for the year Good

/

1 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 MCumulative Safeguards Events Goal Raw Dets Jan-98 Feb-98 Mar-98 Apr-98 May 98 Jun-98 Jul-98 Aug-98 Sep-98 Oct 98 Nov-98 Dec-98

' mutative Safeguards Events 0

1 1

1 2

2 Goal 3

3 3

3 3

3 3

3 3

3 3

3 Safeguards Events (Monthly) 0 1

0 0

1 0

Definition Analysis / Action This indicator depicts the cumulative number of events where The 1998 goal to have no more than 3 events per year Saf: guards 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 two quarters of 1998 two events have occurred.

on information obtair ed from Security Reports and Condition in February a CAD drawing was found to be improperly R ports.

controlled. This drawing was later declassified to non-safeguards status. In May a safeguards document being used for training purposes was left uncontrolled.

Both events were considered to be isolated incidents.

The Security Department will continue to monitor the program and investigate additional actions for improvement.

Goal

\\

Comments The goal is to have no more than 3 safeguards events per year.

Data is current through June 30,1998 l

I l

Da1 Source:

Security and Condition Reports l Analysis by:

M. Skorupski x4905l Owner:

M. Skorupski x4905 1-1 k

t Vchicla Contral incida tho Protccted Arca Millstone Site - June 1998

\\

lOgYOSS:

Performance is satisfactory.

v 14 ~

12 Data is curront through 10 June 30,1998 f

Good T

1998 Goals 6 events for the year V 6 Y

4-2 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 08 98 98 98 98 98 98 98 98 98 98 98 l

m Cumulative Vehicle Events Goal Raw Dets Jan-98 Feb-98 Mar 98 Apr 98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98

- umulative Vehicle Events 1

1 1

3 4

4 Goal 6

6 6

6 6

6 6

6 6

6 6

6 Vehicle Events 1

0 0

2 1

0 Definition Analyela/ Action This indicator depicts the cumulative number events where The station urrently has 66 vehicles inside the v:hicles were not controlled properly in accordance with station Protected Area as Designated (61) and Temporary procedures. Events involve keys left in unattended vehicles.

Designated (5) Licensee Vehicles. An average of 8 This data reflects the actual number of events based on Non licensee Vehicles enter and exit on a daily basis, information obtained from Security Reports and Condition An average of 47 totalvehicle transactions occur R ports.

through VAP daily.

l l

l Goal Comments The goal is to have no more than six vehicle events per year.

Data is current through June 30,1998 I

Da'1 Source:

Security and Condition Reports l Analysis by:

M. Gelinas ext. 4258l Owner:

M Gelinas ert. 42s8 l2 L__-___-_______-___

l Sccurity Badga Control l

Millstone 3 - June 1998 gress:

Progress is satisfactory.

j 14 KPl data is current through I

s 12 June 30,1998 l

. 10 S

[g Goals 8 l

Good 1

I I

m 6 E

O I

I I

I I

I I

l l

l l

l Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 08 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l

m Security Badge Control Evtc ts Goal RawDets Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 sep 98 Oct 98 Nov 98 Dec 98 7

7 4

3 4

7

'rity Bad e Control Evente 9

Gul 8

8 8

8 8

8 8

8 8

8 8

8 Szcurity Badge Control Events 7

14 18 21 25 32 (Total)

~

Definition Analysia/ Action l

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.

Insido the Protected Area. This indicator reflects the actual number of events. The data is obtained from Security Reports (SRs) and Condition Reports (CRs).

l Goal Commente '

The goal is to have s 8 events per month for 1998.

Station population has steadily decreased from 4875 on 1-1-98 to 4095 on 6-30-98.

s Source:

SRs/CRsl Analysis by:

M Klein x4376MPl Owner:

M. Klein x4376MP l-3

i Centrcl cf Vicitors incida tho Protocted Area i

Millstone 3 - June 1998 greSS; Progress is satisfactory.

