ML20148R715

Progress Toward Restart Readiness at Millstone Station

ML20148R715
Person / Time
Site:	Millstone
Issue date:	05/30/1997
From:	NORTHEAST NUCLEAR ENERGY CO.
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ML20148R712	List: ML20148R715
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NUDOCS 9707080007
Download: ML20148R715 (177)

Text

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l Progress Toward 1 l

Restart Readiness ,

I at l j Millstone Station i

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l Northeast Utilities Briefing

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! U.S. Nuclear Regulatory Commission May 30,1997

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W18884E88fg -

2 TABLE OF CONTENTS

1. Executive Summary l

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II. Restart Strategy 111. Site integrated Schedule 1

IV. Progress on Key issues i 1. Leadership l 2. Line Management Self-Assessment (including Human Performance)

3. Corrective Action Program

4. Employee Concerns

5. Oversight

6. Configuration Management

7. Regulatory Performance

8. Operator Training lO l

e.

10.

w ork c o otroi e m e eie o oio s Procedure Quality and Adherence

11. Plant Support (Emergency Planning, Health Physics) i Appendices

1. Millstone Leadership Team i

2. NU Nuclear Seven Success Objectives

3. Key Performance Indicators ...... Millstone Unit 3  ;

Millstone Unit 2 i Oversight Employee Concerns Program ,

Training

4. NU Restart Definitions

5. Site Integrated Schedule l 6. Status of Nuclear Oversight Recovery Plan l 7. Little Harbor Consultants Presentation to NRC on NU l

Comprehensive Plan for Addressing Employee Concerns

! 8. NU Nuclear Safety Standards and Expectations iO

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r l Q( 1. EXECUTIVE L SUNlMARY l l

1 Puroose ,

I This Briefing summarizes Northeast Utilities' (NU) progress towards achieving restart readiness as of May 30,1997 including performance indicator data. It {

has also been designed for use as a proposed template for future Commission  !

Briefings. The following paragraphs highlight NU's progress in several areas  !

vital to Millstone recovery.

Board Supoort and Oversight The NU Board of Trustees continues to support the nuclear option as viable in the face of continued competitive pressures and industry deregulation in New England. Appropriate resources are being provided to achieve recovery of each of the three Millstone units. The Nuclear Group continues to receive strong

, oversight from the Board's Nuclear Committee and the Nuclear Committee

. Advisory Team (NCAT).

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Safety-Conscious Work Environment The NU leadership team fully understands and is committed to create and sustain a safety-conscious work environment. It is recognized that creating a j work environment where workers feel free to raise concerns, and to have i confidence those concerns will be addressed in a responsible and timely way, is an absolute necessity in the recovery of the Millstone Station. Throughout this process, nuclear safety, regulatory compliance, and conservative decision making are the foundation of NU's efforts to set high standards and to do what is l right.

Restart Strategy and Schedule Millstone 3 continues to be the lead plant for restart readiness with NU readiness currently targeted for late 1997. Millstone 2 remains a close second with NU readiness currently targeted for early 1998. The pace of the restart effort for Millstone 1 has been slowed although efforts to restore the design and licensing bases (Configuration Management Project) are continuing. NU's Unit 1 restart readiness is currently targeted for mid-year 1998.

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U Station-Level Management of issues Increased emphasis is being placed by management on eleven issues vital to Millstone recovery. Section IV of this Brief has been structured to provide success criteria, progress (including reference to Key Performance Indicators (KPls) which may be found in Appendix 3, where appropriate), and work I

remaining for these issues in a concise yet comprehensive way. The work remaining includes programs for startup and power ascension and continuous performance improvement.

In many cases, the issues are long-standing areas of weakness identified through self and independent assessments and NRC inspections. Others involve more recently identified issues such as operator training. Additional issues or i sub-issues may be added in the future such as plant support programs (e.g., I security and safeguards) and operator qualification.

NU acknowledges the inter-relationship of the solutions to address these vital issues. For example, effective Corrective Action and management Leadership are critical to address Employee Concerns. The linkages between these vital  !

issues will be finalized and included in future NRC Briefings. ,

o Kev Performance Indicators b -

NU has developed and implemented a standard set of KPis for all three Units I

I and for the Nuclear Oversight organization. The standardized KPis have been I applied as one means of monitoring progress toward achieving defined success criteria. These KPis reflect the unique circumstances at Millstone.

The presentation format for the KPis previously presented to the NRC Staff has been enhanced to provide a more clear and understandable message regarding .

progress achieved, challenges remaining and analyses results which suggest I areas for additional management attention. The fundamental content of the KPI's has not been altered. As NU progresses through the restart process, existing KPis may be modified or new ones added to increase focus on progress toward achieving restart success criteria. These changes will continue to be i communicated to the NRC as part of on-going Briefings.

Confiauration Manaaement 1 I

Measurable progress in restoring and subsequently maintaining the design and j licensing bases and plant configuration for each unit has been demonstrated by the results of the Unit 1 Challenge Board (industry experts) and by recently meeting a major Configuration Management Project milestone, Readiness for

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! v Independent Corrective Action Verification Program (ICAVP) initiation on

d' 5- l Millstone 3. A substantial quantity of work by the line organization and Nuclear

! Oversight was necessary to achieve-lCAVP readiness. This milestone was

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achieved on-schedule and communicated to the NRC Staff on May 27,1997.

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' We . recognize that effectiveness will ultimately be determined through our l I

internal restart readiness assessments and independently verified through the '

ICAVP process and NRC inspections. .Through these activities, NU will have

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1 numerous opportunities to demonstrate that NU's high standards are being met. l '

! Work Prioritization and Plannina NU has made progress in improving work prioritization and planning across the l

! site. This is evident in the following areas: '

sequencing of unit readiness for restart (rather than driving all three units

in parallel),

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implementation of a Site Integrated Schedule, and i

increased cornmonality in programs and processes (e.g., corrective action). 1 L

i Community Outreach l

NU has accepted responsibility for loss of public trust and confidence stemming from past Millstone Station performance. NU has acknowledged that  ;

j improvement in public confidence must be earned through a combination of i

several factors inciuding improved operations, strong internal oversight, and  !'

l favorable evaluations from NU's regulators.

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{ In order to enhance general public awareness of Millstone's progress, NU has

[ implemented a number of community outreach activities whose foundations are based on complete openness and a willingness to share information about our

'; recovery and operations - both the successes and the setbacks. Some of these i

activities include community discussions at the Waterford Town Hall, NU j leadership team . breakfasts with community leaders, public observation of NU l Nuclear leadership team staff meetings, the Millstone Advisory Council,

[ participation in the Connecticut Nuclear Energy Advisory Council, and the

Nuclear Speakers Bureau made up of NU employee volunteers.

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6 0F 3 II. Restart Strategy l ( J On May 5,1997, NU announced a restart strategy refinement involving the adoption of a " lead plant" model. Unit 3 continues as the lead plant, with Unit 2 as a close backup. The pace of restart efforts at Unit 1 is being scaled back to allow focus of criticalleadership skills and talents. Likewise organizational and financial resources are being directed to improve the probability of a Unit 3 l restart by the end of 1997 while continuing to preserve safety and high quality standards. Mr. Michael Brothers (Unit 3 Officer) is responsible for overall Unit 3 readiness. Mr. Martin Bowling (Unit 2 Officer) and Mr. Jack McElwain (Unit 1 )

Officer) are contributing regulatory and physical plant readiness management, respectively for Unit 3. Appendix 1 provides the organization chart for the Millstone leadership team. (See Figure 1)

Identifying Unit 3 as the lead in the restart effort accelerates the adoption of uniform approaches and management standards across the Millstone Station. l Examples of current activities where a consistent station-wide approach is being I rm applied include:

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- Site Integrated Schedule - to establish a clear picture of the restart process and accountabilities (See Section Ill. and Appendix 5);

- Common Key Performance Indicators - to report restart progress to the NRC and other external stakeholders (See Appendix 3);

- Increased commonality on programs or processes - for example, leadership development and corrective action.

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7 l a r O Ill. Site Integrated Schedule

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A. Integrated Schedule - Secuence of Events The activities necessary to support safe restart of the Millstone Nuclear Units are l numerous and inter-related. Consistent with the April 23,1997 commitment to the Commission, a Millstone Site Integrated Schedule (SIS) has been included for the major activities affecting Millstone station. An activity is being included on the SIS if the activity affects the critical path for restart of any unit, impacts l multiple units, or significantly affects external commitments. Revision 0 of the  !

SIS was issued on May 30th, following station wide management review. Itis provided in Appendix 5. ]

l The SIS is the central repository of the planning efforts to accomplish activities, tasks, programs, projects and key milestones. As such, the SIS lays out the  ;

collective pians for sequencing of activities, the anticipated level of effort, and the expected task durations. Additionally, the SIS reflects the responsible station, department, manager or individual for assigned activities. The SIS is an i important communications tool across the site between NU and the NRC.

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B. NU Restart Definitions A set of restart definitions have been developed which are linked to the key milestones described in this section. These definitions were previously provided to the NRC Staff during the May 21,1997 Restart Assessment Panel Briefing at Millstone, and are presented in Appendix 4.

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Table 1 below provides key restart milestones and current NU target dates which reflect the recently announced lead plant strategy. Unit 1 plans and schedules are currently under evaluation and will be revised by the end of June,1997.

Periodic revisions to the SIS are anticipated and will routinely be communicated to the .NRC.

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C, Table 1 KEY NU RESTART MILESTONES

SUMMARY

Unit 3 Unit 2 Unit 1 Taraet Target Target ICAVP Readiness 5/27/97 6/30/97

• OSTI Readiness 9/30/97 9/30/97

• Physical Plant Readiness 9/30/97 11/25/97 * '

Ready for Restart (Regulatory) 11/22/97 12/16/97 *

• To be determined by June 30,1997 4

C. Progress on Restart Milestones t .

Background

The three Millstone units were shut down by NU management decision in order to formulate and implement corrective actions that would address a series of technical, management, and regulatory compliance issues.

Table 2 below provides the month and year each Millstone Unit was shut down.

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MILLSTONE UNIT SHUTDOWN DATES I

. Unit 1 November 4,1995

. Unit 2 February 20,1996

. Unit 3 March 30,1996

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! 9 l Subsequently, the NRC sent a series of confirmatory letters to NU

(^N pursuant to 10 CFR 50.54(f) requiring NU to affirm compliance with the l Cl l

conditions of each unit's license and regulations before restarting the unit.

As NU implements the numerous corrective actions required to address l the 10 CFR 50.54(f) concerns - and on the many broader performance issues (including other confirmatory letters) -- a series of information i

exchanges, letters, submittals, and meetings are being held with the NRC Staff.

An important part of these information exchanges is to provide and discuss progress (detailed in Section Ill.C below and Section IV.) on Millstone Restart Readiness. This discussion includes a comparison of actual or reported unit progress to scheduled progress using the Site Integrated Schedule (SIS) for selected Restart Milestones of interest.

As Unit 3 was designated the lead unit on May 5,1997, this update discussion will primarily be directed to Unit 3, and correspondingly less for the other units.

Unit 3 m Millstone Unit 3 was shut down in March,1996, due to a design deficiency V -

in Auxiliary Feedwater System Containment isolation valves.

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Subsequently, the NRC requested information on . configuration i management under 10 CFR 50.54(f). The following key milestones l towards restart readiness were established:

May 27,1997 Start of ICAVP l

July 14,1997 Complete the Configuration Management Program (i.e. complete discovery on 100% of the Unit 3 risk significant and/or safety significant systems)

September 30,1997 Physical Plant Readiness Ready for the NRC Operational Safety Team Inspection (OSTI)

November 22,1997 Ready for Restart (Regulatory) l l

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(d Millstone 3 has met the May 27th milestone for ICAVP readiness.

Discovery of discrepancies on 50% of our risk-significant and safety- 4 significant systems and associated engineering programs was completed.

Independent assessments by both the Millstone Unit 2 CMP and Nuclear Oversight resulted in favorable recommendations to proceed. In addition, the ICAVP contractor and NRC inspection support are in place.

With ICAVP underway, the focus has shifted to completing the Configuration Management Program discovery of discrerancies by July 14th. Efforts are currently slightly behind schedule due to a shift in l resources in late April and early May to support preparations for start of I ICAVP. With resources being re-focused on this effort, this slippage is expected to be recovered. Unit 3 is on track to have all Condition Reports evaluations which are more than 30 days old completed by July 5th.

Work toward achieving physical readiness for restart is continuing. l Currently, the Motor Operated Valve (MOV) repair program has become  ;

critical path among the activities needed to achieve physical plant i readiness. Physical readiness for restart is also being challenged by required modifications - particularly, issues regarding the operability of f) the Recirculating Spray System (RSS).

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Major elements of this September 30th OSTI readiness date include  ;

completion of the 10 CFR 50.54(f) effort, the NRC Significant items List,  ;

elements of the NRC Manual Chapter (MC) 0350, performance indicators  !

at goal or on the work-off curve, and assurances that an improved, healthy environment exists for receiving and resolving employee concerns. Delivery of SIL packages is proceeding generally on schedule. j Efforts are currently underway to rewrite the Unit 3 Operational l Readiness Plan to define actions required to meet the restart critena i defined in MC 0350. I The attached Unit 3 Performance Indicators (Appendix 3) indicate that 50.54(f), corrective action evaluations, NRC Significant items List, temporary niodifications and procedure review backlogs are on track to meet established schedules. The current challenges are completion of modifications required for startup, License Amendment Requests and total corrective actions required for startup. The management organizational changes discussed above are focusing on completing the submittal of all License Amendment Request submittats by June 30,1997, completing all 1 modifications by September 30,1997 and completing the CMP by '

July 14,1997 to allow completion of required corrective actions by (o) September 30,1997.

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U Execution of the recovery plan has generally been satisfactory, but has highlighted continuing problems with both unit and site-wide programs and processes. Worker frustration with being able to efficiently accomplish work continues to be high. Schedule adherence continues to be challenged.

Several management actions have been taken to address the above challenges at Unit 3:

Line responsibility for the Configuration Management Program (CMP), as well as Regulatory readiness, has been transferred to Unit 2 Recovery Officer Marty Bowling. Changes to the CMP to incorporate lessons learned at Unit 2 are expected to improve efficiency. l

. Line responsibility for achieving physical readiness for restart has been assigned to Unit 1 Recovery Officer Jack McElwain. In that capacity, he will have authority over, and responsibility for all aspects of work planning and outage management, maintenance, and modification engineering. This is expected to enhance the efficiency of the work and modification processes.

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. Engineering of restart-required modifications is being outsourced to ,

other engineering departments within NU, Stone & Webster, and l Southern Company.

. Focus areas are being established to facilitate and promote teamwork, accountability, and determination of progress.

. Experience gained at Units 1 and 2 in the area of leadership development training is being applied at Unit 3.

UniL2 Millstone Unit 2 was shut down to inspect the adequacy of the Recirculation Spray Sump Screens. Subsequently, the NRC requested information on configuration management under 10 CFR 50.54(f) for Units 2 and 3.

Unit 3 had oeen designated as the lead unit for restart until October 1996.

From October 1996 unti! May 5,1997, Unit 2 was worked in parallel with Unit 3.

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/7 During this time, the following major activities were completed:

V Establishment and implementation of a configuration management process which would meet the NRC ICAVP order.

Standards raised for the leadership team (on-going activity).

Effectiveness of the corrective actions process was improved.

In February 1997, Unit 2 unloaded the reactor core to the spent fuel pool and initiated the Unit 2 Recovery Plan. The plan was based on  ;

addressing and fixing systems and issues in order of safety significance.

Execution of the plan has been generally good, but has highlighted weaknesses in both Unit 2 and site-wide programs and processes. The 1996 work effort was not sufficiently effective to reduce the large amount of open work items still required for startup. This combination has i provided both leadership and schedule adherence challenges.

Unit 2 organizational readiness and leadership standards continue to improve. Overall morale is good and should continue to improve as the p)

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backlog of corrective actions are worked off. The Nuclear Safety culture, including addressing employees concerns, is improving.

l Currently, the projected Key Unit 2 Milestone dates are: I

. Ready for ICAVP June 30,1997

. Core On Load August 6,1997

. Mode 5 August 20,1997

. Ready for OSTI September 30,1997

. Physical Plant Readiness November 25,1997

. Ready for Restart (Regulatory) December 16,1997 Key Performance Indicators indicate three of the above Key Milestone dates are challenged. They are:

1. Ready for ICAVP - The projected date for this Key Site Milestone had been adjusted from May 5,1997 to June 23,1997, and now to June 30. 1997. The process implementation has been i effective, but the scope of the required review is very large and efforts to resolve issues (many of which have been backlogged l since 1996) are resource intensive and more difficult than originaliy anticipated.

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2. Physical Plant Readiness - due to the large number (~100) of (3 physical modifications required for restart, and licensed operator V restart qualifications activities, this Key Site Milestone is challenged. The work-off rate must be improved. This milestone is under review to determine what further actions / resources are required.

3. Ready for Restart (Regulatory) - based on the number of license amendments required for restart and the current work off rate, this Key Site Milestone is challenged. The target date for the last submittal to NRC is July 31,1997.

Several management actions are being taken to address the above challenges. Some of these include:

Establishing weekly, monthly, and quarterly focus items and goals to facilitate and promote teamwork, accountability, and the determination of progress.

Outsourcing the engineering of major modifications to a qualified and experienced A/E, fm . Increased focus on the need to complete corrective actions as well C -

as identifying the need for corrective action.

. Strengthening the role of the Nuclear Oversight organization in the assessment of Unit 2 work activities.

. Efficiency enhancements to the work control and modification process.

. Improvements in the quality of safety evaluations performed and license amendment packages prepared.

. Developed plans for ensuring operator qualifications are at the highest standard for restart.

Unit 1 With the naming of Unit 3 as the lead unit, Unit 1 resources have been reduced. While reduced in amount, the work effort on Unit 1 continues to be directed towards safe, shutdown operations. As before, shutdown risk g management is an area of prime focus.

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Plant physical work is being performed primarily through the use of NU

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s-personnel. Emphasis.has been placed on . correcting plant material condition items from the existing work backlog. Unit 1 continues to evaluate the full effect of naming Unit 3 the lead unit. Key NU Restart i- Milestone dates for Unit 1 will be published with the next revision to the Unit 1, Level 1 schedule (to be issued by June 30,1997).

Unit.1 actions in support of correcting 10 CFR 50.54(f) issues continue.

This activity is staffed utilizing a combination of both NU and outside i

contractor engineering, and engineering support personnel. 1 1

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r IV. Progress on Key issues

L A. Issues Management Introduction From the following sources, Millstone Station performance issues have been identified:

Self and independent assessments including: the Fundamental Cause Assessment Team Report, Joint Utilities Management Assessment, and ACR 7007; Quality Assurance audits; Special NRC inspections, e.g. Millstone Independent Review Group, inspection Report 96-201, etc.;

Routine NRC inspections; and 1

INPO evaluations.

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B. Issues and Progress Reports (VD '

The Nuclear organization has identified eleven key site-wide issues as requiring additional management focus and resolution. These issues represent a combination of root causes from previously conducted self-assessments (e.g., leadership and standards), and issues where on-going

action plans include completion of a formal root cause (e.g., plant support areas).

Issue Progress Reports on the eleven areas are contained in the pages that follow.

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O V 1 LEADERSHIP 1

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' l ISSUE Lack of leadership resulting in the setting and toleration of low standards.

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PROBLEM STATEMENT The lack of leadership has resulted in numerous examples of:

1 e Weak implementation of conservative decision making;

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• Loss of trust and credibility of management with employees, regulators, and the general public;

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( e - Loss of conhguration management;

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• Regulatory noncompliance; e ineffective corrective actions; 1

e ineffective self-assessment and oversight.

SUCCE :iS CRITERIA

. Meet the Seven Success Objectives described in Appendix 2.

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. Achieve a 15% improvement in the average Leadership Assessment score j from the baseline measurement in November 1996.

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V PROGRESS A senior management leadership team that understands and sets high standards is in place. First-line supervisors and above are receiving leadership development training with specific emphasis on the basic values: 1) Do the right thing 2) Treat people with  !

respect and, 3) Promote teamwork. Senior management is also championing and l supporting the oversight role (i.e. self-assessment, Nuclear Oversight, Nuclear Safety Assessment Board). Finally, line management is assuming responsibility and ownership of key support activities (i.e. Training, Security, Emergency Preparedness).

Examples include:

Senior management now fills key positions in the Emergency Response Organization; l Unit and senio; iine management have established Curricular Advisory Councils and an Executive Training Council to provide the necessary line ownership for training. The expectation of 100% training attendance accountability has been established; pb Unit 1 has completed its Fomm for Leadership Excellence for first-line supervisors and above; Unit 2 has completed its Enlightened Leadership for first-line supervisors and above; and Standards and Expectations for Nuclear Safety and the Employee Concerns Program have been issued.

REMAINING ACTIONS

. Solidify the establishment of a healthy, safety-conscious work environment based on raising standards in the nuclear safety area and providing an Employee Concerns Program and working environment that employees find credible. To facilitate this, senior management will complete the Managing Nuclear Safety course and champion the internalization of the Nuclear Safety Standards and g Expectations (See Appendix 8).

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18 Further improve Unit .3 leadership capability. Unit 3 management from first-line q supervisor up will be attending the two week long Forum for Leadership V Excellence (FLE), implemented at Unit 1. In advance, and following that participation, this same group will be engaged in periodic sessions aimed at improving leadership focus and communications patterned after the Enlightened Leadership Program at Unit 2. Refresher / reinforcement sessions are being planned to optimize immediate application of the enhanced leadership skills.

Continue to improve the self-assessment capability such that significant program and process issues are identified first by the line management rather than by Nuclear oversight, the regulator, or by an actual event. (See issue Section #2 -

Line Management Self-Assessment)

Improve adherence to established schedules by focusing the organization on completing corrective actions.

. Provide more management visibility and access to workers throughout the station.

Ensure no significant operating events occur that would challenge safety limits by applying the philosophies of conservative decision making and defense-in-depth.

Complete periodic Leadership Assessments and the FPI culture survey to provide f- .

management effectiveness feedback.

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. Individual action plans will be implemented for those with Leadership Assessment Scores in the bottom 15% for Millstone.

. Implement individual action plans for those supervisors with leadership scores in the bottom 15% for Millstone.

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l 19 LINE MANAGEMENT SELF-ASSESSMENT O

ISSUE Ineffective self-assessment PROBLEM STATEMENT l

A culture has existed that emphasized justification of performance inadequacies and acceptance of low performance standards.

SUCCESS CRITERIA j

l Nuclear Oversight confirms that an effective management self assessrnent program (including human error performance reduction) is functioning in the units and

appropriate support organizations.

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PROGRESS The Root Causes of this issue were:

. Failure of management to establish appropriate standards for self-evaluation; and  ;

. Tolerance by management of substandard performance.

Comoleted items

1. Management expectations of the necessity for a robust self-assessment program have been communicated to station personnel.

A recent self-assessment of the station's self-assessment program l

indicates general understanding of management's expectations.

l l 2. In general, station personnel understand that utilization of self-l assessment will improve site performance.

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3. Procedures have been implemented within Units 2 and 3 that establish

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v formal self-assessment programs. The Design Change Manual contains formal guidance for conducting self-sssessments within the engineering organizations.

4. Units 2 and 3 have developed annual self-assessment plans which include 85 and 81 formal self-assessments, respectively. Engineering Assurance has completed 29 assessments and is currently updating the annual plan for the remainder of the year.

5. Formal training has been established to provide station personnel with an understanding of the importance of self-assessment and the tools to perform self-assessments. To date more than 450 people have attended this training.

6. Units 2 and 3 have established common performance indicators which  !

measure aspects of performance within each line organization (See {

Appendix 3). In addition, Unit 2 has established an annunciator window l

process which displays performance in relation to established standards. l This methodology is based on industry good practices.

7. Self-assessments have been conducted by various organizations across (3 the site. Some examples include self-assessments of the Configuration

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Management Plan, design activities related to configuration control, the -

Unit 2 Corrective Action Program, and the Unit 3 Self-Assessment Program. All of the self-assessments have been valuable in identifying areas for improvement in the areas evaluated.

Work In Progress:

Management is continuing to promote the value of formal and individual self-assessment for continuous improvement of site performance. l Training on self-assessment is continuing. Indicators are being developed '

to measure performance against established standards using the ,

annunciator window process. Self-assessments continue to be l conducted in accordance with the annual plans to establish baseline performance.

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j REMAINING ACTIONS Integrate the results from completed self-assessments to identify common causes, to focus corrective actions, and communicate the state of readiness for restart.

Perform self-assessments of relevant NRC Manual Chapter 0350 inspection l areas to determine readiness for OST1. Compare the results with Nuclear j Oversight independent assessments in the same functional areas. l Compare the results of the self-assessment of the Configuration  !

Management Plan with the results reported by Nuclear Oversight. l Perform a follow-up self-assessment of the Self-Assessment program to verify effectiveness. )

Perform a self-assessment of completed Level 1 Condition Reports to  ;

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determine effectiveness of the corrective actions.

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. Implement the industry HPES program.

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. Develop Performance Indicators for human performance.

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1 22 Corrective Action Program i ISSUE Millstone has a weak corrective action program j PROBLEM STATEMENT The Corrective Action program has been weak in ensuring comprehensive, timely, and effective corrective actions.

f SUCCESS CRITERIA

, Nuclear Oversight confirms that an effective Corrective Action Program is implemented for the unit and appropriate support organizations which:

1. . Demonstrates that conditions adverse to quality are identified in a timely manner;

2. Demonstrates that conditions adverse to quality are evaluated for operability and reportability in a timely manner (i.e. 24-72 hours);

3. Demonstrates that action plans to resolve identified conditions adverse to quality are provided within 30 days (KPl developed);

4. Completes corrective actions required for restart; and

5. Establishes a trending program that will identify recurring conditions adverse to quality and common causes of problems.

PROGRESS The Root Causes of this issue were:

. Failure of management to establish appropriate standards for timely and effective resolution of conditions adverse to quality.

