ML050950080

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FENOC - Submittal of Revision 8 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14
ML050950080
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 04/01/2005
From: Bezilla M
FirstEnergy Nuclear Operating Co
To: Caldwell J
NRC/RGN-III
References
1-1409
Download: ML050950080 (50)
v • d • e


Text

. FimtEnergy Nuclear Operating Company 5501 Norrh Sfate Roufe 2 Oak Harbor. Ohio 43449 Matk 8. Bezilla Vice President - Nuclear 4 79-32 1-7676 Fax: 419-321-7582 Doc ke t N umber 5 0- 3 46 License Number NPF-3 Serial Number 1 - 1 409 A p r i l 1, 2005 hlr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I l l 2443 Warrenville Road, Suite 2 10 Lisle, IL 00532-4352 SulJject: Submittal of Revision 8 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

Dear Mr. Caldwell:

The purpose of this letter is to submit Revision 8 of the Davis-Besse Nuclear Po~krer Station (DBNPS) Operational Improvement Plan Operating Cycle 14, dated March 24. 2005, to the Nuclear Regulatory Commission (NRC). By letter dated December 22, 2004, the FirstEnergy Nuclear Operating Company (FENOC) submitted Revision 7 (DBNPS Letter Serial Number 1 - 1396) of the DBNPS Operational Improvement Plan Operating Cycle 14. The NRC letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Coiifirniatory Action Letter, and Issuance of Confirmatory Order, (DBNPS Letter Log Number 1-4524) requires FENOC to notify the NRC of changes in the actions committed to in this Plan.

The DBNPS Operational Improvement Plan, Revision 8, supercedes all previous revisions in their entirety.

This revision to the Plan includes the identification of initiative actions completed since the prior revision of the Plan, a change of sponsorship as a result of respoiisibility transitions fi-om the reorganization and a change of owner as a result of prograni and process transitions from the reorganization. The testing of maintenance staff for training improvements was divided into two separate components of: 1 ) maintenance staff testing; 2) and maintenance training curriculum changes. The maintenance staff testing is complete with the training element outstanding.

Completion dates of two commitments within the Engineering Improvement ii1itiatii.e are extended through the cycle to include scope of work that requires a plant outage. Other changes to key actions and barrier attribute performance indicators are detailed in Attachment 2 of this letter.

Regulatory commitments are identified in the Commitment List (Attachment 1 ) n.ith changes in comniitments from Revision 7 to Revision 8 identified in bold italicized text.

Docket N uni be r 5 0- 3 46 License Number NPF-3 Serial Number 1-1409 Page 2 of 2 FENOC will update the DBNPS Operational Improvement Plan Operating Cycle 14 periodically to provide a status of the actions, and will submit subsequent revisions to the NRC following these changes.

If you have any questions or require further information, please contact Mr. Clark A. Price, Manager - Regulatory Compliance, at (41 9) 321 -8585.

Sincerely yours, Attachments Enclosure cc:

USNRC Document Control Desk S. A. Reynolds, Chairman NRC 0350 Panel J. B. Hopkins, DB-1 NRC/NRR Senior Project Manager C. S. Thomas, DB-1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Page 1 of8 COMMITMENT LIST The following list identifies those actions committed to by FENOCs Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for infomiation and are not regulatory commitments. Please notify the Manager - Regulatory Compliance (41 9-321 -8585) at the DBNPS of any questions regarding this document or associated regulatory commitments.

The following commitments are based on Revision 8 of the Davis-Besse Operational Improvement Plan Operating Cycle 14. Changes from previous commitments in Revision 7 of the Operational Improvement Plan are identified in bold Italics.

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COMMITMENTS

1. Organizational Effectiveness Improvement Initiative Improve individual and organizational performance through development and utilization of alignment tools at the Department/Section levels Implement FENOC Business Practices for:

a)

Focused Self-Assessments b) Ongoing Self-Assessments c)

Benchmarking d)

Semi-Annual Collective Significance Self-Assessments Directors and Managers to attend a Leadership Academy to improve management ski 1 1 s Provide formal Management Observation Skills Training Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-000 1, Operations Expectations and Standards Implement actions to improve trending of major plant evolutions utilizing the Management Observation Program to track performance and feedback Provide face-to-face communications training to all site supervisors and above Re-evaluate all Davis-Besse supervisors to assess competency for current positions Conduct Supervisor and Manager Talent Management Talks IO. Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings in accordance with Davis-Besse Business Practices DUE DATE June 30,2005 Complete C omp 1 et e Complete Complete Complete Complete Co ni p 1 et e Complete Co m p 1 e te December 3 1,2005 C om p 1 et e Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Page 2 of 8 COMMITMENTS