4 l

i l

\\

l KPI data is current through 3

g June 30,1998 w3 j

4 8o Good 4

i (j,

Goal s 1 li 0

0 0

0 0

. I t

I i

i i

i l

I i

i Jan 9F Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l

Visitor Control Events

- Goal RawDatn 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 Goal 1

1 1

1 1

1 1

1 1

1 1

1 Visitor Control Events Total) 0 0

2 2

2 5

Definition Analysia/ Action This indicator depicts the number of events where visitors or All five incidents involved situations where escorts and visitors escorts committed violations of the security escort exited the Protected Area tumstiles in reverse sequence -leaving requir:ments. This indicator reflects the actual number of the visitor unescorted in the Protected Area for a brief period in everits. 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 escort'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 l

include responsibility acknowledgement 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.

Goal-Comments The goal is to have s 1 event per month for 1998.

The average number of events / month for the first two quarters of 1998 is below the goal of no more than one event per month.

l I

Data Source:

sRs/CRal Analysis by:

M. Klein x4376MPl Owner:

M. Klein x4376MP l

l-4

1 Survoillanco Toot Program Schedule Performance

{

Millstone 3 - June 1998 I

YOgreSS:

Performance is satisfactory.

1 i

1 i

100 %

,3 a

Goal 190%

g g

80%

d g{,os j

l 70%

l 50 %

Good E 40%

)

30 %

e

)

10%

0%

I k

k k

h f

k e

s s

s s

s s

s

~

u l M % Completed Prior to Grace Period Goal l Raw Date '

4/1548 4/22/98 479S8 54/98 5/13S8 5/2048 5/2748 6G98 6/10S8 6/1748 6/24 S8 7/198

% Completed Prior to Grace Period 100 %

95%

78 %

87%

64 %

92%

88 %

91 %

85%

96 %

95%

0%

Goal 90 %

90%

90 %

90%

90 %

90 %

90%

90 %

90 %

90 %

90 %

90%

Completed Pnor to Grace Period 132 56 29 47 25 44 28 31 28 26 19 0

Tests Completed as Scheduled 132 59 37 54 39 48 32 34 33 27 20 0

l Definition AnalysisfAction This indicator depicts the percentage of surveillance tests performed prior An effort is ongoing to get surveillance tests scheduled to entering the grace period. The grace period is defined as 25% of the and performed as specified in the 12 week work week Technical Specification (Tech Spec) surveillance frequency. (e.g. Tech planning schedule.

Spec surveillance frequency = 31 days, grace period is 25% of 31 days =

7 days)

Poel Comments "he goalis to complete z 90% of surveillance tests prior to entering the The data displayed represents the previous week's

{

IS% grace period.

schedule performance.

PMMSl Analysis by:

R. Rothgeb x5241MPl Owner:

Datt Source:

C Schwarz r0491MP J-1 a

Ovardua Provantivo Maintanonca AWOa Millstone 3 - June 1998 m

J Progress:

Progress is satisfactory.

i'\\,

40 30 -

Good g

g 20-E 10-g

,E.

M0 0

0 0 0 0 0

0 0

Goal = 0 5

I l1 5 i I8 5

8 8

i 5

! II a

s s

5 s 008 E l ~!

8 s

e s

s s

s a

s l

AWOs Overdue Work-Off/ Goal l

Raw Dets 4/848 4/1648 4!22S8 429/98 6AB4B 6/13/98 6/20/98 SG7/98 6/3/98 6/10/98 6/17/98 6G4S8 AWOs Overdue 0

0 0

0 0

0 0

0 0

0 0

0 Workett/ Goal 3

2 1

7 N., j)

,(

Definition Analysis / Action This indicatoe depicts the number of Overdue Preventive There are 0 overdue PMs.

Maintenance (PM) Automated Work Orders (AWOs).

Overdue PMs due to scheduling will continue to occur due to lead time for deferrals and the transition from an Restart is defined as " Ready to Enter Operational Mode outage schedule to the on-line Work Week schedule 2", which is the point at which Commission approval is required.