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l 23 l e Failure of management to aggressively pursue identified conditions adverse l to quality.

l An atmosphere established by management which discouraged timely l identification of conditions adverse to quality.  ;

Comoleted items:

1. Management expectations have been communicated regarding the critical nature of an effective corrective action program. A process has been implemented which supports '.he expectations of timely identification, timely and comprehensivo acticn p'an development, and timely and effective corrective actions. Stande,ds and performance indicators have been  ;

established to measure perfccmance.

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2. Units 2 and 3 have submitted comprehensive closure packages on schedule for Significant Issues List items related to Condition Reports and regulatory issues. The NRC inspectors have indicated satisfaction with the quality of the packages.

3. Units 2 and 3 have published quarterly trend reports which have been

! identified areas for improvement.

Work in Progress:

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1. Management expectations continue to be reinforced regarding the corrective i action program.

l 2. Management continues to reinforce the need for timely reporting of real or l l perceived conditions adverse to quality. Less than one percent of Condition Reports evaluated have discovery dates earlier than the reporting dates. This

indicates that employees are promptly reporting deficiencies as they are discovered.

! 3. The timeliness of investigations and action plan development is monitored and l displayed through performance indicators. The backlog of unevaluated l Condition Reports continues to be reduced. At the beginning of February, unevaluated Condition Reports for Unit 2 and Unit 3 stood at 812 (781 >30 days old) and 1229 (764 > 30 days old) respectively. By May 23, these numbers had been reduced to 335 (224 > 30 days old) and 674 (233 > 30 days old). In February only 17% and 22% of new Condition Reports were investigated within 30 days for Units 2 and 3 respectively. By April, those j percentages had risen to 24% and 52%. (See Appendix 3) The quality of the investigations and resultant corrective actions are monitored by multi-discipline teams.

24 A 4. The timeliness of completing corrective actions is monitored and displayed

!V through performance indicators. The number of open actions for Unit 3 i continues to grow as the backlog of unevaluated Condition Reports is investigated and actions plans are developed. (See Appendix 3) Units 2 l

and 3 have developed weekly work off goals which are discussed daily. The NRC Significant issues List items related to Condition Reports are being l completed and provided to the NRC on schedule.

5. Units 2 and 3 will continue to access corrective action trends on a quarterly basis.

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REMAINING ACTIONS

. The existing backlog of unevaluated Condition Reports must be eliminated  ;

and consistency established in meeting the standards for investigating and l

developing actions plans to resolve conditions adverse to quality.

. Actions identified for completion prior to restart which are delineated in the response to request #1 from the April 16,1997 NRC 50.54(f) letter must be O completed.

. The completion of the NRC Significant issues List items related to Condition Reports to meet the Millstone pre-requisites for " Ready for OSTI." 4

. Continue completion of quarterly trend reports to determine the need for further self-assessment and corrective actions.

. Conduct a self-assessment of each Unit's Corrective Action Program.

. Develop or refine performance indicators to ensure that the effectiveness of the corrective action program is being measured.

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25 l (nJ EMPLOYEE CONCERNS i

l i

l ISSUE Need for a Safety-Conscious Work Environment at Millstone Station I

PROBLEM STATEMENT 1

Millstone Station has not maintained a safety-conscious work environment in which employees feel free to raise concerns both to their own management and the NRC l without fear of retaliation. In addition, the Employee Concerns Program has not been l effective in assisting concerned individuals who were unable or unwilling to have their concern (s) resolved by their management.

l SUCCESS CRITERIA I

l V

Employee Concerns Oversight Panel confirms sufficient progress toward achieving a safety conscious work environment at Millstone. (Evaluation criteria is under development) l

. Little Harbor Consultants confirms that a sufficiently safety-conscious work environment has been reestablished at Millstone.

PROGRESS The Root Causes for the failure to maintain a safety-conscious work environment are contained within the:

1. Fundamental Cause Assessment Team (FCAT) Report dated July 12,1996; and

2. NRC Millstone independent Review Group (Hannon Report) of October 1996.

Actions in Place to resolve this issue include:

1. Re-establishment of configuration management for each of the units; O 2. Development and demonstration of an effective corrective action program; i

l 26

3. Significantly improving the leadership performance of line management; and (3 4. Implementation of those portions of Northeast Utilities Plan for Addressing V Employee Concems (Comprehensive Plan) which address the restoration of a safety-conscious work environment.

Note: Items (1.), (2.) and (3.) are the subject of issue #1, #3 and #6 and will not be further discussed in this Progress Report.

Actions Comoleted include:

1. All senior leaders (President, Vice-Presidents, and Unit Officers) have been changed from those existing at the time the safety-conscious environment degraded;

2. Seventy-five percent of the Directors have also been changed, or are in different positions; and

3. Of the 155 action items contained in the Comprehensive Plan, 88 have been completed. Key items completed include:

Selection of the Employee Concerns Oversight Panel, Development of an new employee concerns resolution and closure process, Communication of expectations to all employees, and q -

Establishment of an effective self-assessment process which has V -

already identified areas for further improvement.

l The NRC Staff was given an extensive and detailed briefing on the Employee Concerns l Program, the Employee Concerns Oversight Panel, and line management initiatives to I foster a safety-conscious work environment on May 13, 1997 in a public forum. In l addition, Little Harbor Consultants presented their comments on our Comprehensive l Plan at a meeting later on the same day (Refer to Appendix 7). l l

The effectiveness of the actions taken to date are illustrated by the key performance indicators in Appendix 3 which indicate favorable trends for: l

1. The relative rate at which the ECP receives concerns vs the rate the NRC receives allegations concerning Millstone Station;

2. The percentage of employees who come to the ECP requesting confidentiality;

3. The length of time it takes to resolve a specific concern submitted to the ECP;  ;

and

4. The resolution of long standing concerns submitted to the ECP.

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l p The key differences in the new ECP are:

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1. Establishment of a partnership with line management to facilitate the resolution of concerns;

2. Increased ECP staffing and training; i 3. Concerns tracked through implementation of corrective action; and

4. Independent employee oversight.

l REMAINING ACTIONS l

l Completion of the remaining Comprehensive Plan key action items directed at re-establishing a safety-conscious work environment. Appendix 3 shows the status of comprehensive plan action item implementation; e

Assessment of the effectiveness of the action items in restoring a safety-conscious work environment through interviews and surveys. Improvement indicators, as applicable, will be developed;

. Complete leadership development and training; and Conduct FPI Culture Survey to provide feedback to management.

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28 OVERSIGHT (3

V ISSUE Ineffective oversight of nuclear activities.

1 __

PROBLEM STATEMENT

, Assessments performed over the past several years have identified weaknesses in the identification and resolution of Oversight identified problems. The Oversight i organization was not viewed as a value-added organization by the line.

SUCCESS CRITERIA l

. The Millstone Nuclear Safety Assessment Board (NSAB) confirms that Nuclear

)

Oversight is providing effective audits, reviews, and assessments of unit and support organization programs, processes, and ectivities.

. The Millstone Nuclear Safety Assessment Board (NSAB) confirms that unit and support organizations effectively address Nuclear Oversight findings in a timely manner.

PROGRESS The Root Cause of this issue was identified by:

. Adverse Condition Report (ACR) 7007 Event Response Team Report - 2/22/96;

. Report of the Fundamental Cause Assessment Team - 7/12/96; e Report of the Management Review of the Adequacy of the Northeast Utilities Quality Assurance Program ("JUMA")- 7/17/96;

. Effectiveness of the OversigWt Organization, Root Cause Evaluation Report -

9/10/96; and

( . NRC (W. Travers) letter to B. Kenyon, Restart Assessment Plan - 3/24/97.

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/N Comoleted Actions:

N]

In general, the Recoverv Plan for Nuclear Oversight oroarammatic and organizational imorovements has been comoleted. Highlights include:

Published CEO Expectations for Nuclear Oversight; l Executed Interface Agreement on Mutual Expectations for Nuclear Oversight between Nuclear Oversight and the Recovery organizations; Completed Reorganization, increased staffing numbers by almost one hundred percent, and developed or revised procedures to reflect new processes;

. Developed KPis and reports to measure and communicate the health of Oversight programs (see Appendix 3);

e Formalized audit and surveillance / field observation pronrams and schedules; Integrated audit, surveillance, operating experience and Independent Review Team (IRT) activities; e

implemented an Oversight Self-Assessment procedure and developed an annual schedule; e

Developed workoff curves and assignments to identify outstanding issues; and

. Developed a monthly report to send to the President and CEO of NNECO.

The Millstone NSAB has been reconstituted with senior management, additional p external membership, and a strengthened subcommittee structure. The Millstone

( ) NSAB reports directly to the President and CEO of NNECO.

Work in Progress: l i

l

. Implementation of new " hold point" procedures; i e implementation of new training program;

. Upgrade of the ISEG/ Operating Experience organization; j

. Completion of NRC commitment and JUMA (external assessment) open items;  !

. Independent Assessment of Nuclear Oversight (verify Oversight readiness for l restart); and  !

e implement Restart Verification Program (Oversight criteria and plans to assess readiness for key milestones, such as ICAVP and OSTI).

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REMAINING ACTIONS

. Complete the implementation of the Recovery Plan for Nuclear Oversight items to support unit restart. A continuous improvement process is outlined under Objective 7 of the Recovery Plan.

An Oversight Strategic Plan is being developed to help identify and begin to facilitate Oversight long-term improvement initiatives.

implementation of a continuous improvement process which will transition quality functions, analysis and assessment activities and staff into the line organization and position Nuclear Oversight in the role of evaluator of the line's self assessment capability.

Complete NSAB assessments of Nuclear Oversight effectiveness and unit readiness for restart.

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l 31 (a CONFIGURATION MANAGEMENT l

l lSSUE l

The issue is the loss of configuration control of licensing and design bases information for the Millstone Nuclear Power Station, Units 1,2 and 3.

PROBLEM STATEMENT Previous configuration control processes and practices did not consistently maintain the relevant documentation for the licensing and design bases of the Millstone Station units. Unit operation in conformance with its operating license, Nuclear Regulatory Commission (NRC) regulations and the units' Final Safety Analysis Report (FSAR) was not always met.

SUCCESS CRITERIA

. Nuclear Oversight determines with reasonable assurance that:

- The licensing and design bases requirements have been documented, validated, and verified to accurately reflect unit configuration and operation.

- Adequate programs and processes have been verified to maintain configuration control.

• Response to the NRC 10 CFR 50.54(f) letter is completed.

. Reviews by the ICAVP Contractor and NRC inspections confirm the above actions.

PROGRESS The Root Causes of this issue are identified by:

. Adverse Condition Report (ACR) 7007, " Millstone Unit 1 UFSAR inaccuracies" Event Response Team Report, February 22,1996; Letter from William T. Russell, USNRC, to T. C. Feigenbaum,

Subject:

" Confirmatory Order Establishing independent Corrective Action Verification Program", August 14,1996; and

. US NRC inspection Report 50-336/96-201 and 50-423/96-201 dated September,1996.

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32 Comoleted Actions:

Development of the Configuration Management Plan which provides for the ,

restoration of the design and license bases and for the long-term '

r maintenance of plant configuration.

! Establishment of dedicated unit CMP project teams for each unit. Project l teams of up to 200,150, and 250 personnel have been used for UNIT 1, UNIT 2 '

and UNIT 3, respectively.

Development of CMP implementing Project instructions to identify and .

! document license commitments, license and design bases, and technical l programs. These procedures also provide directions for detailed reviews of l technical programs and for physical plant walkdowns.  !

• Systems and programs were identified for each unit. This includes 65 ,

systems for UNIT 1,63 systems for UNIT 2 and 88 systems for UNIT 3. Program l topical areas reviewed included 19 areas for UNIT 1,51 for UNIT 2 and 51 for UNIT 3.

. Reviews to document the licensing basis and design bases are ongoing.

They have identified 2,757 issues for Unit 2 and 3,167 issues for Unit 3.

This resulted in 7 LERs for Unit 2 and 5 LERs for Unit 3. There are also 83 Unit 2 and 103 Unit 3 modifications resulting from these items.

. A team has been formed to support the ICAVP response activities and to be the focal point for the ICAVP contractor.

. Millstone 3 completed discovery on 50% of risk-and-safety-related systems and 19 topical programs and the ICAVP Readiness has been achieved.

'O. . Completion of UNIT 1 CMP Challenge Board:

- Charter: The Board was chartered to perform a challenging, critical assessment of all UNIT 1 CMP processes and procedures. Reviews included detailed evaluations of the adequacy and proper implementation of Configuration Management Plan Project Instructions (Pis). j

Conclusions:

The Board concluded that the Unit 1 CMP, when properly l implemented, including the recommendations from the Challenge l Board, will provide reasonable assurance that plant configuration can l be maintained as specified in the terms and conditions of the unit's l operating license, NRC regulations (including 10CFR50.59) and the i unit's FSAR. '

. Key procedures and processes were reviewed, with changes made in the following processes to strengthen configuration control sufficiently to support plant restart:

Safety Evaluation Process, FSAR Change Process, Design Control Manual, and g -

Document Control.

ty

33 fg Work in ProgrgsE O e Completing the licensing basis re-establishment activity for the 65 UNIT 1 systems,63 UNIT 2 systems and 88 UNIT 3 systems.

. Submitting periodic updates to the 10CFR50.54(f) letter for each unit to provide an ongoing status of each unit's progress.

. Completing the in-progress Engineering Reviews for 31 of 51 Millstone 2 programs and for 32 of 51 Millstone 3 programs.

Implementing Millstone 1 Challenge Board findings and recommendations.

Completing revision of Nuclear Group Policy 3.2, " Configuration Management", and Nuclear Group Procedure (NGP) 2.37, " Configuration Management Program". These documents define configuration control requirements and standards.

. Training of personnelin long-term configuration control standards and {

expectations.

. l Completing corrective actions which have been identified to date by the procedure reviews, self-assessments, topical area reviews and audits.

. Implementing the procedures which control vendor technical information.

. Implementing a process for the maintenance of Design Basis Summaries.

. Completing resolution of ACR 7007," Millstone Unit 1 FSAR inaccuracies" issues. These issues are generally applicable to Millstone Units 2 and 3 also. l Completing fullimplementation of the Engineering Assurance Program to include integration and trending of key internal and external engineering gg performance assessment infc mation.

(~) . Developing indicators to measure the effectiveness of the corrective actions on configuration control. (Currently, Condition Reports [CRs) are reviewed to assess configuration control performance.)

. Conducting periodic self-assessments and oversight of the configuration control activities and technical products:

Line to conduct self-assessments that include evaluation of configuration control effectiveness, Engineering Assurance group to conduct evaluations of engineering operations, and maintenance activities as they relate to configuration control, and Nuclear Oversight to conduct audits and surveillances of programs and processes impacting configuration management.

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34 l REMAINING ACTIONS r

. Complete the implementation of the CMP items to support unit restart.

l Implement NGP 2.37, Configuration Management Program, which will  ;

establish the objectives of integrated configuration documents, streamlined change control processes and improved data and document management tools.

Submit the final 10CFR50.54(f) letter which confirms that all CMP l activities are complete, including the Configuration Management Process l which will ensure that all future operational, maintenance and design activities are performed in accordance with the CMP.

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35 C REGULATORY PERFORMANCE ISSUE Need to improve regulatory performance at Millstone Station PROBLEM STATEMENT )

Declining performance trends in several areas including the following:

- Reportability determination backlogs,

- LER commitment management,

, - NOV corrective action effectiveness, and

- UFSAR accuracy and completeness.

l SUCCESS CRITERIA l

l License Amendment Requests for restart approved and implemented (KPI

~ developed) i

. NRC Significant items List closed (KPI developed)

. No open NRC commitments for restart (KPI developed)

PROGRESS s '

a

1. Confirmatory Order - Independent Corrective Action Verification Program i

NU formally notified the NRC of Unit 3 readiness for ICAVP on May 27, 1997 (on schedule). Unit 2 readiness for ICAVP is progressing; however, i the target completion date of June 30,1997 remains challenging.  !

Parsons Power has been conditionally approved as the ICAVP contractor for Unit 2. (See Appendix 3 for performance indicator information.)

2. Confirmatory Order - Independent Third-Party Overs.ight Program The Independent Third-Party Oversight Team (ITPOP), Little Harbor Consultants, Inc. (LHC) was conditionally approved by the NRC on April 7, I p 1997. LHC submitted their Oversight Plan to the NRC on May 2,1997.

V

36 LHC provided initial results of the ITPOP review of NU's Employee Concerns Comprehensive Plan on May 13,1997.

LHC conclusions are summarized below. Appendix 7 provides _LHC's complete May 13,1997 presentation, which concluded that:

The Comprehensive Plan provides an adequate approach for upgrading the Millstone Employee Concerns Program; The creation of an Independent Concerns Oversight Panel has the potential to accelerate progress toward achieving the Comprehensive Plan Goal; The Comprehensive Plan does not address the full scope of the 10/24/96 NRC Order; {

The Comprehensive Plan does not sufficiently address the normal  ;

programs for problem identification and resolution; and The Comprehensive Plan does not clearly identify criteria for i success or measurement techniques. j i

i

3. Confirmatory Action Letter - Operator Training The status of corrective actions to address Operator Training is provided in issues Section #8.

4. Reportability Deterrnination Backlog Reportability determination backlogs have been eliminated on all Units.

i

5. License Amendment Requests i License amenainent request submittal quality is generally satisfactory.

Schedule predictability continues to be a challenge as known submittal dates now extend through June on Unit 3 and July for Unit 2. (See Appendix 3 for performance indicator information). No proposed significant hazards considerations have been identified to date.

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37 The table below provides the status as of May 21,1997.

L' Unit 3 Unit 2 Total License Amendments 24 16 l Required for Restart l Number Submitted to the NRC 13 6 i

6. Response to April 16,199710 CFR 50.54(f) Request The initial 10 CFR 50.54(f) 45 day response for Units 2 and 3, and a partial response for Unit 1, are on schedule to be submitted by June 2, 1997.

7. Restart Assessment Plan Significant items List Significant items List (SIL) closure package schedule predictability and quality is consistently satisfactory. (See Appendix 3 for performance indicator information.)

The table below provides the status as of May 21,1997.

im Y -

Total Number SIL Unit 3 Unit 2 Closure Packages 205 41 Packages provided for NRC Review 19 11 ,

• Including some sub-division of SIL items.

8. Commitment Management  !

Schedules for providing SIL closure packages to the NRC have been established. There are currently no overdue commitments for restart on either Unit 3 or Unit 2. (See Appendix 3 for performance indicator information.)

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9. Licensee Event Reports tO

' V Licensee Event Reports made to the NRC are trending down for Unit 3 reflecting that the discovery effort is concluding. Through May 16,1997, Unit 3 has had 32 reportable events. Through May 16,1997, Unit 2 has had 17 reportable events. For both Units 3 and 2, historical events make up a significant fraction of the total.

Corrective Action Program improvements currently underway are expected to reduce reportable events over the next year.

(See Appendix 3 for performance indicater information.)

REMAINING ACTIONS

. Submit 10 CFR 50.54(f) 45-day updates and final response.

. Provide periodic submittal of FSAR/UFSAR changes.

Complete remaining restart-related license amendment requests. (See e Appendix 3 for performance indicator information)

. Support independent Corrective Action Verification Program.

. Support independent Third-Party Oversight Program.  !

. Provide response to Confirrnatory Action Letter for Operations Training.

. Establish organizational ownership and implement Commitment Management Program.

(3 G

39

. m 4

OPERATOR TRAINING V

ISSUE Operator training effectiveness was questioned based on Millstone Unit 1 NRC license examination failures.

)

l PROBLEM STATEMENT The operator licensing qualification issue was identified following the ,

examination failure (6 of the 7 candidates failed the Millstone Unit One I licensed operator upgrade (LOUT) class on December 2,1996).

SUCCESS CRITERIA

. Complete actions required by the IRT report and the Training Corrective Action Plan (CAP).

. A high degree of success is achieved with the Unit 3 initial license operator j

p'v fraining class which is scheduled for examination by the NRC in July 1997 PROGRESS 2

Millstone commissioned an Independent Review Team (IRT).

The Root Causes of this issue were identified by the IRT report on the 1997 )

Millstone Unit 1 License Operator Examination Failures were:

1) a lack of management oversight and accountability by management, supervisors, and staff; and

2) the Corrective Action Program was ineffective in resolving previously identified, long-standing issues.

As of May 30,1997,20 of the 60 Training CAP (33%) activities are complete.

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l 40 g Comoteted Activities include:

Leadership changes to revitalize training occurred on March 17,1997. A new Director, Nuclear Training Services, and a Training Recovery Manager were appointed to raise standards and strengthen the Nuclear Training Department. Both individuals were chosen based on his previous leadership and training management successes.

. The licensed operator requalification programs for each of the Millstone Units were assessed. The assessments identified some program deficiencies requiring corrective actions on two of the three units. Those programs were shut down for one week and program deficiencies corrected. The assessments then concluded that the programs were sound to continue.

The Self-Assessment capability of the Nuclear Training Department has been upgraded. A Self-Assessment Team for training has been established, directed by a manager reporting to the Director of Training.

The team has a core group of permanently-assigned training individuals.

Additional personnel, including line and training, will be assigned to the team to support assessments, as appropriate.

/^}

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The Chief Nuclear Officer issued his expectations concerning training oversight to the Nuclear staff.

The new Director, Nuclear Training Services issued his expectations concerning procedural compliance to the training staff.

An Executive Training Council (ETC) consisting of executive management and chaired by the Chief Nuclear Officer has been established and is meeting regularly.

. On May 15,1997, the three Unit Directors, the Recovery Officer - Nuclear Engineering and Support, and Senior Training management provided a summary of actions taken and planned with regard to operator training and readiness for restart, to the Region l Staff at King of Prussia, PA. The Unit Directors emphasized the following activities as keys to operator readiness:

p w/

41

1. The continuation of Licensed Operator Requalification Training,

(]

V which has been conducted on its normal schedule despite the extended plant outages.

2. Planned observations for licensed and non-licensed operators at operating and startup/ returning-from-outage plants of similar design.

3. Emphasis on raised standards, including the " Northeast Utilities Nuclear Safety Standards and Expectations"

4. Attention to the operating experience and command and control principles emphasized in INPO SOER 96-01, " Control Room Supervision, Operational Decision-Making, and Teamwork".

5. Focusing crews on startup evolutions and tasks during the requalification training cycle immediately preceding startup.

6. Increased use of industry experts to verify that the proper standards are in place.

. Performance indicators for such items as attendance, corrective action  ;

p plan items, and supervisor observations of training are being monitored C/ -

(See Appendix 3)

Work in Proo_ress:

The Training CAP is comprised of 60 activities and addresses the following key areas:

. Management oversight and accountability,

. Self-assessment and Corrective Action programs,

. Experience and Staffing,

. Maintenance of program and student records, l

. Training materials, and

. Complete necessary training to have operators ready to support restart and subsequent operations.

The CAP schedule calls for 59 of 60 activities to be complete by August 15,1997.

Completion of all activities is currently slightly ahead of schedule. The activity to finish the implementation of the Northeast Utilities Training Information Management System (NUTIMS) for an integrated records / qualification management system is to be completed by January 5,1998.

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/7 With respect to the March 7,1997 NRC issued Confirmatory Action Letter, it is O comprised of 9 activities. Current status of these activities is as follows:

1. Submit the complete corrective action plan, including a schedule for addressing each of the identified IRT weaknesses and a review of the extent of the problems and root causes for the training area to the NRC staff by April 2,1997. As part of the corrective action plan, clearly define roles and responsibilities for completing NRC Form 398.

[ COMPLETE]

2. Complete corrective actions for the Millstone Unit 1 LOIT/ LOUT (licensed operator initial / upgrade training) program prior to restarting respective classes. [IN PROGRESSJ

3. Complete corrective actions for Millstone Unit 2 LOIT program prior to restarting LOIT classes. [lN PROGRESSJ

4. Complete corrective actions for the Millstone Unit 3 LOIT/ LOUT program prior to NRC examinations of the current LOIT/ LOUT class.

[IN PROGRESSJ p 5. Conduct a thorough review of the Millstone Unit 3 LOIT program

(,1 -

against the accredited program requirements prior to submittal of the license applications to the NRC. [COMPLETEJ

6. Forward the scope of NRC Form 396 (medical certification) process review and its expected completion date for Millstone Units 1,2, and 3 and the Haddam Neck plant (HNP) by April 2,1997. [ COMPLETE]

7. Submit the results of HNP data reviews of LOIT/ LOUT findings to the NRC by April 2,1997. [ COMPLETE]

8. Submit the results of initial reviews of aciditional classes on all the units to the NRC by March 15,1997. [ COMPLETE]

9. Complete specific reviews of the HNP LORT (licensed operator requalification training) program by April 4,1997. [ COMPLETE]

(~s.,

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43 REMAINING ACTIONS

. Complete all Confirmatory Action Letter items required to support restart of Unit 3.

The effectiveness of the corrective actions taken will be monitored by internal and external organizations. An integrated schedule for the internal assessments is to be developed by June 15,1997.

Comprehensive plans are being developed by Training and Unit management to ensure that the Unit operations staff members are ready to support restart and subsequent operation.

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44 WORK CONTROL AND PLANNING O

ISSUE 4

Ineffective Work Control & Planning processes PROBLEM STATEMENT The work control process is excessively complex leading to worker frustration, ineffective work execution and the poor quality of work packages as evidenced by a high rate of packages rejected from the craft.

l SUCCESS CRITERIA O .

The backlog of system and equipment deficiencies has been reduced to industry standards. (KPI and goals developed)

Preventative Maintenance and surveillances are routinely completed as scheduled. (KPI developed)

At least 75% of the work is accomplished as scheduled. (KPI developed).

PROGRESS Work management processes have been established which can effectively control work activities in the plant. Improvement is still needed in simplifying the process and standardizing high quality work packages across the site and improving efficiency.

Several assessments of our present work processes have been performed, including specific self-assessments. These assessments show improvements over the last several months but further improvements are needed in most areas assessed.

. The Managers of the Work Control organizations for all Units now meet on a routine basis for the purpose of sharing strengths and lessons learned.

45

. 1 The number of AWO's completed on a weekly basis has improved over the first

. /^')

V quarter of 1997. The AWO backlog has not shown the same improvement primarily due to the discovery phase of all unit CMP's. (Refer to the associated KPis in Appendix 3.)