2. Operations Improvement Initiative DUE DATE I. Implement Operations Improvements:
a. Initiate Operations Leadership Improvements Complete
b. Initiate the 5 year staffing plan Co ni p 1 et e
c. Implement improvements to Operations work stations Co ni p 1 et e
2. Improve Operator knowledge, skills and abilities through testing, Conrplere training and nientoring
3. Implement the Operations Improvement Action Plan, including:

Co m p 1 ete

a. Strengthening Operating Crews, including assessment of operators, training on procedure use, and improving command and control
b. Strengthening Operating Procedures, including validation of key operating procedures and use of reverse pre-job briefs
c. Strengthening Operations Management, including use of Operations Oversight Managers until no longer needed
d. Strengthening Independent Oversight of Operations
d. Implement common FENOC Operations work process tools Conrplete
4. Strengthen Communications within Operations 5. Benchmark Conduct of Operations
6. Align Perforniance Indicators to Conduct of Operations C onip 1 et e C onip 1 et e Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 409 Page 3 of 8 COMMITMENTS DUE DATE

3. Maintenance Improvement Initiative
1. Utilize post-job evaluations, operating experience, and lessons Complete learned from rework activities to identify improvements in Maintenance training and standards scheduling, and implementation of critical equipment outages to identify improvements training and development to establish improved ownership and accountability of Plant materiel condition
5. Perform testing of Maintenance staff knowledge, skills and abilities to identify improvement actions and incorporate into training
2. Perform an assessment of Maintenance effectiveness work planning, Complete
3. Implement improvements of Maintenance Supervision through Complete
4. Implen~ent actions in the Maintenance individual commitment area Contplete
a. Perforitr skill arid knowledge testing to iderrtijy areas for Contplete irttpro vent erit
b. Incorporate ideirtiJied additional or revised trairiirig, if arty.

June 30, 2005

4. Training Improvement Initiative 1. Implement actions to improve individual and organizational performance and alignment by developing and providing training on design and configuration control to appropriate site staff the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers Coni p 1 et e
2. Establish engineering positional qualification requirements based on Cortiplete

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Page 4 of 8 COMMITMENTS

5. Work Management Improvement Initiative
1. Conimon Process
a. Complete training and mentoring to support the effective transition into the FENOC Work Management Process
b. Resolve gaps in process implementation and station procedures
c. Perform quarterly assessments of Condition Reports and Workweek critiques to ensure opportunities for improvement are addressed knowledge and awareness
d. Implement Risk Management process to improve station
e. Monitor and improve Order quality
a. Complete walk-down and validation of the Order backlog to ensure proper category, priority, consolidation and elimination of invalid orders
b. Complete Cycle Plan identifying equipment outages and providing the framework for addressing backlog Order priorities and results of the System Health Report
c. Develop perfomiance indicators to monitor and manage Order backlog
3. Outage Perfonnance
a. Forced Outage Schedule template and readiness
b. Mid-Cycle Outage Preparation
c. Clarify expectations and improve contractor performance
d. 14"' Refueling Outage Preparation
2. Maintenance Backlog Reduction DUE DATE Complete Co m p 1 et e Periodic through Cycle 14 Complete Co m p 1 et e Coni p 1 et e Complete Co m p 1 et e Coni p 1 et e Cotttplete Corrrplete February 28,2006