Management will continue to monitor this parameter.

This data is being analyzed and addressed on a daily

basis, i

i l

Goni Comments The goal is to have zero overdue PM AWOs prior to restart.

lA\\

L_)

Data Source:

D. A. Bannet x3062MPl Analysis by:

R. M Chnuelecki x6122l Owner:

J R Beckman x5361MP J-2

On Lino Schcdulo Performance Millstone 3 - July 1998 O (OSS Qg Performance is not meeting current management expectations.

% Work Activities Started on Time

% Work Activities Completed on Time 100 %

100 %

90% -

90*/. -

80%

Goal 75% g 80 %

Goalz 70%

70 %

70 %

60% -

60 %

SO% -

Sc%

40 %

40%

30% -

Good 30 %

Good 20%

20%

10%

10%

0%

0%

m m m e e

m S" $ $

e e

e e e e m 5

$S 5 SS*E S

5 9 3 5 SS"E l

M Percent Started Goal (starts) l I

MPercent Completed l

Goal RawData 4/25/98 5/2/98 5/9/98 5/16/98 5/23/98 5/30/98

&G/98 6/13/98 6/20/98 6/27/98 7/4/98 7/11/98 Percent started 71 %

72%

75%

66%

73%

75%

83%

66%

66%

70%

82%

l Goal (starta) 75%

75%

75%

75%

75%

75%

75%

75%

75%

75%

75 %

75%

Total Scheduled to Start 139 176 173 229 258 234 297 223 223 256 160 Total Suded 98 126 130 150 188 175 247 148 148 179 131 Percent Completed 69%

71 %

72%

61 %

70%

72%

84%

65%

65%

67 %

77%

Goat IO%

70%

70%

70 %

70%

70%

70%

70%

70%

70%

70%

70%

Total Scheduled to Complete 139 174 187 230 234 235 269 201 201 233 160 Total Completed 96 124 135 141 164 170 225 131 131 155 123 Definition Analysis / Action '

This graph illustrates the performance of scheduled starts The goals for Work Activities Started and Completed on Time have j

and completions of work activities detailed in the on-line 12 not been consistently met due to emergent work activities and l

i wrik rolling PMMS AWO (automated work order) work plan.

rescheduling required to support the start-up and power ascension, j

l This is tracked on a weekly basis.

l The date is captured Friday before the work week and analyzed the Monday following the work week.

i l

o01 Comments

> goals are that 75% of work activities are started on time Date indicates the end of the work week.

l 70% of work activities are completed on time (within work

,Dru Source:

P3 Schedule l Analysis by:

J. Leger X2391MPl owner:

C. Schwarr x0491MP J3 l

Rccovory Backlog - Opan Op3rability Datorminations Mllistone 3 - June 1998 O greSS Engineering will be resource loading the deferred items for the first quarter following entry into mode 2 (6/30 - 9/30).

l 50 40 b

M 30 Good O

i 1

1 0 20 oe l

l 0

5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 6/29/98 7/W98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 W26/98 l

5 Backlog Open ODs O New Open ODs I

R~w Dets 5/20/98 5/27/98 6/3/98 6/10/98 6/17/98 6/24/98 6/29/98 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 Backlog Open ODs 24 27 27 29 30 30 28 New Open ODs 0

0 0

0 0

0 0

Total Open ODs 24 27 27 29 30 30 28 l

l Definition Analysis / Action This indicator depicts the number of open Operability Engineering will be resource loading the deferred items for the first D: terminations (ODs). Open ODs tied to USQs remain open quarter following entry into mode 2 (6/30 - 9/30).

l l

until approved by the NRC.

l 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 quahfi d requirements.

l l

l J

Goal Commerts The Open OD recovery backlog will be dispositioned by entry v mode 2 following completion of Refueling Outage 06 plus onths.

j

{

D:t: Source: Operations OD Log & CR/AR Status l Analysis by:

R. McGuinness x6855MPl Owner:

G Swider x5381MP l

1 K1

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