Improvements have been made to enhance the scheduling and work scope capabilities of the computerized AWO process. Further changes are in the test mode and will be implemented by August,1997.

Each unit has established a "Fix It Now Team" (Unit 2 terminology is " Work It Now"). These teams have dramatically improved the response to emergent issues which allowe Maintenance and instrument & Control personnel to focus on scheduled activities. They have completed the following maintenance tasks:

Unit 1, started 11/11/96, completed 1415 jobs as of 5/29/97, Unit 2, started 11/18/96, completed 1214 jobs as of 5/29/97, and Unit 3, started 12/01/96, completed 1501 jobs as of 5/29/97.

Retraining of Maintenance, I&C, and Work Planning personnel is being conducted in accordance with new lesson plans, and enhanced procedures.

This action has been completed on Unit 1, is underway presently on Unit 3, and is being prepared on Unit 2.

O G/ . Schedule discipline meetings have been instituted to focus the work force on current issues while raising the level of accountability among performers and support personnel.

REMAINING ACTIONS Upon completion of the recovery, return to use of 12 week rolling schedule, utilizing the work week manager process to control daily work, and a model of system windows based on PRA risk significance. (This process has been implemented, but is not currently in effect across the site, pending restart)

. Standardize the maintenance planning training, and turn it over to the Nuclear Training department so that new employees will be provided a consistent set of requirements and expectations.

. Develop focused restart schedules with appropriate work group buy-in, and then measure effectiveness.

, 46

• ~

l- Continue to improve work package quality, and develop a means to quantify the

) improvement.

j r .

l Develop a more standardized work package.

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47 Procedure Quality and Adherence ISSUE l The effectiveness of Millstone's Technical Procedure Quality and Adherence PROBLEM STATEMENT

Procedure quality and adherence have been long-standing and well-documented concerns.

SUCCESS CRITERIA l

. All procedure deficiencies required for restart are rescived. (KPI developed)

~ .

Procedure quality for new and revised procedures is acceptable. (KPl developed)

\ .

Instinces of not adhering to procedures are reduced to an acceptable level. (KPI developed) l PROGRESS Development of the following performance indicators have been initiated to determine if a negative trend exists relative to procedure quality that may warrant programmatic corrective action.

. During the second quarter of 1997, the Station Administrative Procedure Group will have a performance indicator program implemented to track and trend all changes or revisions to technical procedures made by each Department that is fully implemented in the Station Qualified Reviewer (SQR) Program. The program will track the types of technical and administrative deficiencies that are being corrected and the impact of the deficiencies on the piani. This information is entered when the change is initiated and will allow any negative trends to be quickly identified.

. In addition, the Station Administrative Procedure Group reviews level 1 and 2 Condition Reports which have cause codes relating to procedure deficiencies and trends those found to involve corrections to a technical procedure. Information is

1 l

48 tracked on the Department involved, the type of procedure deficiency identified and i

/3 whether the procedure was upgraded at the time. This information allows the l V reviewer to determine the comparative magnitude of procedure related Condition Reports per Unit and Department and if a negative trend has occurred that requires management attention.

In January 1997, substantial revisions were made to the Administrative Procedures to support implementation of the Station Qualified Reviewer Program which provides Departments with authority to approve new, changed or revised procedures or programs in lieu of PORC/SORC review and approval, if a Safety Evaluation is NOT required. This will reduce the administrative burden on PORC and SORC to review large numbers of procedures and allow the committees to focus on safety significant issues. Significant care was taken to ensure these processes accommodate the heightened responsibility that must be assumed during the SOR process. The SQR Program implemented qualification requirements for independent Reviewers, Cross-Discipline Reviewers and Procedure Screeners. (50.59 and Environmental Screens)

Five assessments have been performed on the Procedure Upgrade Project during the last three years. The more significant corrective actions from the assessments are as follows:

- Engineering has established a Vendor Tech Manual Action Plan to revise the A process for control of vendor information and conduct validation of Vendor V Tech Manuals and applicable plant procedures.

- Training was developed and provided covering the essentials of verification I activities. A qualification process for Independent Reviewers, Cross-Discipline Reviewers and Procedure Screeners was implemented. Guidance has been added to document development procedure on the selection of validation methods. l

- Guidance for conducting Engineering reviews and Nuclear Oversight reviews have been added to procedures, and enhancements were made to the Independent Review process. Qualification requirements were established for independent Reviewers, Cross-Discipline Reviewers and Procedure Screeners. Familiarization training was provided to hundreds of Millstone personnel.

. Unit 3 EOP/AOP upgrade has been completed. The Unit continues to maintain the network to incorporate feed back, design changes and updated Westinghouse Ownem Group (WOG) information.

. The Unit 3 EOP/AOP setpoint calculations have been revised and the appropriate proceduos are revised and will be effective in June 1997.

(o ,)

49 O

(V REMAINING ACTIONS

. Each Unit will complete the upgrade on its required remaining technical procedures before restart. This is being measured by Key Performance Indicators (see Appendix 3). As of April 1997, the procedures remaining were as follows:

- Unit 1 had 96 of 872 procedures which have not been upgraded;

- Unit 2 had 166 of 998 procedures which have not been upgraded;

- Unit 3 had 81 of 1247 procedures which have not been upgraded;

- Service Groups had 25 of 777 procedures which have not been upgraded; and

- Total procedures remaining are 368 out of 3894 or 9% left to upgrade.  !

l e The Centralized Unit Procedure Group recently established by Unit 2 will help determine if a centralized group is preferable to having each Department {

responsible for the long term procedure maintenance of its procedures to the standards established through the Procedure Upgrade Project.

. At Unit 3, most EOPs revised for Appendix R have been reviewed, and a major p portion of this project will go to PORC in mid-June for approval. Training will be V condu'ted c during the current cycle of LORT. Appendix R procedures will be in effect in July 1997.

. Unit 2 currently approved set of EOPs and the EOP support procedures are being revised to support unit restart. i e Unit 2 AOP upgrade has approximately 37 AOPs to be upgraded prior to unit restart (including approx. 25 Appendix R AOPs).

• Unit 2 Severe Accident Management Guidelines are under development and proceeding according to schedule.

• Reinforce management expectations on Procedure Compliance and ensure that it is periodically reinforced.

• Develop indicators that represent the number of Human Performance issues which j include procedure non-compliance with requirements outlined in company, station,  !

and department procedures.

i e Unit and Department Self-Assessments on Procedure Adherence are being performed on a periodic bases.

l

i 50 i

)

• Unresolved item Reports (UIR) or Open item Reports (OIR) using the Confiauration l Management Plan (CMP) are initiated for procedure discrepancies idenutied during t

the 50.54(f) reviews. Upon review by the Management Review Team, they are  !

either closed or converted to Action Requests and assigned to Departments within i the Units for closure. Any procedure deficiencies identified by the 50.54(f) or l

j System reviews that are restart items will be resolved prior to startup. The l procedures that need to be modified by unit restart are being tracked by each unit i as indicated in the Key Performance Indicators (see Appendix 3). i

• See the following trend data sheets for:

- Closed Condition Reports involving Deficient Technical Procedures (Millstone

[ Station, Unit 1, Unit 2 and Unit 3);

- Unit 1,2, and 3 Operations Department Condition Reports involving Deficient Technical Procedures; and j

- Significance Levels of Technical Procedure Deficiency Related Condition i Reports From January 1995 to March 1997. l 1

3 O

l

O Closed CRs involving Deficient Technical Procedures Total 10.

9.

, 8. Upgraded

$ {'- -+- No I 6. Ye s 4.

3.

z 2.

0  : ,

- . . , i Mar '96 Jun '96 Sep '96 Dec'96 Mar '96 Jun'96 Se p '96 Dec '96 M ar '97 Event Date As of March 31,1997 Total Number of Upgraded Procedures = 2457 Total Number of Non-Upgraded Procedures = 358 O

UNIT 1 10 .

Upgraded g .

--+- No

~

% 6. -e- Ye s 4.

3.

m 2.

O f [ hXf Nov '96 Dec '96 May'96 Jun '96 Sep '96 Nov '96 Dec'96 Jan'97 Mar '97 Event Date As of March 31,1997 Total Number of Unit 1 Upgraded Procedures = 776 Total Number of Unit 1 Non-Upgraded Procedures = 96 O

Closed CRs involving Deficient Technical Procedures O

UMT2 10 .

9.

8. _ Upgraded f% 7- -+- No 5l -e- Ye s j 4. '

E 3.

• 2 0  : -  ;

Msy '95 Jul '96 Sep '95 Nov '95 Jan'96 Mar '96 Aug '96 Jan'97 Event Date As of March 31,1997 Total Number of Unit 2 Upgraded Procedures = 831 Total Number of Unit 2 Non-Upgraded Procedures = 167

.s t

v UMT3 i

10 .  !

9.  ;

y o

f; _ Upgraded 6 + No 8

-aH-Yes J 3.

Mar '95 May'95 Nov '95 Fe b '96 Msy '96 Se p '96 Jan '97 Mar '97 Event Date As of March 31,1997 Total Number of Unit 3 Upgraded Procedures = 850 Total Number of Unit 3 Non-Upgraded Procedures = 95 O

Unit 1 Operation Department CRs involving Deficient Technical Procedure

O 10 .

9.

1 8.

I E 7. Upgraded u 4. --+- No

E s.

^ _._ y, ,

4-3.

2.

i 0 <? ?W

May '96 Se p '96 Nov'96 Dec '96 Jan '97

, Event Date i

j Unit 2 Operation Department CRs involving Deficient Technical Procedure I

! 10.

9.

1 8.

g y, , Upgraded u 6. -+- No 5

-e- Ye s i

53-

.. A A - -

0 '\$ 5  : 5 -5 5 May '96 Aug '96 Nov'M Jan '96 Mar '96 Oct '96 Event Date Unit 3 Operation Department CRs involving Deficient Technical Procedure 10.

&  !. Upgraded u

I ll 8

-+- No

--e- Ye s n[M Apr May Sep Dec

=

Feb Apr May Jun Sep Jan Feb

'96 '95 '95 '95 '96 '96 '96 'M '96 '97 '97 Event Date

l l

1 i

O Significance Levels of Technical Procedure Deficiency Related CRs From Jan 1995 to March 1997 l i

l 40 . ,

38 . '

34 . Unit 34 . ]

32 . g1 30 .

28 . G2 m 8- 7- 03 l g M.  ; -

u 22 .  ; a site 1 20 .

18 . - l l

16 . (

14 .

i z 12 .  ;

10 . .; 4

8. e 1

6. ,,_

4

4. . .

i a

, -  : l A B '

2 C Significance Levels 1

Significance Level 1 = 0 l Level Totals Level 2 = 2 O~ Level A = 1 Level B = 11 Level C = 63 Condition Report Process February 25,1997 - Present Level 1 - Significant Adverse Level A signficant or important adverse condition which is important to the degree that action to preclude recurrence is approprtate.

Level 2 - Adverse Condition An adverse attention which has increased management attention and interest but does not meet the criteria for a significant adverse condition.

Adverse Condition Report Process January 1995 - February 1997 Level A - Events or issues of such importance they deserve the immediate undivided attention of whatever resources are required to mitigate the consequences, determine the causes and implement at least sufficient interim corrective measures to prevent recurrence.

Level B Events or issues which are expected to occur infrequently but need to be minimized for the company to achieve its safety and business goals.

Level C - Events or issues which indicate programmatic weaknesses or adverse trends of non-consequential occurrences which if not corrected increases the probabilky that a consequential event will occur in the future.

O

55 EMERGENCY PLANNING i

)

ISSUE Reasonable assurance that the organization will appropriately respond to a Millstone emergency evant (Real or Simulated).

PROBLEM STATEMENT The radiological emergency exercise held at Haddam Neck in August 1996 identified weaknesses in the areas of emergency event classification & protective action recommendation formulation. These weaknesses were equally applicable to Millstone  !

Station in that they are founded upon the same procedures and training.

l l

SUCCESS CRITERIA: l l

Effective Emergency Planning organization as evidenced by a satisfactory response in

, the 1997 NRC graded Emergency Exercises.

PROGRESS The Root Cause of this issue was described in:

. ACR 96-0642,

. ACR 96-0910,

. ACR 96-0911,

. ACR 96-0988,

. Emergency Planning Root Cause Report, November 1996,

. ACR 97-0122, and

. NRC Inspection Report 50-213/96-07.

Comoleted Actions

. Provide Senior Management Expectations regarding the importance of radiological emergency activity in writing to all emergency response personnel; f%

U

56 Obtain Industry Experience in the use of NUMARC Emergency Action Levers (EAL's) to ascertain areas where clarification or additional information has b("s been found to be necessary or convenient for the users to assist in making proper emergency classifications; Conduct an Emergency Response Organization Job Task Analysis (JTA) to ensure design of tasks and functions at the appropriate levels of the response organization and clarify roles and resronsibilities where necessary; ,

Update Emergency Action Level Clarification Cocuments to include results of l industry improvements and suggestions from emergency responders; Redesign the Protective Action Recommendation Process (PAR's) to meet industry standards and the relevant aspects of NUREG 0654 Supplement 3 to support a less complex methodology for the emergency responders;

. l Design PAR Training Material to address the newly designed process.

Include State of Connecticut Department of Environmental Protection management, as recipients of the NU Protective Action Recommendation,in the new PAR process design; e

Establish a Self-Assessment program within the Emergency Planning Services Group by formulation and implementation of a department level procedure; Design a segment of Licensed Operator Requalification (LORT) to include radiological emergency activity such as classification, dose assessment, protective action recommendation formulation, and notification of offsite p authorities; V e Review the Millstone emergency response organization design and staffing to ensure proper structure, task assignment, and personnel assigned to positions; e Conduct classroom training and drill scenarios for the emergency response organization personnel; and

. Conduct Station Emergency Response drills and training.

Work in Progress

. Licensed Operator Requalification training for EP responsibilities;

• A self-assessment of the emergency response organization dose assessment capability; and

. Drills to measure effectiveness of procedure changes, training and staff performance scheduled for June 19 and August 7,1997.

(3 G

! 57 l

REMAINING ACTIONS Implement the capability to perform on-shift dose assessment;

. Complete Self-assessment of the effectiveness of corrective actions associated with Emergency Classification;

. Complete Self-assessment of the effectiveness of corrective actions associated with Protective Action Recommendations; and Complete Self-assessment of the Emergency Planning Maintenance Program.

- i l

l l

t i

t v

58 m  :

V HEALTH PHYSICS i l lSSUE

! Millstone Station has experienced Radiation Worker deficiencies.

1 PROBLEM STATEMENT

, These deficiencies primarily involve instances of workers entering radiation-controlled areas without specified dosimetry equipment (TLDs, and electronic dosimeters).

SUCCESS CRITERIA l Ensure compliance with regulations and company procedures with a low incidence of procedural violations. (KPI to be developed)

% ,/ '

PROGRESS This condition was identified by:

. Worker self-identification; e Condition Reports (CRs) written by Health Physics and line management;

. Nucler_r Oversight audits of Worker and Health Physics practices; e Management in the field observations; and

. NRC inspections (Region 1).

Note: Condition Report CR M1-97-1016 was written by the Management Review Team using RP-4 guidelines to document this adverse trend and initiate a Common Root Cause Assessment.

1 i b3

- - .- . - _ _ . - - - - - . - =__ _ _

F 59 Comoteted Actions Actions completed to date focused in five areas:

1. Documentation - The CR system is used to document infracSons of the dosimetry controls. The CR system has vastly lowered the threshold to report any deficient condition. The CR system's formalized processes are used to evaluate and trend this HP information across all Units. In the past, the station HP program rarely evaluated this information in such a comprehensive manner, nor has this information been subjected to review by the multi-discipline Management Review Team (MRT) process.

l

2. Training - The radiation worker training program has been upgraded to emphasize the importance of dosimetry issues. Health Physics technicians are l now assigned directly to the Training Department to give " practical factor" sessions to all incoming employees.

3. Communications - Articles have been written in the stations newspaper (To l

the Point) on this topic. Major departments on site have participated in Unit Standowns and received direct communication from HP and Station management on the importance of following HP procedures. Benchmarking d trips to other utilities have been conducted to see best industry practices in this area.

4. Personal Accountability - Standards have been articulated to workers on their responsibility as Radiation Workers. Discipline has been administered to individuals who have failed to comply with the Health Physics programs.

5. Challenge Reduction - Selected RCA entry / exit points have been eliminated.

The reduction of more RCA points in under evaluation. Additionally HP technicians act as " greeters" at selected RCA entry locations. A prototype RCA entry turnstile (similar to a subway turnstile) has been constructed and will be evaluated.

Work in Proaress

• A formal Root Cause team has been formed to evaluated problem areas in HP and Security;

. Engineering fixes incorporating one-way traffic turnstiles are being designed; e Multiple entry point stations are being evaluated for elimination; and

. Additional communications to the Millstone work force are being developed for station distribution.

f

J 60 1

IO REMAINING ACTIONS ig '

Complete the evaluations and implementation of " Actions in Progress"; l l .

Monitor performance and Corrective Action Trend reports; and  !

. Develop required KPls.

\

i I

l 1

l 1

i 1

]

i i

i lo i

k i

i Appendix 1 MILLSTONE LEADERSHIP TEAM i

i

}

l i ,

1 l

J

\O l

^

I i

i l

i a

i i

if O

Fig O 1 C)

Millstone Leadership Team .

Employee Concerns _

President &CEO _ Millstone Oversight Panel B.D. Kenpn NSAB Director, Special Controller-Projects Nuclear R.M. Kacich I.E. Canner I ,______

VP Nuclear Executive VP & 'lluman Resources l '

Nuclear l Oversight CNO l C.W. Grise/ l l Communication l D.M. Goebel N.S. Carns I,,,J;C,. Gors,ki ,,l l S.C.,B,aranski,,l MPI Recovery . MP2 Recovery MP3 Nac, Big A VP, Nuclear Ollicer Officer .- Vice President Work Senices J.P. Mcuwain M.L Bowling,Jr. M.ll. Brothers  : J.E. .

EC. Rothen thrector, Emphsyee Director,l' nit l' nit Ihrector . I'nitihm1or Ihrectos; %udear thm1or, lhmtor.

Concerns -

operations -

JA Pnce' G o. iticks -

Enginming -

NudcarSenices -

Startup E L Morgan P.D. Ilinnenkaanp M V. Bonacs TE Neveks L J. Theker Director, Audits & thrector, ihm1or, Pinsical Readness Ihrector, Eng. Ihrectot Nuc. Ihrector, Evaluation (Ading) -

Enpocenng -

Digmeenng(Acting) -

06cer ' -

Programs - Matenals & IhE -

form 1ive Actions RP Ruth J.M. Armstmng S K. Brinkman J P. McElwain S E.Scace Management MA unell 4 L PolM thmtor, Director, York thrector,n Regulatory Ihrectot thrector,lrfo.

Performance Eval. -

Management -

l' nit 5enices -

ReadinessOEicer -

Ntdear Trainmg -

Technology PM. Ridianison LA Ilarrison IIL Mdler - M.L Bowling,Jt RX lohannes RE. Prnulx thrector, Anahss Director, . Ihm1ot Config ihmtor, ihm1or Regulatory thrector,Centrads

- & Programs -

Maintenance /l&C -

Mgmt. Program -

Engineering -

dairs -

& Pmiect MgmL M R. Brown O.J.Becker RP. Need PE. Gros .n PA. Lofnis tc. Mahal <.a.i Director, . Ihrector; Support Senices -

Emergengliannmg R.M. Moore PJ. Stroup Key l On Loan from fY1D l l On loan tnwn ikke Ptmer l l On inan han VmD l lMa ,d, , [,)

io. - -t i i m,-m oncem i l on unniinn vanhec minne l May 1997

i O

1 Appendix 2 i

NU NUCLEAR SEVEN SUCCESS OBJECTIVES l

O .

O l I

1 >

O '

i SUCCESS OBJECTIVES i

Success Objective #1 That we are an organization with high standards and clear accountabilities, i

~

Success Objective #2 That we demonstrate a strong nuclear safety philosophy - evidenced by careful adherence to high nuclear safety standards and conservative decision making.

Success Objective #3 That there is effective self-assessment.

j p Success Objective #4

.g 4

That we have an effective corrective action process.

Success Objective #5 That licensing and design bases have been properly restored - with processes to ensure that they are properly maintained.

i Success Objective #6 That we have an environment that supports the identification and effective resolution of employee concerns.

Success Objective #7 That we are committed to achieve excellence in nuclear operations.

1 i

i i.

o 4

1 1

it j

i i

Appendix 3 f

4 i

, KEY PERFORMANCE INDICATORS

?,

J t

l 4

O I

i

?

I I

b l t I i

9 a

I i .

i t

i \

4 k

t i

(

1 i

L l 1 I j

i.

i i'

f i

i i

1 3

4

1O Index  !

Appendix 3 I l

Key Performance Indicators - Millstone Unit 3 - Pages A-1 through A-16  ;

l Key Performance Indicators - Millstone Unit 2 - Pages 1-16 i

l Key Performance Indicators - Oversight - Recovery Gap Chart

- Pages A-1/2, A-10/11/12, B2, D 1 t

Key Performance Indicators -

Employee Concerns Program )

- Pages E-1/3/4 l

- Completion Progress Curve Key Performance Indicators - Training - Corrective Action Plan

- Supervisor Observativos

- Attendance (No-Show) Notification l

I l

i 0

i i

i iO i

i f

l Appendix 3  !

, KEY PERFORMANCE INDICATORS 4

MILLSTONE UNIT 3 i l 6

I i

O .

l l

O

Indspandant Corrcctivo Action Vorification Program Roadinoco bT b

Millstone 3 - May 1997 Progress: The goal to be ready for IcA VP by May 27,1997 was achieved.

toos I 80 %

i ij =

Good f> 40% l

I

) O l Goal: Ready for J 20%  ! ICAVP - 5/27/97 Y l Achieved l o% I I I i l l I I I i l 4

Jan Feb Mar Apr May Jun Jd Aug Sep Oct Nov Dec l mlCAVP Remaining -e--Work Off! Goal !

1

Raw Dets Jan-97 Feb-97 Mar Q7 Apr-97 May 97 Jun-97 Jul 97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 l ICAVP Romairung 73% 61 % 43% 20% 0%

, t work ott/Goai 74 % ses 37% 19% o%

\

Dennition AnalysisfAction

This indicator measures progress in readiness for Independent Wave 1 CMP tasks, SSAs, and 50.54(f) Program Reviews Corrective Action Venfication Program (ICAVP). For MP3 this have been completed. ICAVP readiness date of May 27, consists of the following items for Wave I systems

1997 was achieved.

1. Configuration Management Plan (CMP) task completions The final May 27 readiness received Management and (weighted at 70%). Nuclear Oversight concurrence.

2. Maintenance Rule Group 1 System Specific Assessments (SSAs) - (weighted at 25%)

3. 50.54(f) Program Reviews (weighted at 5%)

CMP includes : CMP Punch List items plus Licensing Commitment Validation, FSAR Change Request submittals, Piping & Instrument Diagram Walk Downs, and Design Basis Summary comp;etions.

$$As assure: That documented license and design basis documents are correct; that systems are operated, maintained and tested in conformance with the license and design bases; and identified discrepancies will be resolved.

50.54ff) orocram reviews include: Programs such as High Energy Line Break Equipment Environmental Qualification, Electrical Separation, etc.

Gont Comments i The Unit 3 goal is to be ready for ICAVP by 5/27/97. YLitve 1 systems: Auxiliary Feedwater, Quench and b Recirculation Spray, Emergency Diesel Generators, Electrical Distribution, and Service Water.

MR Grouo 1 systems: those systems that are safety an1 risk significant.

Data Source: G Oosius X4232MP l AnalysJe ty: G Ooslus X4232MPl Owner: M H Brothers X43o3MP Page A 1

i 10CFR50.54(f) Rocdincoc for Submittal p Millstone 3 - May 1997 O progress: Submittal of this document to the NRC is on track to meet the 8/13/97 goal.

100 % -

4 10CFR50.54(f) I y gog . work remaining asf of 5/22/97 l c

3

+

l g 40% -

N Goal: Ready for 20% - 10CFR50.54(f) submitta!- 8/13/97 j Mi

• l I I I I I I I I I I

, Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1

M 50.54(f) Remaining f l Raw Dets :

JarF97 Feb-97 Mar-97 Apr 97 May-97 Jun-97 Jul-97 Aug-97 Sep 07 Oct-97 Nov 97 Dec-97 50 54(f) Remaining 0% 81 % 67% 49% 30 %

Work Oft / Goal j Definition Analysle/ Action This indicator measures progress in readiness for As of 5/22/97 CMP Punchlist is 77% complete, Group 10CFR50.54(f) submittal which is the NRC's 1 System SSAs are 50% complete. This results in requirement that management at each nuclear plant having 30% remaining to complete to be ready for verify in writing that the design and operation of their 10CFR50.54(f) submittal.

plants is consistent with what the NRC has approved, Progress towards completion of the work and that all changes and commitments since original necessary to allow the 10CFR50.54(f) letter licensing are properly reflected in current licensing submittal by 8/13/97 is on track, documents, such as the Final Safety Analysis Report (FSAR).

For MP3 this is made up of the:

1. Configuration Management Plan (CMP) task completion (weighted at 75%)

2. System Specific Assessment (SSA) completion (weighted at 25%).

The CMP task comoletion includes: CMP Punch List Goal items plus Licensing Commitment Validation, FSAR The Unit 3 goal is to be ready for 10CFR50.54(f)

Change Request submittals, Piping & Instrument submittal by 8/13/97.

Diagram Walk Downs, and Design Basis Summary completions.

The SSAs orovide: assurance that documented license and design basis documents are correct; documentttion Comments

[]

( /

supports the license and design bases; the system is being operated, maintained and tested in conformance Data through 5/22/97.

/ with the license and design bases; and identified discrepancies will be resolved.

Data Source: G. Closius l Arimlysis by: G Clostus X4232l Owner: M. H Brothers X4303 Page A-2

Tcak Complctionc Rcquired for Rootart Millstone 3 - May 1997 l Progress: This 90alis very challenging; management attention is being applied to reduce the Open category and improve the workoff rate of open tasks required for restart.