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Pagc 5 of 8

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COMMITMENTS

6. Engineering Improvement Initiative Implement actions to improve Safety Margin:
a. Determine the Safety Margin for the top 10 Risk Significant Systems and develop a plan to improve safety margins
b. Electrical System coordination improvements
c. Masonry/block wall re-analyses and design changes
d. Service Water improvements Perform additional Latent Issues Reviews Implement the Design Calculation Improvement Plan Enhance plant equipment performance through the FENOC Equipment Re1 i abi 1 it y Program Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations Schedule and conduct additional Program Compliance Reviews including:
a. Qualification of Program Owners
b. Development of Program Manuals
c. Creation of Performance Indicators Establish the appropriate level of workload for Engineering Change Requests and develop a plan to reduce and maintain the backlogs to that level Perfomi on-going self-assessments to determine if the problem solving process, NOP-ER-3001 has been properly implemented during the previous period Perform independent outside assessments of the effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations Implement electronic accessibility of design basis information and populate with 5 systems Expand the role of the Engineering Assessment Board (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations Establish criteria and modify appropriate procedures to restrict the use of At-Risk Changes in the plant modification process DUE DATE Coni p 1 et e Tlt roirgli Cycle I4 Tlirorrglr Cycle 14 Through Cycle 14 Periodic through Cycle 14 Through Cycle 14 Through Cycle 14 Complete Complete Periodic through Cycle 14 Periodic through Cycle 14 Corr1plete C omp 1 et e Co nip 1 et e

Docket Number 50-346 License Nuniber NPF-3 Serial Nuniber 1 - 1409 At t achm e t i t 1 Page 6 of 8 COMMITMENTS DUE DATE Engineering Improvement Initiative (Contd)

13. Re-institute the use of Quarterly System Health Reports and
14. Assign a Program Owner for the Problem Solving Process
15. Develop and implenient actions necessary to improve the C onip 1 et e Complete Coni p 1 et e Design Basis Assessment Reports technical issues problem solving capabilities in the Engineering organization.
7. Continuous Safety Culture Improvement Initiative
1. Monitor Safety Culture on a monthly basis
2. Assess Safety Culture using the FENOC Business Practice
3. Perform a Safety Culture assessnient utilizing an independent outside organization
4. Provide SCWE training to Site employees who have not completed the SCWE portion of the Site Employee Orientation Manual
5. Provide refresher training on SCWE and Safety Culture to Davis-Besse Supervisors and above
6. NQA to perfomi two Safety Culture Assessments
7. Employee Concerns Program group to perform two surveys of the Safety Conscious Work Environment
8. Perform an effectiveness assessment of the corrective actions taken in response to the November 2003 SCWE survey results Periodic through Cycle 14 December 3 1, 2005 Corrrplete Complete Complete 2004 Cortiplete 4

Quarter 2005 2004 Corriplete 4 Quarter 2005 Co ni p 1 et e

8. Procedure Improvement Initiative
1. Perform Self-Assessments on procedure use and adherence
2. Review the Davis-Besse procedure change process to ensure Complete alignment with FENOC standards for procedure preparation and revisions
3. Provide training on procedure use and adherence
4. Perform follow-up effectiveness reviews on procedure use and adherence Periodic through Cycle 14 Co nip 1 et e September 30, 2005

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Page 7 of 8 COMMITMENTS

9. Corrective Action Program Improvement Initiative
1. Implement the Apparent Cause Improvement Plan:
a. Strengthen procedural requirements for apparent cause evaluations, including analytical methods to be used
b. Corrective Action Review Board review of Apparent Cause Evaluations until standards are consistently met
c. Identify Apparent Cause Evaluators
d. Develop Training Program and Expectations and provide training to the Apparent Cause Evaluators (Initial Evaluator Classes and Additional Classes in 2004)
e. Qualify the trained Apparent Cause Evaluators using the Systematic Approach to Training
f. On an interim basis, rotate team of apparent cause evaluators to Support Services
g. Company Nuclear Review Board (CNRB) review of selected Apparent Cause Evaluations
2. Establish the appropriate level of workload for Condition Report Evaluations and Corrective Actions and develop a plan to reduce the backlogs to those levels
3. Perform a focused Self-Assessment of implementation of the Corrective Action Program using industry peers
4. Reestablish the Corrective Action Program trending process
5. Provide Apparent Cause training to Managers DUE DATE Complete Complete Co ni p 1 et e Co ni p 1 et e Co m p 1 et e Co nip 1 e te Periodic through Cycle 14 Co nip 1 e te Coni p 1 e te Coin p let e Coin p 1 et e

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Page 8 of 8

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COMMITMENTS

10. Internal and External Oversight Improvement Initiative Supplement quality oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical Supplement management oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical Focus more quality oversight on cross-functional activities and interfaces Review and revise the master assessment plan at all three FENOC sites Conduct an external assessment to evaluate the progress of organizational improvements in the areas of critical self-assessments and performance observations Utilize INPO Assist Visits to assess the effectiveness of Improvement Initiatives Perforni Quality Oversight of Engineering using the Continuous Assessnient Process Conduct assessment activities of the Corrective Action Program to evaluate effectiveness of corrective actions taken to improve impletnentation and improve trend evaluation DUE DATE C on1 p 1 et e Co nip 1 et e Complete C o ni p 1 et e Co m p 1 et e Cotrrplere Periodic through Cycle 14 Periodic through Cycle 14