4500 4too 4__ Open tasks as of) 3500 5/19/97 l I Good I

3000 -

2500 120m Y Goal: Cornplete all 1000 restart tasks by 8/13/97 O

Jan Feb Mar Apr May Jun Jd Aug Sep Oct Nov Dec l Open (Restart) - Open (Undeterrnined) -s-Work Off/GoaI)

Raw Dats l

[N Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul 97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Open (Restarn 3059 3076 3489 3753 3717

(*

1 Open (Undeterminoch 438 353 )

Work Off/ Goal 3315 2393 1709 717 345 0 0 0 0 0 l Definition Analysle/ Action l The total number of tasks is defined as those requiring

• This indicator includes open items in the Action 1 closure prior to restart. Automated Work Orders (AWOs) Item Tracking and Trending System (AITTS), such as required for restart are not included, as they are tracked NRC Open items, Significant items List issues, and in a separate indicator. NOTE: the Open Condition Report (CR) corrective actions.

(Undetermined) category are those assignments that

• The number of tasks that must be completed  ;

are still being screened to determine whether they are prior to restart decreased slightly during the first l required for restart. two weeks in May.

. Increased management attention is being applied to this area to ensure that all tasks entered into AITTS are evaluated correctly to determine whether they are truly restart related tasks, or should be deferred until l after restart. Management attention is also being

]

directed toward completing restart-related tasks as scheduled and challenging requests for extensions to ensure that items that support restart are completed.

Goal Comments Goalis all completa pnor to 8/13/97. Data through 5/19/97.

D These tasks are tracked in Action item Tracking and s

V

/ Trending System (AITTS) and the P2 Schedule.

Automated Work Orders (AWOs) are not included.

Work off curve is based on a combination of AITTS due dates and P2 schedule dates.

Data Source: M R. Strout x2?99l Analysis by: B Pinkowitz x43o2l owner: M. H. Brothers x4303 Page A-3

Opon Condition Rcperto Millstone 3 - May 1997 70 GROSS: Condition Reports requiring corrective action are stillincreasing. Increased Management attention is being applied to this area to meet the restart goal.

2400 2200 Open CRs 2000 5/21/97 I8UO Good 1600 j1400 E 1200 s

$ 1000 g Open CRs >120j T days >

600 400 200 0 l I I l l l l l l l I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec l-5-CR's Not Closed (Total) CR's Not Closed (>120 Days) !

Raw Dets Jan-97 Feb-97 Mar 97 Apr-97 May-97 Jun-97 Jub97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 CR's Not Closed (Total) 1827 1921 2003 2086 2264 Level 1 141 153 166 176 189 Level 2 1686 1768 1837 1910 2075 CR's Not Closed (>120 Days) 1223 1173 1109 1104 1162 Level 1 83 81 74 72 95 Level 2 1140 1092 1035 1032 1067 Definition Analysia/ Action This indicator depicts the number of condition reports Significant attention has been focused on completing the (CRs) which have not had corrective actions implemented evaluation phase of recent and backlogged condition reports.

as CRs not Closed (Total), The number of these total This has resulted in a large number of corrective actions CRs which are over 120 days old and have not been being identified and tracked. Efforts are underway to deferred is depicted in the bar graph. review the identified corrective actions to ensure that they are properly scheduled and that redundancies are Condition Reports (CRs) are written to document eliminated.

degraded or non-conforming conditions associated with plant systems, structures or components necessary to support the generation of electricity.

Goal Comments

} The goal is to have all Level I Condition Reports closed Data through 5/21/97.

q by startup unless they have been reviewed by the Plant Operations Review Committee (PORC) and approved by a Unit Officer.

Dats Source: AITTS l Analysis by: S. M. Smith x2277MPl Owner: D. McCracken x0481 MP Page A-4 8_COHOPN XLS

Csndition Rcpsrt initiction and Evaluation Timclincso  !

Millstone 3 - May 1997 Progress: Steady improvement is being made in meeting goal of completing plant condition report evaluations and identifying appropriate corrective actions within 30 days. ,

1 1

500 450 400 e 350 300 Data Through l e 5/21/97 l g250 .

200 o 150 100 /

50 0 - - -

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec l E Total CRs initch"! E # Evaluations Completed 0 Cornpleted within 30 days !

Row Dets Jan-97 Feb-97 Mar-97 Apr-97 May 97 Jun-97 Jul-97 Aug47 Sep-97 Oct-97 Nov-97 Dec-97 Total CRs initiated 358 303 284 291 228

[

l Level 1 CRs initiated Level 2 and 3 CRs Irutsated 46 312 24 273 18 247 11 280 11 21',

1. Evaluations Completed 318 245 218 136 17 Completed within 30 days 79 92 91 88 NA Success Rate 0.22 0 31 0.37 0 52 NA Definition AnalysisfAction This indicator depicts the initiation of Condition Reports (CR) for NOTE: The success rate for April reflects the Unit and the number of evaluations which were not completing 99 of 190 evaluations which are over completed within the goal of 30 days. 30 days old as of 5/21/97.

The graph shows CR data beginning 1/1/97, and represents the initiation of CRs has declined since the beginning of current status / effectiveness of Corrective Action Initiatives. the year but remains above the 1996 monthly average. The reason for the decline can be attributed to the completion of major portions of the discovery phases for several recovery projects.

Slow improvement has been realized in completing evaluations within 30 days. Management attention has been focused in this area to enable the unit to complete a goal of having no evaluations over 30 days old by July 5,1997.

Gos! Commente

, Goal is to complete all evaluations and identify appropriate Data through 5/21/97.

[v ,/

\

h corrective actions within 30 days. Evaluations are considered open if they are either in an open status or a pending review status prior to l the approval of the corrective action plan. The latest month's data reflects the status to date.

Data Source: AITTS l Analysis by: S. M. Smith x2277MPl Owner: D McCracken x0481MP Page A-5

Candition R; port Msthod cf Diccovery l n Millstone 3 - May 1997 Progress: selfIdentification ofissues has improved significantly during the first part of l 1997.

l 100 90 80 Data Through 70 5/21/97 g 60

• 50 3

$ 40 30 20 -

10 0 - Q '- "

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug sep

'NSELF IDENTIFIED EINTERNAL OVERSIGHT DEXTERNAL OVERSIGHT DEVENT !

Raw Dek Oct-96 Nov-96 Dec-96 Jan-97 FetF97 Mar 97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Number of CR's Unit identified 103 122 169 297 268 256 252 215 Internal Oversight 22 13 48 36 25 25 29 14 Extemal Oversight 16 11 3 4 2 0 1 0 Event 36 23 20 20 8 1 8 0 g Total ldenhfied 177 169 240 357 303 282 290 229 8 i Dept Self ID Ratlos k Maintenance Operations 0 42 0 56 0 35 0 68 0.33 0 48 0 53 0.57 0 47 0 60 0 45 0 54 0 33 0.48 0 31 0.33 Work Planning 0 29 0.36 0.19 0.27 0.36 0.16 0 73 029 Destgn Eng 0 35 0 39 0.30 0 43 0 49 0 15 0.30 021 System Eng 0 27 0 38 0.21 0 26 0 42 0.34 0 24 0 42 Licensing 0.42 0 40 0 40 N/A 0.00 N/A N/A N/A DeHnition Analvels/Aedon This indicator represents the percentage of CR's identified by Self identification Of issues by Unit 3 has improved each of the barriers. CR's are categorized into the following significantly during the first part Of the year. One factor f0ur areas: influencing this was the large number Of CRs initiated by the disc 0very phase of the different rec 0very plans.

• Event Driven - Self-revealing, an event occurs. Increased emphasis on self assessment will help to

+ External Oversight - Identified by NRC, JUMA, INPO, etc. ensure that self identification Of issues remains high.

+ Internal Oversight - Identified by QAS, PORC, ISEG, NSAB, etc.

• Self - Supervisor Observation, document review, Self-checking, independent / dual verification, etc.

The department self identification ratios are a measure of the individual department's rate of identifying their own issues.

Dept Self 10 ratio =

number of CR's ID'd /assioned to that de0artment number of CR's assigned to that department l

Goal Commente

[\

}

/

Data through 5/21/97.

l %d Data Source: AITTS l AnalysJs by: S M Smith x2277MP l Owner: D McCracken x0481MP Page A-6

Open NRC Commitmonto for Rootart Millstone 3 - May 1997 J Progress: While the total number of open commitments to the NRC remains high, ,

we have reduced the number that are overdue with a goal of closing '

commitments on their due dates, and none open at restart.

350 300 250 Data through g 5/21/97 } Good 3

l l*

.t i I h150 8 '

100 50 0

, T = '

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

! M Open items - Overdue items -e-Work Off/ Goal l Raw Dets Jan-97 Feb-97 Mar-97 Apr-97 May 97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec 97 Os Open items Overdue items 243 0

237 3

224 23 284 10 324 0

l Work Off/ Goal 270 269 80 36 10 5 2 0 0 Definition Analysis! Action An NRC commitment is: As of 5/21/97,19 items have been closed this month.

However, new commitments requiring closure prior to

• written statement that is docketed. restart resulted in an increase in the number of open a verbal statement to take a specific action, agreed items. The number of overdue NRC items is zero, to by an officer. {

• requirement to take an action imposed by the NRC. To continue to focus management attention in this area, l the overdue NRC commitments and a two week look j The commitments counted here are those that need ahead have been included in the Unit 3 daily report i final closure with the NRC prior to restart of the unit. since 4/7/97. l l

0 i

1 p Gael- Comments i I NRC commitments closed on due dates prescribed Data through 5/21/97.

and all closed prior to restart Work Off/Goalis for end of month.

l Data Source: H. Kross x6666l Analysis by: D. Smnth x5840l Owner: D. Hwks x0326 Page A 7

Significant Itamo Liot p) 4 v

Millstone 3 - May 1997 Progress: closure ofitems on the Significant items List (including items identified by the NRC for closure prior to restart) ara on track for the 9/30/97 goal.

1 200 180 Data through

+' 5/21/97 160 140 as 120 Good l Goal: 4 items 80 Si remaining by 8/t3/97 j i7) 60 .

l Goal: allitems !

40 l complete by y 9/30/97 0 ' '

'E Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec i

M Total Remaining Work Off/ Goal !

Raw Dets Jan-97 Feb-97 Mar-97 Apr 97 May-97 Jun-97 JuF97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Total Remaining 59 55 43 189 178 Work Off/ Goal 55 45 191 177 121 74 4 0 O

i i

\ l Definition AnalyslalAction Items on the Significant items List include those The Significant items list was revised to include the Adverse Condition Reports (ACRs), Notices of items from the NRCs Restart Assessment Plan issued

Violation, Unresolved items, Escalated Enforcement on 3/24/97 which is reflected in the sharp increase in i Items, Licensee Event Reports, and programmatic April. A new work off curve was developed to reflect concems chosen by the NRC which require closure the completion schedule provided to the NRC on prior to start up. 4/29/97. Significant item List closure packages continue to be turned over to the NRC on schedule.

s Goal Comments Goal: 4 items remaining by 3/13/97 Data through 5/21/97.

Allitems closed by 9/30/97 A total of 205 closure packages have been requested by the NRC to date through revisions of the Readiness Assessment Plan (RAP) issued on 3/24/97 Data Source: J. Gonet x5505MP l Analysis by: J. Gonet x5505MP l Owner: D. Smith x5840MP Page A-8

1 Licancee Evcnt Rapsrto l A Millstone 3 - May 1997 .

( )  !

% / Progress: Ucensee Event Reports made to the NRC are trending down, '

reflecting that the discovery effort is concluding.

20 18 16 14 5 12 Good d

C. Data through l j8 5/21/97 { y 4 #

/

2 0 l I I l l l l l l l 1 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec LERs-Recent - LERs-Historical -+-industry Standard !

Raw Dets Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97

(' LERs-Recent 0 2 1 1 0

\ LERa-Histoncal 3 11 9 3 2 LER&YTD 3 16 26 30 32 Industry Standard 1 1 1 1 1 1 1 1 1 1 1 1 DeNnition Analysle/ Action Licensee Event Reports (LERs): Two LERs have been submitted in May. These LERs involved historicalissues, one related to the RSS

+ are reports made to the NRC pursuant to system design and the other related to the useof the 10CFR50.73 Main Steam Pressure Relief Bypass Valves.

+ are defined as historicalif the event did not occur within the last 12 months

+ are reported in the month of the submittal to the NRC Gont Comments Data through 5/21/97.

Os V)

Data Source: Licensing l Analysis by: D Smith x6840l Owner- D Smith x5840 Page A-9

Liconco Amandmsnt Rcquacts i

/' Millstone 3 - May 1997

(

Progress: The June 30 goal for submittal of all License Amendment Requests needing approvalprior to restart will be challenged by nine LARs.

28 24 LAR submittal data through 5/21/97 20 16 3 /

g12 8

4 0 I I I I I I I I I I I Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec LARs to be Submitted 'm LARs Submitted -e-Work-Off/ Goal !

RawData Jan-97 Feb 97 Mar-97 Apr-97 May-97 Jun-97 Juh97 Aug-97 sep 97 Oct-97 Nov-97 Dec-97 LARs to be Submitted 19 24 23 17 11

% LARs Submitted 0 0 0 7 6 I Work-Off/ Goal 19 24 23 17 8 0 Definition Analysia/ Action License Amendment Requests (LARs) are changes to The resolution of engineering issues is delaying the Technical Specifications or other license changes that submittal of 8 LARs. Daily review meetings are being are required for restart, and that must be submitted to conducted to monitor status of activities and expedite the NRC for approval. completion of the LARs. Additional ongoing engineering review may identify additional Technical Specifications that require revision.

Also, communications have been ongoing with the NRC staff to insure that the delays in filing the amendment requests do not significantly threaten the NRCs ability to support our restart schedule.

Goal Comments All LARs requiring .NRC review submitted by

• Data through 5/21/97 June 30,1997.

• Five Proposed Amendment Requests are in final review.

• Two r.re in Nuclear Safety Assessment Board review.

O\

• Two are in Plant Operations Review Committee review.

• Six are in Engineering review.

Data Source: G Papanc x2069l Analysis by: D. smuth x5840l Owner: D. str.3h x5840 Page A-10

Rootcrt Mcdificatiana Awciting implomantation A Millstone 3 - May 1997 '

0 Progress: completing design modifications required for restart by the al30/97 goal requires increased management attention.

180 160-140-

[ Restart Mod I 120 data through good a 5/21/97

.h 100 6 t

f5  : . .

1 y 80 [p Y l g  %) '. x .

l 60 M .

Goal: All

[5h modifications 40 g;

... complete 9/30/97 I4 '

O h 8 Jan Feb Mar Aor May Jun Jul Aug Sep Oct Nov Dec j E Mods Released to Field EMods Awaiting Engineenng j RawDets Jan-97 Feb-97 Mar-97 Apr-97 May-97 sep-97

[

p\ Mods Released to Field 20 29 21 Jun-97 Jul-97 Aug 97 Oct-97 Nov-97

^

( Mods Awaiting Engineenng 83 81 77 Total Mods Remaining 173 149 103 110 98 Work Off/ Goal Definition AnalyslalAction

The total number of outstanding modifications As of 5/21/97, the total number of design modifications identified as raquired prior to restart that have not is 259. Of these,98 are required to be implemented been turned over to Operations. prior to restart. This month

+ 10 modifications were completed in the field

• 6 modifications not requiring field implementation were completed by Engineering a 1 modification was deferred until after restart

• 4 new modifications were added

+ 1 moddication was re-evaluated from desired to required for restart Continued management attention is being applied to the proper screening of modifications required' desired for restart to ensure those required for restart are properly identified and scheduled for implementation.

Gon! Commente All start up related design modifications completed by Data through 5/21/97 9/30/97, (h

\

Cara Source: S. Sudigala x4204 l Analysis by: s. sudigata x4204l Owner: D. Hicks x0326 Page A-11

AWOc Rcquired for Rcstart Millstone 3 - May 1997 G Progress: The generation and completion of corrective maintenance work orders required for restart is high and currently does not support the restart timeline.

225o 2000- '.'

Work Order

) 1750  ;.

{ data through

~

R l 5/19/97 1500 - --

) ..

i Good 1250 -

1000 -

o ,

y 1

$ 750 -

4 O

Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec 4

' M MRAWO ~ Other AWO -+-MR AWO G0al Total AWO G0al)

Raw Data G Total AWO Backlog MR AWO Goal Total AWO Goal Jan-97 1637 350 500 Feb-97 2123 350 500 Mar-97 2170 350 500 Apr-97 2069 350 500 May-97 1996 350 500 Jun-97 350 500 Jul-97 350 500 Aug-97 350 500 Sep-97 350 500 Oct-97 350 500 Nov-97 350 500 Dec-97 350 500 MRAWO 1203 1400 1409 1354 1319 Other AWO 434 723 761 715 677 Definitfor AnoWels/ Action Automated Work Order (AWO) Backlog is the total The number of AWOs generated and completed number of corrective maintenance / condition driven (non- during the first three weeks of May have been less recurring) AWOs required or desired for restart. than expected. Although the backlog decreased, the net reduction this month does not support meeting the

. The total does not include: AWOs awaiting retest, in goal at start up. Approximately 275 AWOs will be closure, work planned for future outages, AWOs that added to the backlog for work on Motor Operated support field work already included in backlog (i.e. Valves, in order to meet start up goals, the net insulation, staging, etc.) and non-power block AWOs. reduction in backlog needs to be approximately 400 AWOs per month

. Safety significant systems are defined as Maintenance Rule risk and/or safety significant systems.

Goal Comments Goal < 500 total AWOs at start-up, less than 350 Data through 5/19/97.

Maintenance Rule risk and/or safety significant system Q AWOs at start up, and no AWOs that are required for restart at start up.

Datn Source: G. Rescek x2433 l Analysis by: R.Rothgeb xE241l Owner: R. B. Roy x5000 Page A 12

i Temporcry Modificctiona l Millstone 3 - May 1997 l O Progress: Temporary Modifications are being reduced. with the expectation or i

having only 5 in place at restart (goal !s less than 15).

l 60 Temp Mod data through f 40 Ak 5/21/97 Good i

= Y e

k20- Goal $15 5

s l

0 I i t i f f -- t - -- f -- - - - f l l -- - - - 1 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Temp Mods - Outage Support -a-Work-Off/ Goal Goal <15 {

Raw Dets Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97 Ternp Mods 48 45 46 38 35 Outage support 5 6 6 9 7

(, TotalInstalled 53 51 52 47 42 Work-Off/ Goal 52 52 51 44 35 22 15 11 4 Definition AnalysisfAction A temporary modification is a modification to plant The " projected work off" and " actual work off" curves design that is short-term in nature and not part of the are starting to diverge. The normal work planning permanent plant design c lange process, process does not expedite removal of the temporary modifications. Increase attention is being provided to Temporary Modificatims to permanent plant design are expedite the removal of the temporary modifications categorized here two ways: " Outage Support" are once they are no longer needed.

those directly tied to physical work to plant equipment in an outage condition, and " Temp Mods' are all Five Temporary Modifications are currently scheduled others, to remain installed after restart.

It is expected that the goal for this indicator will be met.

Goal Comments

<15 TMs installed at startup Data through 5/21/97 None greater than one cycle without Unit Officer approval.

Data Source: S. Stricker x5409l Anstysis by: S. Stricker x5409l Owner: G. Swider x5381 Page A-13

Control Room and Annunciator D0ficiancico Millstone 3 - May 1997 l

(]

%) Progress: Goal of fewer than 10 deficiencies should be met by June 30,1997.

35 rDeficiency data!

30 through l 4' 5/18/97 I e 25 20 G al: <10 by s June 30,1997 l

15 / l 3 # y 2 10 _ = = = = = =

I 5

1 j 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec M Total Deficiencies Work Off/ Goal i l Raw Data Jan-97 Feb-97 Mar-97 Apr 97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec 97 Total Deficiences 21 18 19 22 30

' work oft /coar 17 15 14 12 to 10 to 10 10 10 to Definition Analysis / Action Control room instruments, recorders, indicators, and Thirteen new items were added this month (through annunciators that function ir 1 properly that could affect 5/18). Based on the current schedule 14 of the the ability of the operators to monitor and control plant remaining items will be completed by 6/30/97.

conditions.

Of the 14 to be completed by 6/30/97,

• 2 have the field work complete and are waiting normal plant operating pressure and temperature for testing, a 7 are scheduled for work in May, and

• 5 are scheduled for work in June.

Goals Comments O g Fewer than 10 at startup. Data through 5/18/97 I Projected work off curve is based on less than 10

/

None greater than 6 months old without Unit Officer iterns by G/30/97.

approval. Work that is complete awaiting retest based on plant conditions will riot be included in the total.

Data Source: B Pamsh x0184l Analysis by: D Beachy x4980l Owner: R. B. Roy x5000 Page A 14

4 Oparctor Work Arounde )

Millstone 3 - May 1997

(

l %drogreSS: A workoff plan has been developed to support the goal of s 10.

45 40 35 i Work Around data ! I j j through 5/18/97 l Good

!- / 4

4 ll 0 lI lilI i I I I I I I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec j $ Operator Work Arounds -m- Work Off/ Goal !

4 Raw Data Jan-97 Fet> 97 Mar-97 Apr-97 May-97 Jun47 Jul-97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97

wrator Work Arounds 21 24 23 21 21

, lork Off/ Goal 20 17 15 13 10 10 10 10 I

Definition AnalyslalAction Operatur Work Arounds are conditions requiring an operator Some progress was made in the last month in the to work with equipment in a manner other than original design disposition of these deficiencies. Research on the

', which could: status of design changes and Engineering Work

, Requests continues, i 1. Potentially impact safe operation during a plant transient,

2. Potentially impose significant burden during normal operation,

3. Create nuisance condition due to recurring equipment j deficiency,

4. Distract an operator from noticing a recurring condition.

Goal Comments j Goal <10 Data through 5/18/97 1

q fJone greater than 6 months old without Unit Officer Work off curve reflects end of month goal, approval.

I l

Data Source: L Palone x4737 l Analysis Dy: L Palone x4737 l Owner: B. Pinkowitz x4203 l l

Page A-15

1 Proc;duro Rcvision Backlog i

(~ Millstone 3 - May 1997 i Progress: Procedure revision completion by the 8f13/97 goalis being challenged by the unavailability of Licensed Operator review resources.

I i

300 250

{ Data through l 200 5/21/97 l Good I i B i Y

100 Goal: complete i corrective actions by 8/13/97 g

=

~

0 '

t '

Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec l

! Other Procedures - PUP Procedures -*-PUP Work Off/G0al -e- Other Work Off/ Goal !

RawDets Jan-97 Feb-97 Mar-97 Apr-97 May 97 Jun-97 Jul-97 Aug-97 sep 97 Oct-97 Nov 97 Dec-97

[N

• Total Remaining 349 309 288 244 225 01her Procedures 251 213 198 162 149 pup Procedures 98 96 90 82 76 pup work Off/ Goal 0 94 78 59 43 27 8 0 Other Work Off/ Goat 240 208 169 131 101 70 36 0 DeNnklon Analysla/ Action Procedure Revision Backlog is the total number of new For non-PUP procedures, individual feedback items will l procedures or procedure revisions required or desired for be done as part of the procedure upgrade where l restart. PUP is the abbreviation for Procedure Upgrade applicable. This will minimize the number of times the l Program. procedure must be modified, reviewed, and approved. I Revisions are in progress, there should be a significant l decrease in the backlog in the next two weeks.

Operations is working primarily system operating procedures in order to complete PUP. These '

procedures include the system operating instructions j Comments and valve /electricalline ups.

Data through 5/21/97 The biggest barrier to completion of PUP for Work off curve is based on 100% complete by 8/13/97 Operations is Licensed Operator review support (Independent review, validation). When the training j cycle for the current Licensed Operator class is 1 Goal completed (2nd week of July), a portion of the class will be applied to this area. An additional resource from the p All open items have been reviewed and proper Station Procedure Group is now being used to put the i (( j\ cor7ective actions are completed prior to 8/13/97. remaining Operations procedures in the upgrade format so that the procedure is ready for operator review.

l Procedure reviews and the number of procedure revisions started have increased.

Data source: Departments l Analysis by: T. Kulterman x5421l Owner: B. Pinkowitz!R B. Roy Page A 16

4 i

1 5

i

)!

3 l

i i

1 I.

l Appendix 3 i

i.

i KEY PERFORMANCE INDICATORS i

MILLSTONE UNIT 2 4

l t

i f

J y.-

l l

)

l 1

h I

i i \

i i

i l

I s

ij l k

t 1

i i

)

i 4 .

l  !

i

Indopandant Correctivo Action m Verification Program Readiness j ) Millstone 2 - May 1997 l Progress: IcA VP readiness is progressing; however, the target completion date of l June 30,1997is chaIIenged.

i i

100 % -

j ICAVP work j

{

,' a 80 %

remaining as of l 5/9/97

.E l s

60 %

i j

e j

p Goal: Ready for Good 40%

g ICAVP - 6/30/97 l q L_. i j

i N i 20% y f

i i

E 0% l l l l l l 1 1 I I I i Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec l

l l  ! ICAVP Rernaining --e-W0rk Off/ Goal l i

R&W hin Jan-97 Feb-97 Mar-97 Apr 97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec 97

]

3 ICAVP Remaining 100 % 92% 82 % 65% 57%

Work Off/Goa! 100 % 90 % 70 % 45% 20 % 0%

l

Definition AnalyslefAction

! This indicator measures progress in completing the Most telling conclusion: Phase 1 graded system system reviews necessary prior to initiation of review started and progressed more slowly than i Independent Verification of Corrective Actions Program expected as structure was put into place. System (ICAVP). System review involves evaluation of design review teams are gaining on work-off goals as they and license basis documents for system and system become more skilled in meeting performance goals.

components for incorporation into procedures. 4 Why negative occurred: Project wrestled with )

questions over the depth of review to be applied in the  :

systems area.

)

Corrective action: U2 CMP has added more resources (i.e., professionals, hardware, and support staff), has forced greater focus on System Review Teams to reduce unproductive research or divergence from scope, and created specific task groups to tackle 1 discrete issues critical to maintaining schedule. l l

Goal Comments 1 Complete required system reviews prior to ICAVP start Upward adjustments were made since the last report l scheduled for June 30,1997. that reflect a more precise approach to % complete )

measurement. About 3 weeks behind the original June y ) 9 projection.

l I

Graph reflects data through 5/9/97.

Data source: W. Sawatzky x0016 l Ans/ysis by: W. Sawatzky x0016 l Owner: M. Ahern x5426 I Page1

1 i

i 10CFR50.54(f) Readiness for Submittal ,

Millstone 2 - May 1997 Progress: Submittal of this key final document to the NRC Is on track to be complete i

by 9/15/97.

i

) 100% _

i N .

! Data through I

\ 5/16/97 f l

[ Good p 60% j 3 y

$ g I 40%

4 I Goal: final

' submitta! by 20% 9/15/97 4

i i

! 0% l l l I I I I i 1 i Jan Feb Mar Apr May Jun Jul Aug Sep l

I

( 50.54(f) Readiness -El-Work Off/ Goal !

Raw Dets s Jan-97 Feb-97 Mar 97 Apr-97 May-97 Jun-97 Jul 97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 j 50 54(f) Readiness 100 % 98% 93% 90% 86%

1 Work Off/ Goal 100 % 95% 85% 70% 55% 40% 25% 10% 0%

l t

j DeNnition Analysis / Action a This indicator measures progress in readiness for The project started slowly as structure was put into

{ 10CFR50.54(f) submittal. U2 readiness for submittalis place and what was really needed underwent more

defined as System Review Packages (SRPs) complete precise definition. The performance curve j and approved for all Phase 1 and 2 Systems, along with demonstrates an accelerating closure rate on the work l graded reviews completed and documented for all Unit 2 off goal as the project becomes more skilled in meeting programs, performance goals.

l

The project wrestled with questions over the depth of l review to be applied in the systems area and breadth of scope of review questions regarding the number and depth of review for U2 programs.

U2 Configuration Management Program has added more resources (i.e., professionals, hardware, and support staff), has forced greater focus on System Review Teams to reduce unproductive research or divergence from scope, and created task groups to tackle specific issues critical to maintaining schedule.

Goal Comments The Unit 2 goalis to be ready for 10CFR50.G4(f) Data through 5/16/97. Reflects an upward adjustment submittal by 9/15/97. as more conservative statistical approaches were applied. The May data are hard figures. The April figure adjusted upward to correspond.

Dara Source: W. Sawatzky x0016l Analysis by: W. Sawatzky x0016l Owner: M. Ahern x5426 Page 2

Task Completions Required for Startup i Millstone 2 - May 1997 l Progress: As discovery continues, the tasks required for startup continue to increase. With additionalmanagement attention, this indicator will be back on the workoff curve by August. .

j 3000 j

! l Data through l

, 2500h 5/15/97 I

{

l Good q 2000 l

,1500 s g

w i

1000 L 1

l 500

! j l i o L__ _+_ . . . . .

.  : l Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

! M Open (Restart) IEEE Open (Undetermined) -m-Work-off Goal Raw Dets Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Open (Restart) 1655 1778 1866 2550 2708 3 pen (Undetermined) 135 149 Work-off Goal 2685 2485 2150 1849 1550 800 499 198 25 Definition AnalysisfAction The total number of tasks is defined as those requiring Task completions have been re-assessed for restart closure prior to restart. items in PMMS (AWOs) are not readiness applicability.

included. Undetermined are those assignments in AITTS that have not been screened as to required for restart.

Goni Comments The goal is to have all required tasks complete prior to Data through 5/15/97 g ., entering the applicable mode restraials.

DAf8 Source: G. L Alix x2200l Analysis by: S.V. Heard x5600l Owner: S.V. Heard x5600 Page 3

Open Condition Reports p)

( Millstone 2 - May 1997 Progress: condition reports have shown a silght increase in the total number that are open. This trend will turn and the expected number open >120 days willbe < 550 by the end of June.

1 2000 1600 t Good

. m g1200 e '

Total Open CRs asli of 5/15/97  !

! Y CRs open >120 0 4--

days as of 5/15/97 400 0 1 I I I i 1 I l l l l Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec l M CRs Open >120 Days -+--Total Open CRs }

Raw Data Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun 97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec.97 Total Open CRs 1335 1300 1255 1215 1258 CRs Open >120 Days 738 787 735 810 821 Definition Analysis / Action This indicator depicts the number of open condition The May (through 5/15/97) number of CRs open > 120 reports (CRs) and CRs open > 120 days. days is up slightly as we have concentrated on closure of Phase 2 system items, in the Corrective Actions Department (CAD) we have a population of between 150-200 CRs that are indicated as having all corrective actions complete and require only final review. We expect to meet our goal of less than 550 CRs open greater than 120 days by the end of June.

Goal Comments I

D k

w Data Source: G L. Alix x2200l Analysis by: S. V. Heard x5600l Owner: s. V. Heard x5600 Page 4

Cendition Hoport Initiation and Evcluction Timolinoss p Mllistone 2 - May 1997 i

N-}

Progress: The line departments continue to reduce the no zner at cas open >so

, days, the Corrective Action Department is not keeping pace with the increasedinput.

200 l

150 1

5 g 100 m

E Data Through f 50

/

5/27/97 i

0 ' ' '

Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec

. E Total CRs initiated ETotal Now Complete O Completed within 30 days l RawDets d

( Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97 Total CRs indsated 181 163 166 173 152 Level 1 C,Rs initiated 7 7 7 11 7 Level 2 and 3 CRs Indiated 174 156 159 162 145 Cornpleted within 30 days 31 53 36 25 24 I Total Now Complete 119 90 57 28 24 I

success Rate 171% 32 5% 21.7% 15.7% NA i Definition AnalyslalAction This indicator depicts the initiation of Condition Reports NOTE: April data for completed within 30 days (CRs) for the Unit and the number of evaluations which were (15.7%) reflects that 28 were successfully completed completed within the goal of 30 days. The center bar shows out of a total of 159 which have had 30 days elapse the number of CRs for whicn the investigations have been to date. The following breakdown shows the completed to date. distribution of CRs in open (investigation phase) and P2 (in CAD for review) status:

The graph shows CR data beginning 1/1/97, and represents the current status / effectiveness of Corrective Action Jan - 13 open / 49 CAD Initiatives. Feb - 17 open / 56 CAD Mar - 15 open / 94 CAD Apr - 51 open / 94 CAD Goal Comments Goal is to complete all evaluations and identify appropriate Evaluations are considered open if they are either in s corrective actions within 30 days, an open statas or a pending review status prior to the approval of the corrective action plan. The latest month's data reflects the status to date.

Data Source: G L. Alix x2200l Analysis by: s V. Heard x5600l Owner: s V. Heard x5600 Page 5

Condition Report Method of Discovery Millstone 2 - May 1997 l Progress: The positive trend at seitidentification continues 100 i

Data Through j 80 5/18/97

/

3 60 0

t 2 1

/ 40 20 '

0

' ' U' l 4 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec l E Self identified Einternal Oversight D External Oversight D Eventj RawDats Jan-97 Feb-97 Mar 97 Apr.97 May-97 Jun-97 Jul-97 Aug-97 Sep 97 Oct-97 Nov-97 Dec-97 h Self Identified 123 102 114 126 70

\ Internal Oversight 20 13 9 15 8 External Oversight 6 4 3 0 1 Event 16 9 6 7 6 Total ldentified 165 128 132 148 85 Definition Analysis / Action This indicator represents the percentage of CRs Condition reports continue to be self identified with one identified by each of the barriers. CRs are categorized extemal oversight CRs identified in the first two weeks into the following five areas: of May. Event driven CRs remain low at 6.

Event Driven - Self-revealing, an event occurs.

External Oversight - Identified by NRC, JUMA, )

INPO, etc.

Internal Oversight - Identified by OAS, PORC, ISEG, NSAB, etc.

Self identified - Supervisor observation, document review, Self-checking, independent / dual verification, I etc. l l

Goal Comments improvement continues O

Data Source: G L. Ahx x2200l Analysis by: S. V. Heard x 5600l Owner: S V. Heard x5600 Page 6

\

l l

1 Open NRC Commitments for Restart

h)

U Millstone 2 - May 1997 j Progress: No items have been overdue to the NRC this year. Closure ofitems is 1

on track for completion in September.

l 150 125 -

j I Data through ,

wq 5/16/97 )

'S e

I l O 50 Goal: all open items closed by restart l 4 25 4

Y 0 _

=

Jan Feb Mar Apr May Jun Jul Aug Ser. Oct Nov Dec 1

4 l M Open items EIEBOverdue items -e-Work Off/ Goal j Raw Dets l

Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97

( Open Iterns Overdue iterns 117 0

103 0

101 0

109 0

92 0

Work Off/ Goal 120 123 122 95 62 32 13 1 0 0 0 0 Definition AnalyslalAcdon An NRC Commitment is: These commitments consist of Unit 2 URis, IFis, LERs, Violations, and Docketed correspondence. The

• Any written statement that is docketed. total number has decreased by 17.

• Any verbal statement to take a specific action, agreed to by an officer.

• Any requirement to take an action imposed by the NRC.

The commitments counted here are those that need final closure with the NRC prior to restart of the unit.

Goal Comments NRC commitments closed on due dates prescribed Data through 5/16/97 m and all closed prior to restart.

Data Source: D. W. Perkins x 4604 l Analysis by: D W. Perkins x4604l Owner: R. Joshi x 2080 Page 7

Significant items List 4 \ Millstone 2 - May 1997

, b Progress: closure ofitems on the Significant Items List are on track for delivery 1 to the NRC by 8/15/97.

50

, Data through l l 5/15/97 l 40 Good i

a: 30 Y

! li l .h i y 20 Goal: allitems to;

P NRC by 8/15/97 i e 6 u i i 10 l

0 l I I I I I

! Mar Apr May Jun Jul Aug Sep l MTotal Remaining Work Off/ Goal I RawDate l j Mar 97 ' Apr-97 l May-97 Jun-97 Jul-97 Aug-97 Sep-97 l Total Rernaining 48 45 30 i

Work Off/ Goal 48 45 39 33 27 0 l Dennition AnalyslalAction l Items on the Significant items List include those items Closure packages for issues related to 11 SILs have

(48) chosen by the NRC which require closure prior to been submitted to the NRC for review. Closure start up. Of the 48 SILs,41 require closure packages to packages for 4 additional SILs have been partially l be submitted to the NRC. In May, the NRC determined completed.

I that 7 SILs did not require closure packages. The work 2 off/ goal line in the graph above has been revised as of l May to reflect the 41 SILs requiring closure packages.

1 i

i i

i Goel Comments Goal: All closure packages to NRC by 8A6/97.

O I

, Data Source: J. Resetar x5411l Analysis by: J Resetar x5411l Owner: R Joshi x2080 Page 8

Licensee Event Reports Millstone 2 - May 1997 w) Progress: Historical License Event Reports made to the NRC should have peaked in May with the completion of Phase 1 & 2 system discovery.

10 8

I Data through

. 5/16/97 4

g6 a

Ig_

Y>

O l El l l l l l l l l l Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

!ELERs-Recent BLERs-Historical {

R&W hie Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 LERs-Recent 0 1 0 0 0 LERs-Histoncal 0 3 2 3 8 LERs-YTD 0 4 6 9 17 Dennition Analyele/ Action Licensee Event Reports (LERs) are reports made Through May 16th, there have been 17 Reportable to the NRC pursuant to 10CFR50.73. Events year to date. Corrective Action Program improvements currently underway are expected to LERs are defined as historicalif the event did not reduce reportable events over the next year.

occur within the last 12 months.

LERs are reported in the month of the submittal to the NRC.

Goel Commente Data through 5/16/97 I I Osta Source: M. Ehredt x2142l Analysis by: M. Ehredt x2142l Owner: R. Joshi x2080 Page 9

Lic3nse Amendment Requests

[ Millstone 2 - May 1997 Progress

License Amendments are approximately one month behind original schedule.

1 20 15 Data through '

, S/16/97 Good gl

~

l 10 y i 15 Y

4 Submittal Schedule 5 one month behind l

Y 0  ; ' '

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec fM LARs To Be Submitted BEi3 LARs Submitted -e-Work-Off/ Goal i Raw Dets '

Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 1 Dec-97 (j LARs Submitted 2 1 1 1 1 LARs To Be Submitted 13 12 11 11 9 Work Off/ Goal 15 13 12 12 7 1 0 Definition i AnalyslalAction

License Amendment Requests (LARs) are changes to There has been one license amendment request Technical Specifications or other license changes that submitted to the NRC during the first two weeks of are needed for restart that are to be submitted to the May. Five license amendment requests were NRC for approval. scheduled for NRC submittal by 5/30/97. Delays are a result of additional analysis required by outside support and the sharing of intemal resources. The remaining LARs are required to be submitted to the

, NRC by 7/31/97.

1 l

i Goal Comments Receive NRC approval prior to restart. Data through 5/16/97

!, D i Data Source: R. Joshi x2080l Analysis by: R Joshix2080l Owner: R. Joshi x2080 Page 10

h Restart Modifications Awaiting implementation l Millstone 2 - May 1997 TOgreSS: Modifications are being released for work. The completion c? these modifications is a challenge.

120 Data through 100 g g  ;;yg 4_,

5/16/97 gj g gjj Goud

. 80 g g [ f j l

.! n gm

=

M

% 6 2

y Y Jtt f* M @

s IA 3)!' [

40 h  ;

(g f h

j h l Mods to be i l complete after l

);J si s!) Mi g?,

s l restart l 20 u

h a

kh hh $b g

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

! M Mods Released to Field BBBMods Awaiting Engineering -e-Work Off/ Goal j w Dets FetF97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Mods Released to Field 11 16 Mods Awainng Engineering 81 103 91 86 Total Mods Remaining 81 103 102 102 Work Off/ Goal ,

3 Dehnition , AnalyslalAction The total number of outstanding modifications identified The work off/ goal has been adjusted to refiect as required prior to restart that have not been turned scheduling changes resulting from design resources over to Operations. being shifted to support discovery issues and the preparation of new design / calculations to support the start of ICAVP.

l Goal Comments t

All start up related design modifications completed Data through 5/16/97 l Three mods to be completed after power ascension.

Data Source: M. Amadon x6249l Analysis by: M. Amadon x6249l Owner: W. Corbin x0626 Page 11

AWOa Roquircd for Rostert Millstone 2 - May 1997 (g) Progress: The generation and completion of corrective maintenanc l

required for restart is high and currently challenges the restart timeline. 1 1

2250 2000 -

Work Order 1750 A data through 1500 -

g} 5/27/97

., Good o

1250 - O h f h Es

• g* 4 4 5 1000 -

~

o Y

$ 750 -

500 - = = = = = = =

l 250 - I 0 l Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec l 4

i l l MR AWO *~ Other AWO -*-MR AWO Goal Total AWO Goal j Raw Dats

[N Jan-97 Feb-97 Mar 97 Apr 97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Total AWO Backlog 1348 1376 1434 1354 1461

,  % MR AWO Goal 200 200 200 200 200 200 200 200 200 200 200 200 Total AWO Goal 500 500 500 500 500 500 500 500 500 500 500 500 MRAWO 964 976 1031 940 1045 Other AWO 384 400 403 414 416 Definition AnalysisfAction Automated Work Order (AWO) Backlog is the total The Maintenance Rule Backlog remains stable as new number of corrective maintenance / condition driven AWOs continue to be generated through the discovery (non-recurring) AWOs required or desired for restart. process.

The total does not include: AWOs awaiting retest, Changes in process are being evaluated to increase in closure, work planned for future outages, AWOs that the through put of AWOs to provide an improving trend support field work already included in backlog (i.e. that will support goals established prior to restart.

insulation, staging, etc.) and non-power block AWOs.

• Safety significant systems are defined as

, Maintenance Rule risk and/or safety significant systems.

i Goal Comments Less than 200 MR AWOs and trending down prior to Data through S/27/97 l readiness for restart, s

4 l (

Omfa Source: R. Lally x4426l Analysis by: R.W. Poole x5338l Owner: S.J. Jordan x4292

, Page 12 i

Tamporary Modificctions C Millstone 2 - May 1997

(%

Progress: Temporary Modifications are being reduced, with the expectation of having only 10 in place at restart.

60 Temp. Mod.

data through j j 5/26/97

~ 40- OOOd l

!e Y 2

8,20-E

_ = = = ,

O I I I I I I i 1 1 I I Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Doc l Temp Mods -~ Outage Support -e-Work-Off/ Goal!

RawDate Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 Dec 97

/ Temp Mods 29 29 30 31 31 Outage support 21 21 19 18 17 v Totalinstalled 50 50 49 49 48 Work Off/ Goal 50 50 49 49 49 45 35 20 10 10 10 10 Definition Analysis / Action A temporary modification is a modification to plant There are 47 Temp Mods installed on the plant. One is design that is short-term in nature and not part of the an operator burden (BAST level indication nitrogen permanent plant design change process. supply monitoring was improved but not permanently repaired). The number of mods has been increasing as Temporary Modifications to permanent plant design are the outage continues. A review of the Engineering work categorized here two ways: " Outage Support" are list compared with the Temp Mod list showed a those directly tied to physical work to plant equipment dramatic reduction in the number to be installed by in an outage condition, and " Temp Mods' are all startup. While future developments may require others. Changes, current expectations call for fewer than 10 Temp Mods to remain installed at startup.

Goal Comments

<10 TMs installed at startup Temp. Mod. data through 5/26/97 None greater than one cycle without Unit Officer With the plant shutdown there are temp mods that are approval, required to support shutdown work. There are currently

)

'V seventeen temp mods for this purpose.

Data Source: W. Woolery x0698l Analysis by: W. Woolery x0698l Owner: M. J. Wilson x2081 Page 13

l Control Room and Annunciator Dsficiencias

! Millstone 2 - May 1997

%*rOgreSS; Goal of fewer than 10 deficiencies will be met by Sept. 30,1997.

a 60 l Deficiency data 50 through j # 5/26/97.

.I 40 good

.l j Goal < 10 by

] 30 g Sept. 30,1997.

l s* /

i 10 _

/ = = =

E O I I I I l l l t i i l

) Jan Feb Mar Apr May JLa Jul Aug Sep Oct Nov Dec l l Total Deficiencies -e-Work Off/ Goal l Raw Dets

. Jan-97 Feb-97 Mar-97 Apr 97 May 97 Jun 97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 otal Deficiencies 41 39 45 52 48 Work Off! Goal 52 42 32 22 12 10 10 10 10 1

j Definition Analysle/ Action Control room instruments, recorders, indicators, and The CRP Deficiency list is composed initially of Priority annunciators that function improperty that could affect 3 TRs. As such, the individual deficiencies do not post the ability of the operators to monitor and control plant an immediate challenge to safe operation. The concem conditions. is that the cumulative effect of many small deficiencies may cause a critical system to perform improperly in an emergency situation.

ronts Comments Goal < 10 by Sept. 30,1997. Deficiency data through 5/26/97.

()None greater than 6 months old without Unit Officer approval.

Data Source: W. Woolery x0698l Analysis by: W. Woolery x0698lCwner: M. J. Wilson x2081 Page 14

Oparator Work Arounds s Millstone 2 - May 1997 l j

aYOgreSS; A workoff plan has been developed to support the goal of s 10.

1 j

j d

f 45 i 40 l Work Around data j 35 / through 5/26/97 0

f j30 2 l

}' < 25 w r

t! T

$20 o

h

] 10 _ = = = =

j S i

0 l l l 1 l l l l t i I l

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

)

l

^

Operator Work Arounds -e- Work Off/ Goal !

l l Rawonta 1 f Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 2erator Work Arounds 43 39 41 42 41

,!ork Off/ Goal 41 35 29 23 17 10 10 10 10 10 l l l l Definition AnalysisfAcdon i Operator Work Arounds are conditions requiring an operator Repairs are being made and the 16 Operator burdens j to work with equipment in a manner other than original design chosen to be removed are starting to be cleared. The which could: population of items that will remain after startup is being

] reviewed for aggregate and individual impact on the j 1. Potentially impact safe operation during a plant transient plant operators. New items will be evaluated as they j

2. Potentially impose significant burden during normal make the list. l l operation l l 3. Create nuisance condition due to recurring equipment

! deficiency

{ 4. Distract an operator from noticing a recurring condition I

i l

i i

Goal Comments j Goal < 10 Work Around data through 5/26/97 1

i N Work off curve reflects end of month goal.

3 \ one greater than 6 months old without Unit Officer approval.

V Data Source: W Woolery x0698l Analysis by: W. Woolery x0698l owner: M.J. Wilson x2081 Page 15

i Pracaduro Rovicion Bccklog p Millstone 2 - May 1997 O Progress: Procedure revisions are a challenge to be completed prior to restart.

Additional resources and management attention is being appIIed. l 300 250  !

, Data through I 200 5/16/97 Good g -

Goal: complete l

] 150 j l g corrective actions y l

' I 100 -

lby restart 50

. M 0 l l l l l l l l l l l ,

Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec I

! Restart Req'd Proc. Rev. M PUP Restart Req'd Work Off/ Goal -e- PUP Work Off/Goalj RawDets l

Jan-97 Feb-97 Mar-97 Apr 97 May-97 Jun 97 Jul-97 Aug-97 sep-97 Oct-97 Nov-97 Dec-97 e Total Rernaining 268 270 269 257 246

[ 4 Restart Req'd Proc.

k Rev. 88 102 116 108 102 PUP 180 168 153 149 144 Restart Reg'd Work Ofi/ Goal 94 106 115 103 90 86 77 64 60 0 0 0 PUP Work Off! Goal 210 190 i 150 120 100 70 50 35 10 0 0 0 Definition AnalystalAction l

Procedure Revision Backlog is the total number of new One hundred fifty deficient procedures have been procedures or procedure revisions required or desired for identified to date. The majority are EOP revisions and l l

restart. AOP development and upgrades. The remaining are Millstone Procedure Upgrade Project (PUP)(Phase Ill) . actual deficiencies which are identified as needed for Upgrade the Technical Procedures at Millstone Station to restart. This UPI is expected to have constant input of a Standardized Writer's Guide and Verification and newly identified procedure deficiencies, still with the Validation (V&V) Process. The goal of PUP is to improve goal of completion before restart.

the technical quality and usability (human factors) of procedures; this will reduce human errors and enhance PUP is 89% complete. The Centralized Procedure

plant reliability by supporting quality of work. Group (CPG) is continuing to work down the number of 4

procedures not yet upgraded.

Comments i Data through 5/16/97 Goal All restart required procedure revisions and PUP y requirements have been reviewed and proper corrective

( actions have been taken prior to restart.

Data Source: W.J ChaNant x6416 l Analysis by: W R Watson x6245l Owner: H L. Miller x0474 Page 16

4 1

i

! ,:c.

ri i

t

}

l i

i 4

i i Appendix 3 4

l KEY PERFORMANCE INDICATORS - OVERSIGHT i

i ,

l i

l 4

i l

i 6

i i

i 4

4 l 1

1 i,

i 4

4 1

4 1

1

}

i l

i t~

f i

3 4

W 4

4 4

i Milletona Overcight Recovery Gap Chart April 1997 Progress: Progress is being made in all areas. Outstanding recovery plan items continue to be an issue. Management attention is being focused on problem areas.

100 % -

90% ,

80 %

70 %

60%

50 %

40%

30 %

20 %

10%

0%

Staffing Procedures Recovery Audits Survs Self AITTS Plan Assess-rnents f 5 Actual NGoal l

Raw Dets .-

Apr 97 May-97 Jurw97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar 98

• taffing - Actual 121 s staffing - Goal 134 Procedures - Actual 23 Procedures - Goel 31 Recovery Plan- Actual 88 Recovery Plan - Gcd 110 Audits- Actual 2 Audits -Goal 2 5 7 5 4 5 7 5 0 Surveillances - Actual 18 Surveillances - Goal 34 Self Assessments - Actual

• NA NA NA NA NA NA Self Assessments - Goal

• NA NA 9 NA NA 8 NA NA 6 AlTTS Current Actual 159 AITTS Current - Goal 206 Definition Analyela/ Action This indcator rneasures progress in Millstone Oversight Recovery, The two bars measure actual percentage vs. the goal,

• Self Assessment goals set by the quarter.

\ Goel Comments l

Data source: l Analysis by: V. Papadopoll x6245 Owner: D Goebel B_ GAPS.XLS

Millctsno Ovarcight AITTS Accignmcnto April 1997 A

Progres8: Outstanding items are being addressed by all organizations. Work off curves are being utilized to track Individual group efforts.

250 200 150 Good 100

~

g o i I I i i i t i l i i Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec J .n

[NOverdue BCurrent l ROW Dets F eb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct 97 Nov-97 Dec-97 Jan-98 Overdue 41 58 47

[ j Current 130 155 159 5

3

) Tote.1 NRC Commitments 171 4

213 17 206 4

Unit Restart items 105 114 119 Definition Analysis /Actiott Displayed are the number of A/R assignments for the Nuclear Breakdown of April data by Department:

Oversight Organization at Millstone in the Action item Traciang Overdue / Total and Trending System (AITTS). Both overdue and total VP O/4 assignments are shown.

Assignments made to Oversight groups that are designated as PE 38/156 commitments to the NRC (assignment type:CATC in AITTS) are ECP 0/3 listed in the table, as well as assignmen,s made to Oversight A&P 8/28 groups that the Millstone units have designated as necessary to A&E 1/15 be completed for their unit restart.

Data is based on all Millstone Oversight alert groups.

Gael Conunents (N Goal: No overdt'e items. Any tems detwmined to require resolution prior to key events (ICAVP, OSTI or mode changes) item due dates are being screened to determine any which

('s require resolution pnor to key events, such as ICAVP, OSTI, or are completed in a timely manner, mode changes.

Osta Sourcer M Baldini x4456 l Analysts by: V. Papadopoil x5245l Owner: O Goebel Page At B_AITTS XLS

Millatena Ovcraight Rscsvary Picn <

/m Action itsm Werk Off Curva

) May 1997 (V Progress: Oversight is behind schedule in completing Recovery Plan items.

Corrective measures are being taken to reduce overdue items.