Docket Number 50-346 Liccnse Number NPF-3 Serial Number 1-1 409 Page 1 of4 6.lb CHANGES TO CYCLE 14 OPERATIONAL IMPROVEMENT PLAN, REV. 8 Implement actions to improve TITLE ACTION/PI NUMBER 6.lc 9.lg Key Actions safety margin: Electrical system coordination improvements lniprove Safety Margin:

Masonryiblock wall re-analysis and design changes Company Nuclear Review Board (CNRB) review of selected Apparent Cause Evaluations Sponsor List, Page 6 Changed owner from R. Hansen to 1.

3.5 Perform testing of Maintenance staff knowledge, skills and abilities to identify improvement actions and incorporate into training.

CHANGE Changed sponsor of Initiative 10 Internal and External Oversight Improvement to J. Rinckel. (Transfer of duties from reorganization is comDlete)

Extended due date to Second Quarter 2005.

Divided this commit men t into two parts in the OIP. Actions taken through 12/3 1/04 are documented as complete. Incorporation of any identified training needs is a sub-set with a due date of 6/30/05.

In keeping with the Systematic Approach to Training (SAT) process, the applicable Curriculum Review Committee (CRC) will review the results of the Knowledge Surveys and determine if any training is needed for the totics tested.

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 At t ac limen t 2 Page 2 of 4 TITLE ACTlONlPl NUMBER Performance Indicators 1-04 1-05 1-06.2 1-1 1 1-12 P-0 1 P-06 M-05 M -06 Individual Error Rate Employee willingness to raise concerns Operator Work Arounds -

Level 2 Employee Willingness to Use the Corrective Action Pro gram Worker Confidence in Raising Safetv Concerns Corrective Action Program Effectiveness Program and Process Error Rate Management Field Observations are self-critical Effectiveness of Management and Supervisors CHANGE The Fleet PI Reference number changed to D-HP-01.

This Performance Indicator will be assessed through the annual SCWE survey.

Added ranking criteria and reworded Obi ective/Goal.

Added the Annual Safety Culture Assessment as a source reference.

Delete NQA.

Changed owner from Griffith to Am i don.

Changed owner from Griffith to Amidon.

Changed grading criteria for weighted values for backlog and root cause.

Changed from a pass/fail to a graded average.

The Fleet PI Reference number changed to D-SPO-05.

The Fleet PI Reference number changed to D-HP-02.

Changed PI Reference in the Operational Improvement Plan to Annual Safety Culture Assessment, NQA Field Observations and Management Observations.

Changed to annual PI reporting.

The Fleet PI Reference number changed to XD-PDE-05.

Docket Number 50-346 License Number NPF-3 Serial Nuniber 1 - 1409 Attach M en t 2 Page 3 of 4 M-07 I

I 34-08 I-----

0-01.2 0-02 r---

0-03 I

Talent Management and Personnel Development Leadership Development Completion of Primary Elements Investigation Responsiveness to DBOV Identified CRs CR DBOV Review Tim el i ness Removed monthly from the Goal statement in the Operational Improvement Plan. This is a semi-annual Performance Indicator.

Removed monthly from the Goal statement in the Operational Improvement Plan. This is a semi-annual Performance Indicator.

Added criteria for Year-to-Date and Y ear-End Expectancy.

Changed from measuring the responsiveness to DBOV-initiated CRs in units of days to measuring this responsiveness as a ratio (percentage) of the sites responsiveness to all CRs.

Additionally, CRs identified as immediately closed (CC) will no longer be included, since they require no response. DBOV-initiated CRs that DBOV answers are also not included since the indicator is monitoring line organization resDonsiveness to DBOV issues.

Changed from measuring the 90 of CR reviews completed within 15 days to measuring the number of days required to complete 100% of the CR reviews.

Changed the goal from 90% of CR reviews to be accepted within 15 days to the goal of 100% of CR reviews to be accepted within 14 days.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 409 Page 4 of 4 0-04 0-05 CA DBOV Verification Timeliness Timeliness of NQA Audit Report Issuances Changed from measuring the % of CA reviews completed within 30 days to measuring the number of days required to complete 100% of the CA reviews.