M -'- -

A d

1 100[ * ; ^-

; . i d so 60

$* 20 0 . . . . . . . . . . , . . . . . . . . . . . . . . . . . : -;;

s s s s s s s s s s s s s ~

gg$$fggg s s s s oe gg

:  ; g*g_ISE@S{SlS$$ggsaeseel]Slgsal88l$

-g -

3s a a s ss l-e-Cu rent Schedule Actual Completion Progress j )

l New Date Remaining items 2/197 2/8/97 2/15/97 2/22/97 3/1/97 3/8/97 3/15/97 3/22/97 3/29/97 4/5/97 5/8/97 5/23/97 1 gg Actual 101 100 99 99 97 96 96 90 77 60 52 52

/ Current Schedule 96 91 02 92 77 77 70 68 67 25 21 15 Schedule Vanance 0 0 0 0 0 0 0 0 0 35 31 37 DsHiorn Aranlysin/Ac6ern This chart displays the work off curve for the action items in Weekly VP/ Director meetings are conducted to review plan

, the Nuclear Oversight Recovery Plan. Depicted are the status and to implement corrective action. Management current schedule. believes the plan schedule will be recovered and that Nuclear Oversight will not impact unit readiness for restart.

The majority of Oversight intemal process improvements were scheduled to be complete by 3/31/97. Four such initiatives slipped beyond that date, which account for most of the overdue action items. Corrective action underway is expected to bring three of these issues to closure by 4/18/97. Due to the significant scope of the license commitment review, this activity is rescheduled to be complete by 6/30/97.

Goal Commeens

The goal is to close out the Recovery Plan items in Thirty-seven action items are overdue as of 5/23/97.

accordance with the approved schedule.

Data Source: T. Houghton no270 l Analys/s by V.Papadopolir5245 l Owner- D. Goebel Page A2 B_RECOV.XLS

Statua cf Ovcraight Canditicn R psrto Millstone 1 - April 1997 tr)

i V Progress: Level 1 and 2 backlogs are not changing to meet goal expectations. Many ,

CRs remain open.

150 100 Good 50 Y

o l I I l l I I I I I I l l l Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr l ELevel 1 Open E Level 2 Open OLevel3 Open ]

newonta Feb-9'1 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97 Jan-98

% Total CRs 164 181 205 Open 125 135 133 f

'sj L1/>30 days 11/10 11/10 10/9 L2/>30 days 114/102 120/113 118/96 L3/>30 days 0/o 4/o 5/4 Dehnition AnalyslalAction This graph displays the status of Condition Reports (CRs) initiated by Nuclear Oversight for adverse, discrepant, or other conditions needing improvement ,

Open - Condition has been identified. The evaluation for reportability and operability, failure mode and/or root cause has not been performed, or, has been performed, but not yet approved.

Resolved - Condition has an accepted solution, a clear owner, a commitment for completion and a corrective action date and plan. The corrective action has not been completed by the unit.

Overall evaluation of the unit based on this KPl is as follows:

SAT (Green) No Level 1 or Level 2 CRs open > 30 days without an approved corrective action plan.

UNSAT (Red) Any Level 1 CR open > 30 days w;thout an approved corrective action plan.

MARGINAL (Yellow) No Leve! 1 CR open > 30 days but a Level 2 CR open >30 days witnout an approved corrective action plan.

/

rm \ ' Qqgj No Level 1 or 2 CRs open > 30 days.

I f

Data Source: M Baldinix4456 l Anafysis by: V. Papadopoli x5245l Owner: D.Goebel Page A10 B_OVCR.XLS

Stctuo of Ovcreight Crnditien R': porta Millstone 2- April 1997

("'\

"\j Progress: eacklogs continue to increase. Many items remain open with the majority over 30 days old.

150 100 Good 0 I I I l I l i 1- 1 I I l I I Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr l E Level i Open E Level 2 Open Clevel 3 Open l Raw Dets Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep 97 Oct-97 Nov-97 Dec-97 Jan-98 O Total CRs 87 95 107 1 g

\v} Open L1/>30 days L2/>30 days 60 2/1 Sa'51 65 2/2 63/58 76 2/2 68/59 L3/>30 days o/o o/o 6/1 Dennition Analysle/ Action This graph displays the status of Condition Reports (CRs) initiated by Nuclear Oversight for adverse, discrepant, or other conditions needing improvement .

Open Condition has been identified. The evaluation for reportability and operability, failure mode and/or root cause has not been performed, or, has been performed, but not yet approved.

Resolved - Condition has an accepted solution, a clear owner, a commitment for completion and a corrective action date and plan. The corrective action has not been completed by the unit.

Overall evaluation of the unit based on this KPI is as follows:

SAT (Green) No Level 1 or Level 2 CRs open > 30 days without an approved corrective action plan.

UNSAT (Red) Any Level 1 CR open > 30 days without an approved corrective action plan.

MARGINAL (Yellow) No Level 1 CR open > 30 days but a Level 2 CR open >30 days without an approved corrective action plan.

Goal - Commente (v j No Level 1 or 2 CRs open > 30 days.

Data Source: M. Bakhni x4456 l Analysis by: V. Papadopoli x5245l Owner: D Goebel Page A11 B_OVCR.XLS

Stctus cf Ovarcight Canditisn Rcparto Millstone 3 - April 1997 I fh l

~

Progress: Some progress is evident In reducing overall numbers ofissues. Many still.Tm& : pen > 30 days which does not meet goal expectations.

l 150 ,

l 100 Good I 1

SO j

I li I

O I I I I I I I I I I I l l l l Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr

! ELevel 1 Open E Level 2 Open DLevel 3 Open l I Raw Dets Feb-97 Mar-97 Apr 97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97 Jan-98

[N Total CRs 152 179 200 Open 99 f ) 96 109 j

\d L1/>30 days 11/5 15/11 11/10 L2/>30 days 85/63 93/85 86/60 LT>30 days o/o to W1 Definition AnalyslalAction This graph displays the status of Condition Reports (CRs) initiated by Nuclear Oversight for adverse, discrepant, or other i conditions needing improvement .  !

Open - Condition has been identified. The evaluation for reportability and operability, failure mode and/or root cause has not been performed, or, has been performed, but not yet approved.

Resolved - Condition has an accepted solution, a clear owner, a commitment for completion and a corrective action date and plan. The corrective action has not been completed by the unit.

Overall evaluation of the unit based on this KPI is as follows:

SAT (Green) No Level 1 or Level 2 CRs open > 30 days without an approved corrective action plan.

UNSAT (Red) Any Level 1 CR open > 30 days without an approved corrective action plan.

MARGIN AL (Yellow) No Level 1 CR open > 30 day 1 but a Level 2 CR open >30 days without an approved ce rective action plan.

D Goal Comments I

(v No Level 1 or 2 CRs open > 30 days.

Dats Source: M Baldanix4456 l Analysis by: V Papadopoli x5245l Owner: D Goebel Page A12 B_OVCR XLS

Millstona OvGreight Audit Schsdula Adharanca April 1997 O Progress: Audits are on track and schedule adherence has been exceIIent.

10 9

8 II 6b 5 Good n

3L I

2 1

0 I I I I I I I I I I I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec M Audits Performed Audits Scheduled l Rsw Dats Jan-97 Feb-97 Mar 97 Apr-97 May-97 Jun-97 Jul 97 Aug-97 Sep-97 Oct-97 Nov47 Dec-97 Q Audits Scheduled 2 4 4 2 5 7 5 4 5 7 5 0 Audits Performed 2 4 4 2

)

L/

DeHnition AnalyeWAction This charts depicts the schedule adherence of Oversight Audits at Millstone Station. The audit schedule for the year was approved in January,1997. The audit is considered performed when the exit occurred.

Goal Commente

( Goal: Perform all audits as scheduled. Corrective Action audits for each unit were combined into

(' one audit. See memo AE 97-4020 dated 4/7/97 Data Source: B Kaufman x2246 l Analyshn Ly: B Kaufman x2246l Owner: _

Page B2 B . DIT.XLS

Millatcna Ovarcight Survcillenco Schadulo Adharanco April 1997 (GProgress: Schedule adherence has been below goallevels due to emerging work.

Overall surveillance philosophies have changed to reflect a quick turnaround for field observations.

40 30 20 10 0 '

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

~~ Scheduled Surveillances Performed Unscheduled Performed

-*-Surveillances Scheduled )! _

RawDets 1 Jan-07 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Sury Scheduled 22 16 19 34 Surv Performed (sched) 9 9 12 18 Periormed (unscheduled) 14 12 11 17 Performed / Scheduled by Unit:

L5it 1 5/6 2/7 7/8 6/11 Unit 2 2/12 3/4 2/4 7/17 Und 3 2/4 4/5 3/7 6/6 Definition AnalvelalAction This chart depicts the Oversight surveillance scheduled and the Surveillances were not formally scheduled at Millstone number of them performed. The table shows the breakdown of the until Nov.,1996. The numbers indicate that 56%of the scheduled surveillances performed vs. those scheduled by unit. It scheduled surveillances were performed in February.

also shows the total number of unscheduled surveillances There are several reasons not all surveillances were performed.

performed as planned. Several surveillances were performed on emergent issues. The 1996 surveillances were scheduled to take one week for unit specific surveillances and 2 weeks for multi-unit surveillances.

Experience indicates this is not currently achievable or desirable, in 1997 unit specific surveillances are scheduled to take 2 weeks and multi-unit 3 weeks.

March surveillances did not meet the NU goal , although overallimprovement was noted. The 4 week "look ahead" recently implemented should improve schedule adherence.

Gon! Comments

, Preliminary goalis 100% schedule adherence. As of May 1,1997 April data:

surveillances will be performed within 2 days- Scheduled Unscheduled (Performed)

Und1 6 8 Unit 2 7 5 Unit 3 5 4 Data Source: L Borek x3o86 l Analysis by: L Bozek x3086l Owner: P. Richardson x4302 Page D1 B_SuRV.XLS

i i

!O 1

i c

! Appendix 3

! KEY PERFORMANCE INDICATORS - EMPLOYEE

j. CONCERNS PROGRAM l

i b

l

'O .

j O

i Nucloor Empicyco Concerns Program Progroec Millstone /CY - April 1997

!O hr0gYOSS: Employees are making more use of the ECP which is viewed as a positive indicatorof theirconfidencein thatprogram.

1 45 40 35 NOTE: No Resolved / Overdue During Dec. Jan. Feb. Mar.

30 25 . . .

l 15 0 l i I I l'NEEL-Dec Jan Feb Mar Apr I muss Rec'd Resolved (This Month) Total Resolved /Pending Closure N Resolved / Overdue --e--Total Unresolved  !

RawDets i 19 %-1997 Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov I

Received 6 8 12 14 28 i Rate / Year 72 96 144 168 336 lesolved 11 23 13 11 21 Unresolved < 45 Days 12 4 12 16 20 Unresolved 45-90 Days 6 4 2 5 10 Unresolved >90 Days 20 15 8 4 2 j Total Unresolved 38 23 22 25 32 Resolve &Pending Closure 16 28 32 45 Resolve & Overdue l 0 0 0 1 i NOTE: Data listed through 4/30/97.

Dennition AnalvelalAction The ECP receives, and attempts to resolve, concems which are both As of 4SO/97, 32 concem issues are unresolved. April new receipts directly safety related and non-safety related This data reflects both types nearly doubled over March Based upon the current filings. ECP can i of concems. expect to receive well over 100 concems during 1997. Additional j contractor statt began work on 2/3/97 to reduce the backlog The Beginning January 1,1997 the Employee Concems Program introduced use of expanded staff has allowed the ECP to process the sharp

" Resolved

• as a category of concem status. To meet this condition a increase in concems while rnanntaining a nearty unchanged backlog.

concem must have an accepted solution, a clear owner, a material commitment for completion and a corrective action completion date and plan. The data in this table reflects lhes new definition.

Beginning with February data. ECP is plotting the number of Resolved But Unclosed concems as well as any concems which have been identified as resolved, but whose corrective action completion is overdue for completion Goal - Comments .

The ECP Goal is to have no unresolved concem older than one year by 2/13/97, no unresolved concem older than 3 months by 5/13/97, and no unresolved concem older than 45 days by

\ (7/13'97 V ' The long term goal established in the ECP Comprehensive Plan calls for concern resolution within 45 days of initial filing.

Data Source: C Mihako x4541 l Analysis by: C.M bakox4541 l Owner: E. Morgan x4335 Page E1 B_ECPNEW.XLS

! Numbar of NU and NRC Received Concerns l Millstone /CY - April 1997 i

l Progress: April results continue improving trend of NRC vs NU concems received.

f l

} 80 i

I 70

) 60 i i l i l I i 1994 1995 1996 Jan-97 Feb-97 Mar,97 Apr-97 l m NU Rec'd E NRC Rec'd

]

Raw Dets j 1997 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec NU Received 8 12 14 28

.; lNRC Received 19 11 13 5 j v NU Rec'd YTD 8 20 34 62 NRC Rec'd YTD' 19 30 43 48

! NOTE: Data listed through 4/30/97.

I Dennition Analysle/ Action ,

1

!' Nuclear safety concems are nuclear or radiological events or During the month of April, the NU ECP received significantly 1 I observations reported to NU's Employee Concems Program (ECP) more concems than were received by the NRC. This

! believed to violate regulatory requirements or NU policy or continues the trend began in February. A continued decline i procedure conceming nuclear safety, which have not been in the number of concems filed with the NRC, combined with

! adequately /promptly addressed by formal Quality Program an increased number raised with the NU ECP, would be Reporting mechanisms or fall outside the scope of the formal evidence of increased employee confidence in our internal reporting mechanisms; e.g. Nonconformance Reports, Adverse resolution process.

Condition Reports, Drawing Change Requests, etc. The ECP also receives, and attempts to resolve, concems which are not directly i safety related. I J NRC concerns include concems received from licensee

employees, contractors, the general public and concerns self-4 generated by NRC staff based upon observations and/or media reports.

J

^

Goal Comments NRC Rec'd Concems M M M M The final NRC tally for the Millstone site for 1996 was Millstone 39 45 42 76 76 concern.s.1996 concerns lodged with the NRC from Ha h Neck 13 8 9 23 the Haddam Neck plant total 23. Both totals represent US Avg (110 statens) 88 81 7.4 8 corrected final tallies as received from the NRC Allegations Advisor, u

Data Source: C. Mbako x4641 l Analysis by: C Mbalko x4541 l0wner: E. Morgan x4335 Page E3 B_ECPNEW.XLS

I Millotono Employos Concerns Confidantiality Trond l April 1997 i

i Progress: Increase in confidentiality waivers may indicate employee confidence in i the ECP process is improving.

a 70 %

i  %% ,e

,e 40 %

• 0% l l I Jan-97 Feb-97 Mar-97 Apr-97 I f

aminimul Anonymous Confidentialtiy - No Confidentiality 1 i 4

i RawDatn

! 1997 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

! Anonyrnous 5 3 5 6 I . [Conhdentiality 8 6 5 5

."No Confidentiality 8 11 12 18 f

Total 21 20 22 29 l

! DeHnition AnalysisfAction l Nuclear safety concerns are nuclear or radiological events or

observations reported to NU's Employee Concerns Program

(ECP) believed to violate regulatory requirements or NU policy or procedure concerning nuclear safety, which have not been adequately /promptly addressed by formal Quality Program Reporting mechanisms or fall outside the scope of the formal reporting mechanisms; e.g. Nonconformance Reports, Adverse Condition Reports, Drawing Change Requests, etc. The ECP also receives, and attempts to

resolve, concerns which are not directly safety related. This data includes such concems.

I l

Goni Comments

)

Dera Source: C A. MAalko x4541 l Analysis by: C. A M6alko x4541 l Owner: E. Morgan x4335 i

1 Page E4 B_ECPNEW.XLS l

)

Number of Action Items g o a e 8 8 8 8 8 8 2/1/97 2/15/97 M 3

3/1/97 V_

O l 3/15/97 I M

> 0 o G

$1 c @

[ - 3/29/97 l g 4/12/97 o

s O

4/26/97 O 3

M 5/10/97 -

(** 9 5/24/97  : O 3

6/7/97 t' (/) V 6/21/97

~

E3 g g-G 7/5/97

==

7/19/97 gi k_.

8/2/97 On 3 bm 8/16/97 QU eo 8/30/97 NO 3

9/13/97 V_  !

O 9/27/97 C.

/ O 10/11/97 U T

10/25/97 o '

(Q 11/8/97 g M

11/22/97 M O

12/6/97 C ,

k 12/20/97 e 1/3/98  !

O.

---,-ww--.v--,-p-+--,ve,--- ..,-.-r,-wwem..w----,-w--,--y,,

, - - - - - r- - - - - - - ,.-r-cew --9-------r---r-----,--e-v,- rt1-- e + , "

i l

O Appendix 3 KEY PERFORMANCE INDICATORS - TRAINING O .

O

l Training Corroctivo Action Plan O

Training Corrective Action Plan 100 %

90 % i  ! -

. 80 % -

70 % I -

60 % I I I

, y -

50% . -

1 40 % -

30 % - - - -

20 % - - -

10% - - -

0%

Mar Apr May June July Aug Month i Mar Apr May June July Aug Jan 98 ACTUAL 5% 7% 33 % 33% 33% 33% 33%

[T SCHEDULED 5% 7% 30 % 77 % 95 % 98 % 100 %

Definition

Corrective Action Plan includes 60 items.

One item is not due until January 1998 and is not included in the graph.

Actual percentage represents cumulative closure to date.

Analysis / Action .

Slightly ahead of schedule - No additional action required.

4 4

Data Source: Corrective Action Plan l Owner: R. Johannes

,4 Analysis by: A. G:verson x2591 V

l 4

Supervisor Observations of Training i

l j Supervisor Observations of Training I y 30 1

.@ 25

! 8

! $ 20 -- - - - - - - - - - - - - - - - - - __

i 8

. =

q @ 15 -

I $

! o 10 - -

i o 4

2 5 -

i 5

] z O --- - - -- - - -

28-Apr 7-May 14-May 21-May 28-May i Week of i

Week of 28-Apr 7-May 14-May 21-May 28-May Observations 11 27 9 20 22 Definition lQ Supervisor observations of training for which an evaluation report was submitted.

l Analysis! Action *

Unit Training Advisory Councils are developing expectations for their management personnel.

Once established, these will be tracked on an individual unit basis.

i

}

~

Data Source: Corrective Action Plan ~lowner:R. Johannes Analysis by: A. G verson x2591

Attendance (No-Show) Notification 2D Attendance (No-Show) Notification 120 100- -

I

{6 80 -

{ 60 --

! 40 -- - - -

I 20 _ _ _ _ _.

O - - - -

7-Apr 14-Apr 21-Apr 28-Apr 5-May 12-May 19-May 26-May

, Week of Week of 7-Apr 14-Apr 21-Apr 28-Apr 5-May 12-May 19-May 26-May l No Shows 102 68 46 62 53 31 22 16 l

Defimtion

, "No Show"is defined as anyone who is scheduled for class and does not cancel or

] reschedule at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to class.

} Goal Analysis / Action j Goal is 0 "No Shows." Continua to emphasize attendance j performance at unit morning meetings.

i 1

1 h

Data Source: Correctwe Action Plan l Owner: R. Johannes Analysis by: A. Guerson x2591

4 s

e 4

4, 4

l 4 f

4 t

.I i

l Appendix 4 i.

NU RESTART DEFINITIONS

}

1 l

k 4

'l 1

a 4

I f

• f i

1 i

i t

i i

4 i

e

/

1 i

e l

i 4

t 4

4 i

,I A

l

/ APPENDIX 4 NU Restart Definitions

• 1 ICAVP READINESS

1) Audit Plan finalized

2) Discovery phase complete for 50% of safety and risk significant systems and associated Engineering Programs

3) ICAVP Contractor and NRC Inspection support in place PHYSICAL PLANT READINESS

1) Systems functional

2) Satisfactory pre-startup test results ,

3) Adequacy of system line-ups

4) Restart hardware issues resolved (including SIL)

5) Maintenance backlog managed and impact on operation assessed

6) Startup and power ascension program in place

7) Adequate plant materiel condition

8) Operator work-arounds and control room annunciator deficiencies addressed

9) Plant drawings reflect as-modified conditions

'rh (j

• Excerpt from May 21,1997 Northeast Utilities Briefing for the NRC Restart Assessment Panel

r  :

OSTl READINESS

1) Plant operated within regulatory requirements

2) Organizations that control and support operations are functioning

effectively

! 3) Staff and plant are fully prepared for resumption of power operation

4) 03560, SIL, ISP and restart items closed or disposition scheduled with work-off controlled and tracked and results showing favorable trend or at goal 1

5) 10 CFR 50.54(f) responses on schedule

6) Corrective action plan implementation addresses root causes of performance decline

7) Startup and power ascension program in place

8) Long-term performance program in place

9) Operator readiness

10) NRC Inspection support in place READY FOR RESTART (Regulatory)

1) Restart related ICAVP, OSTI,0350, inspection, ISP,10 CFR 50.54(f) and licensee identified items resolved and deferred items dispositioned

2) Compliance with regulatory requirements (including Technical Specification changes and license amendments implemented)

3) Startup and power ascension program in place

4) Long-term performance program in place

5) NRC Restart Assessment Panel response support in place

e i

?

?

i

l 1 1 a

! I i

4 j Appendix 5 i

i l SITE INTEGRATED SCHEDULE l i

i i 1 l l

l l

i 4

i  ;

I O ,

l 1

l

i

}

lO i

l 1

l Millstone Nuclear Power Station

! Site Integrated Schedule 1

!O 4

i 4

6 0

a i

lO

j s

MILLSTONE SITE INTEGRATED SCHEDULE PnOJs.Li Slik biART AS OF 5/23/97 (REV. 83 DOCTse F t A NN iN6 PLOT SITE FINISH bJUN99 5cH E auL E i p

. s0E 1/1 SHEFT 1/2 LINE BREAK ON MODE C/F RUN J St% f ti ? lbs 46 (

DATA DATE 7tMAY97 SORT BREAKS E START E FINSH NODES PROJECT /2 93A1 l INTERVAL 1 MONTH (91 SCHEDULE BAR CHART _

4 I

1997

}

1996 APR PW JUN JtlL AUG SEP CCT NOV DEC JAN FE3 MAR AaR MAf i JUN PP UNIT 3 e

C NFIGURATION MGMT PROG CMPL 13 AUG 1 i 1 I

CONFIGUR'ATION' MANAGEMFNT PROGRAM L CENSE AMENDMENTS APPVD 21 POV

2 .

I 2 LICENSE AMENDMENTS APPROVED i

3 RESTART UNIT 23 DEC

! I I I t C ISSIONER RESTART BRIEFING 19 DEC 1 1 i t I i 1

READY FOR RESTART (HEATUP) 22 NOV l i l PpYSICALL[READYFORRESTAJT38SEP j- 3 l

13 l l i i l f T/ PROG IMPROVEMENTS CMPL 13 AUG NRClSIGNIF. ITEMS LIST CMPL 13 iAUG i + I I I I I

j ADY FOR OSTI 30 SEP 4

MILLSTONE UNIT 3

~

IgAVPCOMPLETE02OCT l 4 I I 4 CONTRACTOR ICAVP i

4 NRC ICAvP COMPLETE 14 NOV Fi 5 I

' 5 NRC ICAVP O TI COMPLETE 24 NOV b i. I b OSTI rv wn x L CENSE AMENDMENTS APPVD 25 NCV 7 = =- =

1 7 LICENSE'AMMENDMENTS APPROVED cpm. RESTART BRIEFING 23 JAN (PROJ)

RFADY l

FORi RESTART (HEATUP) ib DEC I I I I PYS{CALLY READY FOR RF. START 25 NOV 8 ~ ~ ~ - I 8 7l 1 i i NRC SIGN:'F. ITEMS LIST CMPL 15 SEP P

) MILLSTONE UNIT 2 EDT

. - . = .

f"'%

i i

't J

'MMITE RUN 30mY97 15:98 PLOT SITE Pari 1/1 SHEET f/? PROJECT /2 93A1 SCHEDULE BAR CHART I

I 19s7 tsss APR MY JUN JUL AUG SEP OCT NOV JSN mR DEC FEB APR MY JUN PF UNIT 2 CgNFIGURATIONMGMTPROGCMPL08SEP 9 . . . .

I 9 l CONFIGURATION MANAGEMENT PROGRAM ICAVP COMPLETE 15 NOV ri 10 1 i 10 CONTRACTOR ICAVP N C ICAVP COMPLETE (TBD) 11 i i 11 NRC ICAVP l

09TI COMPLETE 27 CCT (PROJECTED)

F 12 i i 12 OSTI

~Pf UNIT 1 CpNFIGURATIONMGMTPROGCMPL01 MAR U 13 -

. 13 CONFIGURATION MANAGEMENT PROGRAM M 1 RESTART UNIT (2ND QTR)

COMM. RESTART BRIEFING (2ND QTR)

P 14 -

1 14 Y)ICLLYREADYFORRESTART27 MAR MILLSTONE UNIT 1 L ENSE AMENDMENTS APPROVED 21 MAR

)

15 i .

i 15 LICENSE AMENDMENTS APPROVED I I IpAVPCOMPLETEB1 MAR 15 I I ib CONTRACTOR .ICAVP NPC ICAVP COMPLETE (IND QTR)

M 17 F- 1 17 NRC ICAVP OpTICOMPLETEObAPR 18 I i 18 OSTI p

Q,[ EVE

! l t l

!O Millstone Nuclear Power Station Millstone Units 1,2 anc 3 Level 1 Schedules l

i 0 .

O

HILL STONE

( N I UNIT 1 LEVEL 1 SCHEDULE AS OF 5/23/97 (REv. 8)

P H If LINE fiir .K ON SCHEDULE SUE SEC ICN5 MODE C/F J T 93At

• %E 1/1 SWEET 1/3 DaTo OnTE 71MAY97 SOPT BPEar5 E stopt E FIN 5H ]NT[PVA(t 1 MONTHf51 SCHE DUL E BAP CHAPT I i 1997 1998 AFP mY JUN JUL AUG SEP OCT Nov DEC JAN FEB MAR APR MAY JUN CONF 1GVQAT2CH MGEHCNT P90GRs+1 1 25FEB TU - - - - an i 1DEC MO I CONFIGURATION MGMT PROGRAM - DISCOVERY COMPLETE l l l 1 l l l <

2 F 8NOV SA ! l  !

UNIT READY FOR ICAVP l

," l I I l l l i 3 15NOV SA I i 1 MAR SU t CONTRACTOR ICAVP I l l l l  !