Changed the goal from 90% of CA reviews to be accepted within 30 days to the goal of 100% of CA reviews to be accepted within 30 days.

Deleted use of calendar days from end of quarter and only use working days from end of quarter.

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 Enclosure Davis-Besse Nuclear Power Station Operational Improvenient Plan Operating Cycle 14 Revision 8 March 24,2005 (34 pages to follow)

sooz 'PZ WJeW 8 NOISIMH

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Table of Contents Page Introduction...........................................................................................

2 Barriers To Ensure Nuclear Safety.......................................................

3 Davis-Besse Improvement Initiatives....................................................

6 Improvement Initiative Key Actions......................................................

7 Safety Barrier Attributes and Goals.......................................................

24

. Individual.........................................................................................

25 Programs 28 Management 29 Oversight 31 Page 1 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Introduction To ensure continued improvements and sustained Power Station, the Leadership Team has developed Cycle 14 performance in Nuclear Safety and Plant Operation at the Davis-Besse Nuclear this Improvement Plan to focus on key improvement initiatives and safety bamers essential to safe restart from the Reactor Pressure Vessel Head degradation extended plant outage and into subsequent operating cycles. This plan provides for a managed transition from the organizational and programmatic actions taken to support the Davis-Besse Return to Service Plan and Building Block Plans to that of normal plant operations and refueling outages.

The initiatives discussed in this plan were derived from lessons learned during the extended plant outage which resulted from the significant Reactor Pressure Vessel Head degradation identified at the beginning of the 13h Refueling Outage. During the extended outage, numerous improvements were made in the areas of Safety Culture, Management, Human Performance, System Health and Programs as described in the Return to Service Plan and the Building Block Plans. However, additional improvements are required to achieve world class performance and to ensure that the safety bamers that failed to detect the significant RPV Head degradation are maintained to prevent a recurrence of an event in the future.

As described in the Return to Service Plan, the numerous root causes associated with the Reactor Pressure Vessel Head degradation could be grouped into the areas of Nuclear Safety Culture; ManagementPersonnel Development; Standards and Decision-making; Oversight and Assessments; and ProgramsKorrective ActionsRrocedure Compliance. Actions described in each of the Building Blocks were designed to address numerous significant improvements in each of those areas. This transition plan of Operational Improvements focuses on the four primary safety bamers of Individual, Programs, Management, and Oversight (as described in the following pages) to ensure improvements realized during the extended outage remain in place and are further built upon to improve performance in the future. This plan will ensure that the improvements made to Davis-Besse are built to last.

This plan will be used by the Davis-Besse Leadership Team on a monthly basis to monitor safety barrier attributes that would provide early detection of declining trends in performance and to focus on major initiatives to achieve operational excellence. This plan is a living document and will be periodically updated and revised to address completed actions and add new initiatives as determined and approved by the Senior Leadership Team.

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Barriers To Ensure Nuclear Safetv The safety of nuclear power relies heavily on the defense in depth concept. Nuclear power plants are designed with robust systems and redundant back-up safety systems in the unlikely event of a failure. However, systems and equipment must still be operated, maintained and designed by people to ensure reliability and availability if called upon to perform an intended safety function. The first barrier to ensure safety is the Individual. The operator, maintenance technician, engineer and all the other support personnel play an integral role in monitoring plant status and maintaining systems and equipment in top-notch condition. Thus, ensuring that the individuals that support nuclear power plant operation are highly qualified, trained and motivated to do the best job possible is an essential barrier to ensure nuclear safety.

To guide the individual in performing their required job functions, numerous Programs have been put in place to address the operations, maintenance, design and licensing basis activities performed daily at the station. Programs are implemented by procedures and other written documents to ensure a consistent approach by the individual. Thus, programs are another essential barrier to ensure nuclear safety.

Management also plays a key role in nuclear safety. Management is responsible for providing the proper focus on priorities that ensure the plant is operated and maintained to high standards and expectations. Management is also responsible for creating a work environment that is conducive to a safety conscious work environment and strong safety culture, and to ensure there are adequate staffing levels of qualified and motivated individuals in every department. Management, therefore, is also considered one of the barriers essential to nuclear safety.