4 15NOV SA I i 1 MAP SU  !

C50.54F) PROGRAM COMPLETE i l l l l l l 5 8DEC MO I I 23APR TH NRC ICAVP n

l 6 F 1 MAR SU CMP FINAL LETTER SUBMITTAL Yl l l 8APR WE 23APR TH (9

/

,/

i tgt ISSUE RESOLUTION FROM CMP REVIEW l l l l l l l l l l l l l l l ""'""8 25FEB TU -- - 22% i 2bAPR SU WORK EACKLOG REDUCED TO ACCEPTABLC LIMITS I l I i i i i I i i i I I l 9 2NOV SU i i 1 MAP SU ALL MODIFICATIONS REOUIRED FOR SU i l l l l l l 10 2NOV SU i i 1FEB SU l ALL MODIFICATIONS REOUIRED FOR RELOAD l l l l l 11 F 1FEB SU ALL PHYSICAL WORK FOR PELOAD f l l l 12 2FEB M0 0 SFEB FR DOC REVIEW 5 L APPROVAL TO LOAD FUEL (PORC) l l l l 13 7FEB SA 011FEB WE CORE PELOAD

! l 14 F 2 7 MAR FR  ;

UNIT 1 PHYSICALLY REACY FOR STAPTUP l

• I' l l l I i l l l l l l l l l l 15 80CT TU dix i 17 MAR TU TECH SPEC AMENOMENTS IMPLEMENTED

/'\ . n, l l t t

n/ v -,

ea

_- . _ , . , ~ ~ . . ., u , . . . . -, .. ..+ --,. ~ .-- .. . ~ . .

L e

(3 L# !!u paGE t/1 SHEET 2/3 lGd&f;%!'"' '

SCHEDULE PAP CHAPT I I 1997 1998 I APR NAY JUN JUL AUG SEP OCT NOV CEC Jm FEB MAR APR NAV JUN RE GUL ATD#1

-16 15APR TU PEseatt i 263UN TH l SELF ASSESSMENT PROGRAM COMPLETE i i 1 I ,

17 F 21SEP SU TECH SPEC AMENDMENTS SUBMITTED l l l l l l l 18 26FEB TH I i 6APR MO CONDUCT OSTI l l l 19 F 21 MAR SA TECH SPEC AMENDMENTS APPROVED ex t l l 20 F bAPR MO NRC REGULATORY ISSUES APPROVED I l l 21 7APR TU 26APR SU RESOLVE OSTI ISSUES l l 22 7APR TU O 26APR SU OPERATIONAL' READINESS REVIEW i O **l l V -

7APR TU O 26APR SU READINESS FOR RESTART REVIEW  !

• l l 24 7APR TU O 26APR SU l

SYSTEM READINESS REVIEW l exl l elm 1 j {

25 F 2bAPR SU '

NRC APPROVAL FOR RESTART f l 26 27APR MO O bMAY WE PROCEED TO REACTOR CRITICAL

! l 27 7MAY TH I i 5JUN FR PROCEED TO POWER ASCENSION ex l 28 53UN FR I 5JUN FR COMMENCE POWER OPERATIONS ex LEPle PRQLEMtwiilE JP@RQvENENT S 29 1 MAR SA zes 1 27 MAR FR OPERATIONAL READINESS PLAN l

l lC,%" l

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

I i

l =

/~T

! \ l l T h LCT SITE &UN 294197 15:45 i PLOT SITE PR0]ECT/2 93A1 f PACE 1/1 SMEET 3/1 SC HE DUL E BAP CHAPT l I 1997 1998 APR Per JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APP MAY JUN

}

DEPT /PROGRArtm11C IPee0VEMENTS

! 30 13AN THI i 1 MAR SU ,

i ALL TRAINING REQUIRED FOR STARTUP l

{ ex j } } l ,

I 31 bJUN SA E b]UN SU l

, L,,ONG TERM IMPROVEMENTS  ;

9 I

i O -

l h

4 I,

i 1

l I

i !

4 I

l n  !? ? % '

U

. MILLSTONE  ;

UNIT 2 LEVEL 1 SCHEDULE l A5 OF 5/23/97 (REV. 8) l FROJECT blit Sinal 60CI9e PL aN N 1 N V 5LM t DU ( t kUN jdMHTS2 l }: 29 PL OT $1TE FINISH 6JUN99 LINE hREAg ON SCHEDULE SUB SECTIGNS MODE C/F PROJECT /2 93At PACE 1/1 SHEET 1/1 DATA DATE 2tMAv97 SCRT PPE AR S E STAPT E FINSH IWERVolt 1 NONTHf51 SCHE DULE BAP CHART I

l l 1997 1998 APP PnY JUN J UL AUC SEP OCT NOV DEC JAN FEB MAR APR NAv JUN Cor#ICu9ATICN MAP 4EMENT P900&an PHASE S - (9/08/97)

FI I I I PHASE 4 - (7/21/97)

G l l l l PHASE 3 - (b/30/97)

G I I I I i PHASE 2 - (6/30/97)

G I i i l l PHASE 1 - (b/ 30/9 7)

G l l l l l 1 3FES MO - x dox i 8SEP MO CONFIGURATION MANAGEMENT PROGRAM - 50.54CF)

- 1 ll l 1 2 5MAY MO O 16MAY FR CMP INDEPENDENT REVIEW l l l l i 3 F 30JUN M0 NNECO READY FOR ICAVP ex 5

4 30JUN MO I i 15NOV SA CONTRACTOR ICAVP e r.

l l 5 F 15SEP MO 10CF R5 0. 5 4 (F ) RESPCNSE TO NRC l l l l 6 F 30NOV SU ICAVP REVIEu L REPORT COMPLETE l

• • i l  ! l l l m e. i ,  ;

7 2 b DE C TH ---- d ix i 1DEC MO l MAJOR MODIFICATIONS TOTAL (108) ,

HIGH ENERGY LINE BREAK ( 9/27) l RBCCW PROJECT (10/15) i CHECK VALVE REPLACEMENT (12/01) j MOTOR OPERATED VALVES (11/20) I I II I I l l l 1 8 17 F E B MO ---- s ex i 153UL TU  !, l l

PERFORM DRAINED DOWN WORK C DEF UEL E D)

I ll I I I I I t l 9 lbJUL WE O 23JUL WEl l I REACTOR HEAD INSPECTIONS ex 1

3717v%' I i

I l

l 1

I i

l

)

.(O#" tiu wr m swm

a!!r;'h4"" '

seseoute sc., csc 2e I r

I I I see7 sees  !

er mv aus aut auc ser cci e osc 2au sta nan aan sa, aun 1 FEGuLATORT LICENSING AMEND APPROVAL (11/25/97)

G LICENSING AMEND SUBMITALS (7/31/97)

P

$ l l l l l l l l 10 1]AN WE =~ 472 l 25NOV TU '

i oyqN ITEMp l l l l l l l 11 1]AN WE =26% 1 13UN MO OPERATIONAL READINESS PLAN 12 SMAY MO re n l l l IFi15SEP l M0 SIGNIFICANT I, TEM,5 LIST , CLOSURE PA,CKAGES SYSTEM READINESS REVIEW (9/01/97)

G I I I I I I I I I READINESS FOR RESTART REVW (8/31/97)

S I l l l l l l l l OPERATIONAL READINESS REvW (7/31/97) 6 l l l l 13 13UL TUi i 1SEP MO

{EADINESSREV EWS a -

p 14 295EP MO1 l 280CT TU NRC REVIEW ASSESSMENT OSTI 0%

l P

15 2 3] AN F R D 2 93 AN TH COMMISIONER RESTART BRIEFING l l l PheWT 16 2AUG SA 0 bAUG WE RELOAD CORE l l l 17 F 20AUG WE MDDE 5 l **i l 18 95EP 10i i 90CT TH Z1 SURVEILLANCES  !

• • l l l l l l

'19 100CT FR I i10NOV MO  !

Z2 SURVEILLANCES  !

l l l l 20 F 25NOV TU PHYSICAL READY FOR RESTART 8%

$Uv7 l

.- -. . - -. - . . . . . ,. , .. - .~. .~. .- . ~ .

{* e i.

~

/

$T SITE PUN 3e mv97 13: 2e (m .,/ SITE P&OJECT4 93A1 i PA0f 1/1 SMEFT 1/1 $CHE DULE BAP CHART I I  ;

1997 1998 APP mV JUN JUL AUG SEP OCT NOV DEC JAN FEB P%R APli NAV JUN PLNG 21 F 16DEC TU i READY FOR RESTART (COMMENCE HEATUP) l l l l I 22 F 2 7 J AN T U  ;

MODE 2 l

4 ex

• l  ;

23 F 17FEB TU  !

100 PERCENT POWER exl DE P T/PNOGaut%II C leftOVENENTS

. 24 13 AN WE 5 === 3 n i23DEC TU I PROGR4MATIC IMPROVEMENTS l l '

ORGANIZATIONAL LICENSING NUCLEAR OVERSIGHT SELF ASSESSMENT NUCLEAR BAFETY ASSESSMENT BOARD i i

25 1JAN WE - 3n lF i23DEC TU r

DEPARTMENT IMPROVEMENTS OPERATIONS

( MAINTENANCE WORK MANAGEMENT ENGINEERING l

I i

I

$70,7 O

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

_ _. .___..__m~ . . . . . _ . _ _ . _

I l

NILLSTONE UNIT 3 LEVEL 1 SCHEDULE l

AS OF $/23/97 l E 1/1 SHEET 1/3 ATE 7 B EAK AR E NSH RV  ! t #1DNTH(S) S I I I

tes7 assa apa mY JUN JUL f

SEP Jm AUG OCT NCY DEC FEB PmR APR tmYlJ{

CCPFIGURATION PVW(,ENENT PROGRM1 1

Cg COMPLETE (7/14/97) pE1 (5/1 /9 7) 1 1 J AN WE EFr== . .

I 14JU.L M.O CONFIGURATION MANAGEMENT PROGRAM COMPLETE ESTABLISH LICENSE f, DESIGN BASIS (FSAR/DBS)

SYSTEM REVIEWS l l l l l l l MP EME{ PROCEDyRES (8/11/97) 74UAL C{PLETE(7/1/73 2 1JAN WE - i 13AUG WE NNCU (SBO,HELB,M (.MOWREPRTECTON,97...ETC)

, ISI LEC SEP.,RG 1. APPENDIX-R l l l l gESTARTPHASE(8/13/97) i 3 24FEB MO . . .i13AUG WE .

OPERATIONAL READINESS PLAN I I ig/02/97 4 27MAY TUi i 20CT TH CONTRACTOR "CAVP l l l 5 30JUN MO I 14NOV FR NRC ICAVP l l l 6 23JUL WE i i230CT TH FINAL SYSTEM' READINESS REV]EW FINAL WALKDOWNS l l l 7 + 13AUG WE i 10 CFR 5 0 - 5 4'(F) RESPONSE TO NRC l PMYSICAL honk PgANTPHYSICALLYREADY (9/3B/97) 8 13AN WE I 30SEP TU "am8amma"h ws"")

QSS/RSSPIPEMODhICATIONS CCP PIPE SUPPORT MOD APPENDIX-R MODIF CATIONS l

i G l l  !%an' l

. 1 O

v pgy 3 emy g 7 g ,,17 fCT

_ Pace vi sNon m ( M Cl'a y a I i 1997 itse APR MAY JUN JUL AUG SEP OCT NOV DEC JM4 FEB MR APR mV JUN PHYSICAL 60RK ILRT COMPLETE (9/38/97)

Ok/ESFTESTING(9/16/97 e e'MCD' COMPLETE (9/10/97

+ 1 1 I I l 9 2bJUL SA1 i 30SEP TUl l NON MODS PHYSICAL PLANT WORK REbuLAli)RY NgCS.I.L. (8/13 97) 10 1 J AN WE "3=== .

1, 30SEP,TU EkCkWf10bIFIhAk$0NS DE E E l

l l L CENSE AMENDMENT APPRVL-11/21/97 gECH SPEC SUBMITTAL ( 30/973 11 1JAN WE I 21NOV FR

/m . .

NRC OPEN ITEMS

)

12 + 13AUG WE UNIT READY FOR OSTI PERFORMANCE INDICATOR (KPI) ON GRAPH LINE I I I I 13 4 30SEP TU STATION REA Y FOR OSTI I

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BNOV SU OPERATING CYCLE b

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[,) , RgSTARTPHASE 8 13/97) l 20 1JAN WE 30DEC WE PROGRAMMATIC IMPROVEnE16.-i l ORGANIZATIONAL LICENSING NUCLEAR OVERSIGHT SELF ASSESSMENT NUCLEAR SAFETY ASSESSMENT BOARD I I I I RgSTARTPHASE (8ji3/97) 21 1 J AN WE =- == .

30DEC WE DEPARTMENT . IMPROVEMENTS OPERATIONS MAINTENANCE WORK MANAGEMENT ENGINEERING l

O 4

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1 l

i i i O

l Appendix 6 STATUS OF NUCLEAR OVERSIGHT RECOVERY l PLAN

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o o o I

i Status of NUCLEAR OVERSIGHT RECOVERY PLAN Presentation to the NSAB May 29,1997 i

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O O O Nuclear Oversight Recovery Plan

- The Recovery Plan - Revision 2

- Current Status and Challenges

- Readiness for Restart 1

____._.._.___.______.__.________.__.______.__________e- _ _ _ _ . _ _ _ _ _ _ _ _ _

o o o Recovery Plan Contents Purpose

• Cause for Action  ;

• Nuclear Oversight Recovery Plan Objectives

• Expected Results

• Roles and Responsibilities

• Attachment A: Detailed Action Plans  !

• Attachment B: Cross Reference with Independent Assessments issues 2

i I

O O O Recovery Plan Purpose Implement an organization that will .

effectively identify and pursue correction of conditions adverse to quality. An integral part of this purpose is to oversee the line organization's ability to self assess, identify problems and correct them in a timely manner. 1

[

3 I

O O O Cause for Action  :.

ACR 7007 Event Response Team I Fundamental Cause Assessment Team (FCAT)

Annual external audits of the program (JUMA)

Root Cause Evaluation of the Effectiveness of the Oversight Organization .

Millstone Restart Assessment Plan (NRC)

Attachment B lists the issues and findings and shows where they are addressed in the Plan t l

4  !

i

i Key Objectives of the Plan

1. Develop and implement an organization to provide oversight of NU nuclear units (effectiveness of the third level of defense of quality).

2. Enhance the ability of the NU nuclear line individuals, work groups, supervision and management to identify and correct conditions adverse to quality (effectiveness of the first and second levels of defense of quality).

3. Provide oversight of NU Nuclear unit recovery activities.

4. Develop and implement an effective Employee Concerns Program.

5

i Key Objectives of the Plan ... cont'd

5. Enhance the effectiveness of the Nuclear Safety Assessment Board (NSAB).* ,

6. Provide oversight of NU Nuclear support organizations.

7.Begin a continuous improvement process which will transition quality functions, analysis, and assessment of staff activities into the line organization. This process will not be completed prior to unit restart.

• Note: The role of the NSAB includes oversight of the Nuclear Oversight organization. The President and CEO NU Nuclear has requested the Vice President Nuclear Oversight to include the actions to enhance the NSAB in this plan.

6

i Expected Results

- Problems are identified by line organizations prior to Nuclear Oversight, and by Nuclear Oversight prior to external agencies or events.

The oversight function is an integral part of the '

management team's assessmeni. process.

The Nuclear Oversight organization is viewed as a key contributor and is fully supported by the President NU Nuclear and line management.

- Employees and contractors understand their rights and responsibilities for nuclear safety, including federal law, company policy, and internal and external reportmg mechanisms.

7

O O O 7 Expected Results ... cont'd

- An environment exists which is conducive to reporting problems and having them addressed promptly, accurately and with professional feedback to the initiator.

. The Nuclear Oversight organization is clearly defined, with established roles, responsibilities, reporting relationships and interfaces which are well understood.

- Nuclear Oversight is appropriately staffed with

professionals who are fully trained and qualified to perform their currentjobs, and a training and development plan is in place to provide individual job growth and .

progression, and to provide organization bench strength and continuous improvement.

i

- Procedures conform to regulatory requirements and the commitments of the nuclear organization, including FSARs, Topical Reports, and technical specifications.  ;

8 t t

O O O i Expected Results ... cont'd

• Evaluations by external organizations (e.g. Independent i Corrective Action Verification (ICAV), Employee Concerns ,

third party oversight, NRC, etc.) determine that oversight activities by Nuclear Oversight and the line are being appropriately performed.  :

• Performance monitoring and indicators are established to permit assessment of Nuclear Oversight effectiveness, '

i correction of negative trends, and continuous improvement.

i

• A continuous improvement process has begun which will transition quality functions, analysis and assessment activities and staff into the line organization and position Nuclear Oversight in the role of evaluator of the line's self assessment capability.

9 t

O O O Status - Foundation has been set for an effective Oversight organization I:

• Expectations set in:

, CEO Expectations for Nuclear Oversight ]

! - Interface Agreement on Mutual Expectations for

. Nuclear Oversight  ;

Pre Access Training

• Organization structure revised with clear accountability

- Increased number of staff positions, including more permanent positions and job rotations with the line

- New procedures communicating higher standards

- NU QA Topical revised

• QA Hold point program revised -- surveillances to be conducted to assess effectiveness

- Feedback to the line improved

- Self Assessments being conducted 10

O O O ,

Self Assessments have identified '

areas needing additional attention-Operational experience backlog Audit records not properly transmitted to vault 50.54(f) staff training and qualification deficiencies

. Number of years of QA experience of PE Management team is low

-- PE developed a strategic plan to address this issue

. Surveillance of Recovery Plan closure packages revealed deficiencies Reviewing the effectiveness of Recovery Plan against previous external assessment findings 11

Nt a Z I.

2. a ooE 3 N

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3m vs 3 9 Q. m # Number of Action items Remaining C lll:1

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O O O .

Status - 60% complete; however, many essential activities remain to be completed in the Recovery Plan ,

Nuclear Oversight Recovery Plan Workoff Curve t As Of 5123/97 140

- - - Current Schedule

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, 100 _ ,

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O O O  !

Challenges still remain to be ^

addressed

- Training and Qualification programs have not been finalized

- Review and disposition of prior licensing commitments '

• QA and Appendix B indoctrination for all site personnel  ;

• Improving quality of work product  ;

- Integrating activities across Oversight organization

• Improving the Monthly integrated report

• Assessing readiness for restart 13

O O O l

, Assessing Readiness of Nuclear Oversight i

l Objective:

Conduct an independent assessment of Nuclear Oversight to determine the organization's ability and effectiveness in fulfilling its regulatory responsibilities Scope:

i

• Performance based observations of meetings, audits, surveillances and inspections; documentation and report reviews; and interviews ,

(officers through workers)

• Does not directly cover Employee Concerns or ICAVP Review elements:

. Compliance with 10CFR50 Appendix B and licensing commitments -

NU QA Topical Report Recovery Plan sufficiently complete to support restart; Attachment B ,

issues (FCAT, JUMA, etc.) addressed j NRC oversight assessment topics addressed

• Selected elements of NRC Inspection Procedure 40500 (Effectiveness t Of Licensee Controls in identifying, Resolving and Preventing Problems) and INPO 96-006 (Performance Objectives and Criteria)

. Demonstrated progress toward meeting Recovery Plan expected results 9 i

. _ - - - _ - __-____-_ _ - - _ _ - _m

O O O '

Assessing Readiness of Nuclear Oversight... cont'd -

- Team Members include: -

! Former NRC Regional Director

• Former NRC resident inspector (and current QA supervisor)

Two utility directors with recent successful QA Director experience Former utility VP with QA and nuclear safety assessment background Former utility manager with recovery experience NSAB member i

- Deliverable: l, Assessment report providing overall conclusion regarding the readiness of Nuclear Oversight for Unit restart, as well as specific findings and conclusions in individual topic areas i Each topic area will be assessed as Ready for Restart; Expected to be Ready for Restart (on track, but all necessary activities not .

complete; or Not Ready for Restart (additional initiatives required)

Schedule:

June 19 to July 3 (includes exit)

Final Report July 25 Oral Presentation to NSAB TBD- July or August meeting 15

O O O Restart Verification

Purpose:

• At critical milestones in the restart process, Nuclear Oversight will provide its independent conclusion on the readiness of each unit to proceed to the CNO and CEOIPresident These milestones include:

Readiness for ICAVP (each unit)

• Readiness for Corrective Action Program review (site program and unit implementation)

• Readiness for special team inspection of the Oversight Function (NRC Manual Chapter 40500 -- includes Nuclear Oversight, Line Oversight, NSAB, Corrective Action and Self Assessment)

• Readiness for ECP review Readiness for OSTI (each unit)

- Readiness for Startup and Power Ascension (each unit) 16

O O O Restart Verification ... cont'd Approach:

- NO Directors are developing a matrix for each restart milestone consisting of the review criteria, type of assessment to be conducted, and schedule which will support the station schedule

- Criteria and schedules will be provided to units

- Each plan will be tracked by a manager

- VP and Directors of Nuclear Oversight will develop an integrated assessment of readiness to proceed

- VP Nuclear Oversight will provide NO's recommendation to the CNO and President /CEO.

Status:

- Review criteria are being developed for each key milestone using NRC and INPO criteria, Confirmatory Action Letters, and the Millstone Restart Assessment Plan .

- Assessments are complete for ICAVP start Unit 3 and Corrective Action Program (not implementation effectiveness) 17

O

)

a i

j Appendix 7 i

4 LITTLE HARBOR CONSULTANTS PRESENTATION

TO NRC ON NU COMPREHENSIVE PLAN I. FOR ADDRESSING EMPLOYEE CONCERNS i

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Expectations for the Compf chensive ITPOP REVIEW OF """"

• Address Each Requirement Established in the NNECo 3 0,21, s aC O,,,,

COMPREHENSIVE PLAN - ra* 'ar "'*"ad **= ' 5*'> 'a a Raised by Employees

- Ensure That Employees % he Raise Safety issues Are Not Millstone Subject to Retabation May 13.1997 - Address the Root Causes of Past Performance Failures )

l30PM + Establish Clear Path to Meeting Goalof Achieving a Safety-Conscious Work Environment

.ne .,< ~ ,u. m .,, ,,.

Expectations for CP, Cont'd Process for Reviewing CP

• Identify Action items That. IfImplemented.Will

• Reviewed 10/24/96 NRC Order to Identify

(

g Achieve the Stated Objectis e for the CP: a Safety-Consciops Work Environment Requirements for the CP

• Studied Millstone Employee Concerns Assessment

• Establish Completion Criteria for Each Action item Team Report (l!96) FCAT Report (7/96) and MIRG Report (9/96) to Understand Problems and

• Identify Methodology for Measuring Progress Causes Toward Achieving a Safety-Conscious % ork

• InterviewedElesen ECTFMembers Environment

• Reviewed CP and Action Plans me ~ ,n. .m Conclusion 1: CP Provides an Adequate Conclusion 2: Creation of an Approach for Upgrading Millstone ECP Independent Concerns Oversight Panel Has the Potential to Accelerate Progress

• Requires New ECP Policy Statement and Towards Achieving the CP Goal Des elopment of Program Manual

• Calls for Management to Demonstrate Support for

• Provides for Oversight of ECP and Millstone Program Station Ensironment with Feedback to Senior l

• Requires Impros ed Qualifications and Training M '" 8 8'*'"'

for ECP Staff and Line Supervision Personne]

• Calls for Review of Workplace Environment for

• Requires a Policy Which AddressesTimely " Chilling" Effect a nd Problem "Hotspots" Response to Concerns and Feedback to Concerned

• Calls for Identifying If and Where Workplace ladividual Intervention is Required ao* . - , .a ,ne .y V

1 l .

t Q)

Conclusion 3: CP Does Not Address Conclusion 3: CP Does Not Address Full Scope of the 10/24/96 NRC Order Full Scope of the 10/24/96 NRC Order Example:

o Places Primary Emphasis on Expanding and MIRG Report Root Cause 7.1 Strengthening the ECP "The team concinded that ineffective problem resolution o Does Not Place Proper Emphasis on Restoring Line pr,c,,,,, have contribeied to continued employee concerns at Management's Accountability For Establishing a Mmstone, fucing relianee on the Nuclear safety Concerns Safety-conscious work Ensironment Program (NsCP) process to resolve concerns that should have o Actions Identified to Address Root Causes From been comcted by roudne pmess."

Past Insestigations Appear to Be inadequate or To Narrow in Scope As ITPOP has stated the CP does not address this Root Cause The CP focus ts the Employee Concems Program and does not e

address the routme process adequately.

. , , , , - ,, m.- . , ~

Conclusion 3: CP Does Not Address Full Scope of the 10/24/96 NRC Order Conclusion 4: CP Does Not Sufficiently Example: Address the Normal Programs for MIRG Report Root Ca use 7.5 Problem Identification and Resolution:

[

• equ

" Communications appeared to be a connauing problem area. ement for Mcal Revkw prmal

\' characterised by poor inter-departmental interacuan, general failure to encourage questioning statudes, and a tendency to Correctise Action Programs and Their Implementation manage by memorandum. Ineffective implementation of the

• Places Insufficient Emphasis on Effective Use of concept of teamwork also appeared to have contributed to .

employee concerns at Millstone. Self-assessment Process I The action items idenafied in the CP to address the issues of poor Provide Feedback on Plan Effectiveness Regarding commimicanons and lack of teamwork an not sufficient to correct these problems at Millstone. Problem Identification a nd Resolution

,,, . , - m,, . , - ~

Conclusion 5: The CP Does Not Conclusion 5: The CP Does Not Clearly Identify Criteria for Success or Clearly Identify Criteria for Success or Measurement Techniques. Measurement Techniq ues.

Example:

• Action Item Elements Are Presented g Essentially As" Punch List" items Action b2 Feedback to Concerned Individuals

• Success Criteria Are Not Established for Many Action item Elements, Thus Providing No Basis o I,,or,,1 for Judging implementation Success Action 7-2 " Cooperate in investigations as appropriate"

• Measurement Techniques for Evaluating Action 2-5 HR communications Implementation Against SuccessCriteria Are There are n criteria for soccess Not Adequately Specified There is n mendon of monitoring effecoveness t,,,, -- ~ w,, .,"

• O V

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

J d

4

. t 4

4 Recommendations Recommendations, Cont'd Revise the CP to Address the Following:

Revise the CP to Address the Following:

- Ensure All Root Causes Are Effechvely Addressed So i - Require a Critical Review of Current Corrective That Resultant Action Plans Combined With 1 Achon Programs Management's Direction, Will Correct Each Root Cause

- Expand the Requirement for Format. Periodic Self-

) - Place the Focus on Line Management's Role and Assessments by Each Organizational Element Accountabilities in Achieving the Desired Safety-Conscious Environment

- Develop Success Criteria and Measurement Techniques

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1 OBJECTIVES MILLSTONE EMPLOYEE CULTURE SURVEY

• What has NNECo done in the past?

HISTORY . What is the quahty of that effort?

Should we rely on the data?

Millstone

• Have past surveys yielded usefulinformation?

May 13,1997 1:30 PM I CONCLUSIONS RECOMMENDATION I 1

Before Conducting the Nest Survey Consider the Following:

• The surveys were not constructed to address

'[] nuclear safety culture.

• The suhrvey process may have adversely

. ob;ecoves are clearly defined l[, '",, ' """j'q# sms ame.ed and trnpacted results. vahdated

• Survey resulu were not factored into plant

• All mas of culture ce mciuded.

improvement processes.

• Line managers are appropnately prepared and involved.

• Management is comrnmed to translate and implement the results into actions.

SURVEYS WERE NOT CO.NSTRUCTED SURVEY PROCESS M AY ll AVE TO ADDRESS NUCLEAR SAFETY IMPACTED RESULTS CULTURE g,,,n n.  ;

Some L a ampleu

• There has been httle or no pre-survey esmmumcanon.

• Did not mvolve hne managers in the survey process. Ex:

• Limited NNEco mvolvement m the design and Did n t train them hem to an%ze. commumcate resWts.

Selection of the questions.

• De adimmstranon process itself had mimmal built-m a

The survey questions,themseh es do not address man s.

attributes of nuclear safety directly.

• Never condt.cwd follow-on mternews.

Did not melude employee concerns portion in Graphu:al. raw data detail from October survey gwen to analysis. Ime management to distribute m1thout any trainmg m how The questions address processes and programs rather to analyze and cornrnumcam it.

than relationships and morale

• Surveys were c nducted too close together.

• There has been no fo!!ow-on communicanon.

[D b

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SORVEY RESULlb W ERE SO'l FACTORED INTO PLANT IMPROVEMENT PROCESS Fiamriles-No management commitment to effectnely commumcate, act i

on the results.

No effecove analysis completed on either sun ey.

Management did not implement any acnon plan related to suney findings after the June and October Surveys

• Some employees appear to be skepncal since there was no sctmty Management chose not to commumcate or analyze the results of the October 1996 Suney.

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i l Appendix 8 i

NU NUCLEAR SAFETY STANDARDS AND EXPECTATIONS 1

l f

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Northeast i)) Utilities System i

I i

1 I

l Northeast Utilities i Nuclear Safety Standards and Expectations l 4

i Rev. O l

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l w r/uh9 B. D. Qon Date l President and Chief Executive Officer  !

Northeast Utilities Nuclear Group O

l l.

O Table of Contents I.

Section Page Principles 1 l Standards and Expectations 3 1.0 Nuclear Fuel 3 6 1.1 Reactivity Management 3 1.2 Spent Fuel 3  :

i 2.0 Safety of Operation 4 2.1 Administrative Control 4 2.2 - Cognizance of Plant Conditions 5

, 2.3 Plant Configuration Control 5 2.4 Availability of. Safety Systems 6 3.0 Management of Activities and Evolutions 7 3.1 Conduct of Maintenance 7 3.2 Conduct of Outages 8 3.3 Evolutions 9 2 4.0 Conservative Decision-Making 10 l 5.0 Review and Monitoring of Operation 11 References . 13 r ,

l

NUCLEAR SAFETY STANDARDS AND EXPECTATIONS The mission of the Nuclear Group of Northeast Utilities is the safe, environmentally sound, dependable and economical generation of electrical energy utilizing nuclear power.

To successfully achieve this mission, every person within the Nuclear Group must consider i Nuclear Safety as the top priority. The cornerstone for fulfillment of this mission will be the creation of a work environment established by the attitudes and behaviors ofindividuals that is based on the followmg: 1 1

PRINCIPLES

1. Every person involved directly or indirectly with the NU Nuclear Group must maintain a profound respect for the safety of the reactor core and the spent fuel.

Everyone must recognize the importance of how their activities contribute to maintaining the reactor core and the irradiated spent fuel in a safe condition. All of us must assume a personal responsibility for performing all operations, maintenance, design, and supporting activities in a conservative manner that fully supports this goal. Nuclear Plant Safety shall be the highest priority ofindividuals at every level of the organization. Our decisions and actions must be based on this priority and our behavior must actively ensure that concerns O receive the attention warranted by their nuclear safety significance.

b

2. Our attention and resources must focus on proactively preventing events that compromise nuclear safety.

l Inherent in this principle is the need to maintain positive control and to protect barriers implemented to prevent reactor core damage. Defense-in-depth must be practiced throughout the organization to maintain plant safety and reliability and to reduce the consequences of i events. We shall establish the necessary barriers in procedures, processes and equipment configuration to prevent occurrences that could affect reactor safety.

1

3. The fundamental component to successful implementation of Nuclear Safety is the use of l conservative decision-making.

Decisions affecting nuclear safety shall be based on established methods, procedures, and a thorough understanding ofplant conditions. When conditions are such that an informed decision may not be possible, personnel are expected to seek the necessary information to make an informed decision and demonstrate conservative decision-making to ensure nuclear safety. Management shall support nuclear safety through its actions, and by actively supporting and encouraging the use of conservative decision-making.

O 1 Rev.O

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

1

h. I

)

- i The Nuclear Group will make consenative decision-making and nuclear plant safety integral i

to its culture. Individuals involved in Nuclear Group activities will demonstrate:

j e a prevailing state of mind focusing on safety; e

an insistence on sound technical basis for action and a thorough understanding of the {

i potential consequences of actions; e l j a recognition that potential ris.ks inherent in nuclear technology necessitate that safety

! considerations pervade all activities;  ;

)

e a practice of adherence to all procedures; e a rigorous self-assessment of performance;

e an environment that is receptive and responsive to safety issues raised by employees.

. l i

4. Personnel are required to do the "right thing" and enforce high standards.

j' Routine communications from Management shall consistently and frequently reinforce the i belief among all personnel that every activity, regardless of the perceived importance, is to be

j. performed to uniform high standards.

i

! Focus on the task at hand and take the time needed to do thejob right. Do not rush.

i Concentrate on the job and prevent distractions from affecting your task.

i

. Individuals shall self check and expect and welcome being checked by others. Everyone j must hold themselves accountable for their actions.

4

Clearly understand assigned tasks. and know how to determine if they are being done correctly.

).

j Be conscious of the potential consequences of each action. Be cautious and have a questioning attitude. Individuals shall work in a cautious, conservative manner and ask the j "what if' question particularly when faced with uncertain or degrading conditions involving i reactor safety or other important tasks. .

Work for success but be prepared to meet the worst case. '

l

[

2 Rev.0

STANDARDS AND EXPECTATIONS 1.0-NUCLEAR FUEL l At the heart of nuclear power plant safety is the control of nuclear fuel. All activities affecting nuclear fuel shall be performed in a conservative, planned and controlled l manner. Irradiated fuel shall be kept adequately covered with water and suberitical at all i I

times when stored in the spent fuel pool.

, 1.1-Reactivity Management l

l l The reactivity of fissile assemblies shall be changed only in a deliberate and controlled I manner.

i 1.1.1 Administrative controls for reactivity management shall be established to develop a  :

consciousness for reactivity issues in the organization and to implement conservative l actions with regard to reactivity. l i

1.1.2 Licensed operators shall be responsible for control of reactivity and taking conservative j actions to safeguard the integrity of the reactor core. All planned reactivity changes shall Q be made under direction from, and with the prior knowledge of, a licensed Senior Reactor j Operator (SRO).

J 1.1.3 All unplanned, unexpected and inappropriate reactivity changes are considered reactivity events and shall be promptly investigated and condition reported.

1.2-Spent Fuel l

1.2.1 The spent fuel pool system design basis includes a residual heat removal system.

criticality control, appropriate confinement, filtering and protection against draindown.

ventilation, cooling water makeup capability, and suitable shielding for radiation I protection.

1.2.2 Removal of Spent Fuel Pool equipment and supporting systems from service to perform work shall be effected in a controlled manner consistent with approved programs and procedures that appropriately address all design and licensing basis requirements.

1.2.3 Adequate measures shall be provided to ensure a defense-in-depth philosophy which will i preclude and mitigate the consequences of accidents postulated in the design basis of the spent fuel pool.

!O  !

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3 Rev.O

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!'") 2.0-SAFETY OF OPERATION Three physical barriers protect the public from fission product release: fuel cladding, reactor coolant system boundary and containment. Plant features are designed to reduce the probability of accidents that may challenge these barriers. Programs and procedures are implemented to prevent plant activities from challenging these barriers and provide for reactivity control, inventory control, heat removal, containment integrity, and availability of vital auxiliaries.

Safety systems are implemented and maintained in a state of readiness so that they can mitigate the consequences of challenges to these barriers. This combination of physical barriers, prevention and mitigation equipment, procedures and trained personnel form multiple, redundant layers of defense which provide a defense-in-depth. The effectiveness of the implemented layers of defense depends on:

. Adherence to Administrative Controls;

. Effective Cognizance of Plant Conditions;

• Plant Configuration Control; and

. Availability of Safety Systems 2.1-Administrative Control o Administrative controls establish criteria that support safe reactor operation and Q maintenance of the design configuration. i l

2.1.1 Actions that depart from license conditions or Technical Specifications may only be taken in an emergency, when approved by a Senior Reactor Operator (as a minimum) to protect the health and safety of the public and when no alternative or equivalent action is apparent, consistent with the provisions of 10CFR50.54(x).

2.1.2 The Unit shall have administrative controls to ensure that all configurationand i operations are consistent with the licensing basis or are appropriately evaluated per 10CFR50.59.

2.1.3 Technical Specification Clarifications shall not change the intent of Technical Specifications. A 10CFR50.59 Safety Screening / Evaluation and review by the Onsite Operations Review Committee will be performed as needed before implementation.

2.1.4 Nonconforming or Degraded Conditions:

. Shall be documented and evaluated for impact on operability.

. Corrective action to restore a nonconforming or degraded condition shall be taken in a timely manner, commensurate with its safety significance, and in accordance with 10CFR50 Appendix B, Criterion XVI.

l (g)

~

. Ifit is determined to be acceptable for a nonconfonning or degraded condition to exist for an extended period of time, a 10CFR50.59 Safety Evaluation shall be performed.

The guidance in Generic Letter 91-18 and SECY-97-035 should be considered to determine the time frame to perform the Safety Evaluation.

4 Rn.O

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2.2-Cognizance of Plant Conditions l

2.2.1 The Shift Manager has the primary responsibility for the safe operation of the facility and may only be relieved by another qualified individual with an active Senior Reactor

• Operator's License. The Shift Manager shall:

Maintain a broad perspective of operational conditions affecting the facility and not  ;

become involved in any single operation when multiple operations are taking place.

Ensure reactor parameters are maintained within established limits and procedures.

Maintain strict control of tests / activities affecting core reactivity.

• Never compromise nuclear safety to meet schedules.

. Terminate any activity considered adverse to reactor safety.

. Inform management of any significant discrepancies between expected and actual plant conditions.

2.2.2 Safe operation requires that the status of equipment affecting nuclear safety can be readily determined and that it remain under the direct control of the Shift Manager and NRC licensed operators. Verification of equipment and system operating status is performed in order to prevent:

D e Inadvenent bypassing ofinspections and tests.

. Unsafe conditions caused by operation of damaged or defective equipment.

e Incorrect or inappropriate operation of equipment.

2.3-Plant Configuration Control 2.3.1 Configuration control (physical and functional) shall ensure that:

• Availability and operability of equipment can be readily determined.

• Plant configurations are consistent with the design and hcensing bases.

• Activities affecting system availability and operability are effectively communicated.

• Progranunatic commitments are implemented and preserved.

2.3.2 Plant modifications shall be conducted in accordance with approved procedures or instructions to ensure the following:

. The latest as-built configuration accurately reflects the current design and licensing basis.

e Procedures used to operate or maintain plant equipment are maintained current.

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,U e Personnel responsible to operate, test, or maintain the affected systems are cognizant of the changes and the impact on Unit operation. Effect on off-normal and emergency operations will be thoroughly understood by those responsible for handling such '

situations.

. Temporary modifications are assessed for impact on Nuclear Safety prior to installation.

2.3.3 Work shall be perfonned in accordance with the established Maintenance Program to ensure related design basis, operating procedures and maintenance data have been  ;

updated as appropriate. l 2.4-Availability of Safety Systems 2.4.1 Availability of Safety Systems per Technical Specifications  ;

Risk to nuclear safety is reduced by assuring availability of safety systems. Therefore, I equipment required by Technical Specifications needs to be maintained at the highest state of availability. The following guidelines should be implemented when working l with systems and equipment specifically required to mitigate consequences of major accidents: l A '

• Availability of safety systems that prevent or mitigate accidents needs to be maximized during an outage. ,

e Maintenance, surveillance, or design changes which take a portion of Technical j Specification equipment out of service need to be evaluated for retum to service i testing (Post Maintenance Testing) requirements prior to performing the maintenance.

surveillance, or design change where possible.

. The number and duration of activities simultaneously conducted on systems and components required to function to prevent or mitigate accidents should be  ;

minimized.

. If equipment failures or deviations from planned schedules force concurrent outages of key mitigating systems, then an evaluation using PRA insights should be performed to provide additional guidance on prudent compensatory measures.

• Open safety-related work orders are to be reviewed prior to unit startup following an outage, to ensure safety functions have not been degraded and are in compliance with 1 I

the Unit's design basis.

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,Qf3 2.4.2 Defeating Equipment or System Automatic Safety Functions e

The substitution of manual operator actions for safety-related automatic functions will be minimized and all practical efforts should be taken to maintain equipment in Ge as-designed configuration.

If an automatic safety function, which is specifically stated or implied in Technical Specifications is not available, the equipment or system is to be declared inoperable and the applicable action statement entered.

e - Automatic safety functions required by Technical Specifications will not be replaced with manual actions unless evaluated per the guidance of Generic Letter 91-18 and a i 10CFR50.59 Safety Evaluation is prepared. Otherwise, prior NRC approval is ,

required either in the form of a license amendment or through the use of the

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Enforcement Discretion process.  :

• Manual operator actions necessary to place the plant in a safe condition (which 4 includes recovery from a transient) consistent with the provisions of 10CFR50.54(x) l are not precluded.  !

If an automatic safety function, which is described in the UFSAR but not required by Technical Specifications,is not available. a safety evaluation must be performed to suppco continued operation.

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3.0-MANAGEMENT OF ACTIVITIES AND EVOLUTIONS '

v 3.1-Conduct of Maintenance 3.1.1 Maintenance Activities Considerations e Maintenance activities shall be minimized under the following situations:

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1) During activities that increase risk or safety consequences (e.g., during reduced inventory, refueling operations or PRA-identified risk significant equipment l outages).

2) When preparations for the maintenance are not complete.

3) When return to service testing requirements (PMT) have not been established.  ;

• Maximize safety awareness during maintenance evolutions conducted during periods ofincreased operating risks.

3.1.2 On-Line Maintenance

. In performing On-Line Maintenance an assessment of the total plant equipment which is out of service shall be performed to determine the overall effect on the performance of safety functions. Whenever possible, such an analysis should be supported by risk analysis techniques (e.g., PRA reviews or a pre approved PRA based system risk relationship matrix).

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The operating status of structures, systems and components (SSCs) during On-Line Maintenance shall be readily determinable and remain under the control of the NRC-Licensed Operators.

. l Prior to performing any On-Line Maintenance, the status of SSCs important to that '

evolution shall be verified.

On-Line Maintenance activities simultaneously conducted on SSCs required to function to prevent or mitigate accidents should be performed only if allowed by a l PRA review or a pre approved PRA based system risk relationship matrix.

. Unit and switchyard activities should be minimized when critical On-Line Maintenance evolutions are taking place so that full attention can be focused on l Nuclear Safety. l l

If On-Line Maintenance will result in a Unit configuration or operation which is inconsistent with the licensing basis and administrative controls, an analysis shall be l performed in accordance with the requirements of 10CFR50.59. '

For off-normal conditions and planned activities, the need for compensatory measures and resources shall be determined. Whenever possible additional guidance should be derived from PRA insights.

Entrance into Technical Specification Action Statements shall require special controls  ;

as follows: l (l 1) Entrance into Action Statements should be minimized.

V '2) Plant Management shall ensure that time spent in Action Statements is minimized by proper scheduling of resources planning and approval of work activities, and communication of priorities and activity status.

3) Planned activities that will result in entrance into multiple Action Statements shall consider all structures, systems and components (SSCs) that are out of service in order to determine the overall effect on plant risk. Whenever possible PRA insights should be utilized.

4) Planned work should not be scheduled to encompass more than half of the allowed Action Statement time without additional management review and approval.

5) Repeated entry and exit from Action Statements shall be avoided.

3.2-Conduct of Outages 3.2.1 Outage Safety Assessment An independent Outage Safety Assessment shall be performed for the planned outage activities potentially affecting safety to assure all activities are bounded by the Technical Specifications, UFSAR, and applicable procedures.

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fn) x_) 3.2.2 Startup Assessment Prior to operation after an outage, an assessment shall be conducted by the Unit Director.

Each applicable department shall identify the unit's readiness to operate from the department's perspective, identify items not resolved or completed and determine their potential impact on safe operation. Based on an assessment of this information, the Unit Director will determine if Unit operations may proceed.

3.2.3 Outage and Planning Considerations .

. Optimize safety by considering the risk of performing maintenance for selected equipment and systems (e.g., Shutdown Cooling System) at power versus in an outage.

• Maximize availability of safety-related equipment.

. Minimize any increase in risk associated with removing equipment from service to  ;

perfomi maintenance by considering the total plant equipment which is out of service.

Whenever possible PRA insights should be utilized.  ;

e Minimize time spent at reduced Reactor Coolant System inventory.

. Mid-loop operations with fuel in the core shall be supported by a PRA review and the appropriate controls and heightened awareness to address the elevated risk posed by n the configuration.

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3.3-Evolutions 3.3.1 Critical Evolutions and Priorities Significant reactivity changes, including reactor startup, reactor shutdon, significant reactor power changes, and safety system tests such as reactor physics tests, shall be the key focus of the control room and the highest priority activity of the Unit. l l

Operators shall conduct procedure reviews and receive simulator training, where feasible,  ;

in preparation for plant cooldown, draindown, reactor startup, etc.

3.3.2 Test Controls i

. Testing activities including generic, special, or infrequently performed tests, shall be conducted such that the tests accomplish their intended objective, personnel and plant safety are not endangered, regulatory and other administrative controls are not violated, and plant operation is not jeopardized.

. Test controls required by 10CFR50 Appendix B, Criterion XI, for tests that can g3 potentially affect core safety shall be supplemented by additional special test controls

() to assure test criteria address nuclear core safety and the recommendations of SOERs 87-1 and 91-1.

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i 3.3.3 Infrequently Performed or Complex Tests or Evolutions 5

l Infrequently performed or complex tests or evolutions such as the following may warrant additional senior line management oversight or controls to ensure plants are not operated in a manner that could degrade the margin of nuclear safety or violate license requirements:

!- e Evolutions not specifically covered by existing normal or abnormal operating procedures.

• Evolutions that seldom are performed even though covered by existing normal or i abnormal procedures (e.g., plant startup after an outage that involves significant changes to systems, equipment, or procedures related to the core, reactivity control, or reactor protection).

• Special, infrequently performed surveillance testing that involves complicated 2 sequencing of unusual plant configurations.

j e Evolutions that require the use of special test procedures in conjunction with existing j procedures.

e Conditions where the performance of multiple relatively simple tests or evolutiont

may make plant control complex (e.g., the conduct of many system tests prior to j startup following a prolonged outage).

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! 4.0-CONSERVATIVE DECISION-MAKING i Decisions affecting nuclear safety shall be based on established methods, procedures, and  !

a thorough understanding of plant conditions. Personnel are expected to seek the necessary information to make informed decisions and to exercise conservative decision-making to ensure nuclear safety.

It is not always obvious which decisions affect nuclear safety. Decisions affecting  !

availability or reliability of non-safety grade systems may affect nuclear safety by causing transients, or by affecting their probability of occurrence, or by reducing margin of safety.

Personnel are expected to exercise conservative decision-making by approaching decisions with a questioning attitude and concern for potential consequences.

Management shall support nuclear safety through its actions and the clear endorsement and frequent reinforcement of conservative decision-making.

The following general requirements will be adhered to in order to support conservative decision-making:

4.1 Maintenance, modification, and testing activities that have the potential to reduce decay O heat removal or shutdown margins shall be performed with either the reactor vessel defueled or the maximum number of safety and key support systems in service.

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l 4.2 The Unit shall have controls in place to ensure that operability determinations appropriately reflect commitments associated with that equipment as well as the applicable Technical Specifications. Operability of equipment shall be assessed against all commitments associated with that equipment, not only those contained in the Technical Specifications.

4.3 No physical work with the potential to breach the primary boundary will be performed on the primary reactor coolant system up to and including the first closed isolation valves while at power.  ;

i 4.4 Equipment that is unavailable which can affect the frequency of plant transients shall be i restored to service on a pnonty basis even if not required by the Technical Specifications.  !

l l 4.5 Personnel are expected to find their own safety and quality problems. When problems are found any other way, management shall investigate the self assessment deficiency promptly through the established corrective action program and have it thoroughly

) corrected. ,

4.6 The root cause program shall be used to ensure proper corrective action is taken for events that could challenge nuclear safety.  ;

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() 4.7 Awareness of operator work-arounds shall be such that prompt corrective action will be taken to ensure a work-around or the aggregate of outstanding work-arounds does not impede the operator from operating the unit in accordance with procedures or affect his ability to respond to abnormal and emergency situations.

5.0-REVIEW AND MONITORING OF OPERATION 5.1 Self Check Program The need for each individual's attention to detail is encouraged through implementation of a self check program ( Stop, Think, Act and Review) to avoid personnel errors.

5.2 Independent Reviews  !

Independent reviews ofitems affecting safety are required to minimize bias and provide safeguards against normal influences from daily operating objectives and concerns.

These critical examinations of potential or actual safety significant items are completed by qualified reviewers not directly responsible for the design or operation function under rev;ew.

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ll 53 Verifications Design verifications shall be performed to verify incorporation of design requirements, accuracy of documents used in the design basis, and justification of conclusions.

Independent verifications ofitems affecting nuclear safety during testing, operation, and maintenance shall verify that potential or actual safety significant evolutions are completed to administrative requirements. Where adverse safety consequences of actions l may be immediate, concurrent / double verification of required conditions may be

necessary. This process precludes operation of damaged or defective equipment, l operation of equipment other than that which is intended to be operated, and incorrect or inappropriate operation of equipment. j i

5.4 Self-Assessment Self-assessments will be used routinely to determine areas for improvement in terms of compliance and performance. Departments will use self-assessments as a means to identify and correct significant issues within their areas before they are identified by  ;

Oversight or external agencies. They will be focused to address specific areas, and the l l

findings will be addressed and tracked within the corrective action program.  !

5.5 Monitoring of Safety Performance The-availability of key plant safety systems shall be monitored consistent with INPO reporting requirements and Maintenance Rule requirements. Integrated safety performance shall be monitored on a periodic basis using PRA techniques such as the Backward-Looking Risk Monitor. ,

5.6 Oversight The on-site operations review committee (PORC/SORC), Nuclear Oversight and off-site nuclear safety audit review committee (NSARC/NSAB) shall provide oversight of operations, maintenance, design and support activities.

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O REFERENCES 1

1) Virginia Power Nuclear Standard, ASNS-3000, Nuclear Safety Policy, March 26,1996

2) INPO 96-006, Performance Objectives and Criteria for Operating Nuclear Electric Generating Stations

[ 3) INPO 92-009, Guidelines for the Organization and Administration of Nuclear Power l Plants

4) INPO 90-020, Performance Objectives and Criteria for Corporate Evaluations

5) INPO Significant Operating Experience Report (SOER) 96-1, Control Room Supervision, Operational Decision-Making, and Teamwork

6) INPO Significant Operating Experience Report (SOER) 96-2, Design and Operation Conditions for Reactor Cores

7) INPO Significant Operating Experience Report (SOER) 94-1, Non-Conservative Decisions and Equipment Performance Problems Result in a Reactor Scram, Two Safety O Injections and Water Solid Conditions

8) INPO Significant Operating Experience Report (SOER) 91-1, Conduct ofInfrequently Perfbrmed Tests or Evolutions

9) _ INPO Significant Operating Experience Report (SOER) 87-1, Core Damaging Accident Following an Improperly Conducted Test

10) INPO Document, " Excellence in Human Performance," November,1995

11) INPO Document, " Principles for Enhancing Professionalism of Nuclear Personnel,"

March,1989

12) NSAC Report 125, Guideline for 10CFR50.59 Safety Evaluations

13) 10CFR50 Appendix B

14) USNRC, Generic Letter 91-18," Resolution of Degraded and Noncomforming Conditions and on Operability"

15) Principals of Nuclear Power Plant Operational Safety, January 1996, W. R. Corcoran et al.

16) SECY 97-035," Proposed Regulatory Guidance Related to implementation of 10 CFR 50.59 (Changes, Tests and Experiments)," February 1997 D Rev.0

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