To ensure that the individual and management (using established programs and associated procedures) performs their duties to high standards and maintains the proper safety focus, Oversight organizations provide another barrier for nuclear safety. Oversight checks for adverse trends in performance and is independent of other pressures. Independent oversight, when properly used, can identify differences from industry norms for early detection of potential weaknesses developing in the safety barriers.

Together these four barriers work in conjunction to contribute to the safe operation of Davis-Besse.

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 This illustration represents how the four safety barriers failed, allowing the degradation of the RPV Head to go undetected for several years and serves to anchor the lessons learned and corrective actions taken to prevent recurrence.

Programs Oversight C

H E

Individual Management E

Davis-Besse Nuclear Power Station C

H A

L L

E Operational Improvement Plan G

E Cycle 14 1 Barriers Demonstrating FENOCs Strong Safety Focus 1 L

Competent Strong Experienced Individual Programs Management c

Independent Oversight FENOC Vision:

People with a strong safety focus delivering top Feet operating performance Page 5 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Davis-Besse Initiatives:

Based on lessons learned from the Reactor Pressure Vessel Head degradation and during the extended plant outage, a series of key initiatives have been developed by the Leadership Team to focus on opportunities for continued improved performance. These initiatives extend beyond those significant improvements already realized during the extended outage and achieved prior to restart. These initiatives will provide additional improvements to further strengthen each of the four bamers. Details for each initiative are provided in the following pages.

~

Sponsor M. Bezilla B. Allen B. Allen B. Allen B. Allen S. Loehlein M. Bezilla M. Bezilla M. Bezilla J. Rinckel Davis-Besse In it iatives 1. Organizational Effectiveness Improvement

2.

Operations Improvement

3.

Maintenance Improvement

4.

Training Improvement

5.

Work Management Improvement

6.

Engineering Improvement

7.

Continuous Safety Culture Improvement

8.

Procedure Improvement

9.

Corrective Action Program Improvement IO. Internal and External Oversight Improvement Barriers Enhanced E !! 8 X

X X

X X

X X

X E

CT) -

f b

X X

X X

X

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 1 Organizational Effectiveness Improvement Initiative DESIRED OUTCOME: Improved Human Performance, Leadership and Team Alignment through Critical Self-assessments, Use of Operating Experience, Industry Benchmarking and Communications Key Actions 1. Improve individual and organizational performance through development and utilization of alignment tools at the De part men t/Sec t i o n I eve Is a) Focused Self-Assessments b) Ongoing Self-Assessments c) Benchmarking d) Semi-Annual Collective Significance Self-Assessments

2. Implement FENOC Business Practices for:

(Included in Focused Self-Assessment Business Practice)

3. Directors and Managers to attend a Leadership Academy
4. Provide formal Management Observation Skills Training to improve management skills Owner M. Trump L. Dohrmann D. Haskins J. Reddington nsor: M. Bezilla I

2"d Qtr 2005 Complete Complete Complete Complete Complete Com plete Page 7 of 33 Revision 8

Davis-Besse Nuclear Power Station Opera t iona I I m provemen t Plan Cycle 14 1 Organizational Effectiveness Improvement Initiative continued

5.
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Key Actions Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards Implement actions to improve trending of major plant evolutions utilizing the Management Observation Program to track performance and feedback Provide face-to-face communications training to all site supervisors and above Re-evaluate all Davis-Besse supervisors to assess competency for current positions Conduct Supervisor and Manager Talent Management Talks

10. Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings in accordance with Davis-Besse Business Practices Owner K. Fehr K. Fehr D. Haskins D. Haskins D. Haskins M. Lark-Landis iponsor: M. Bezilla Completion Complete Complete Complete 4th Qtr 2005 Complete through Cycle 14 Page 8 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

2. Operations Improvement Initiative DESIRED OUTCOME: Establish the clear leadership role of Operations through improved Organizational Effectiveness and Alignment to the FENOC Processes Key Actions
1. Implement Operations Improvements:
a. Initiate Operations Leadership Improvements
b. Initiate the 5 year staffing plan
c. Implement improvements to Operations work stations
d. Implement common FENOC Operations work process
2. Improve Operator knowledge, skills and abilities through tools Owner K. Ostrowski K. Ostrowski D. lmlay K Ostrowski M. Trump mnsor: B. Allen Completion Co m p I ete Co m p I ete Complete Complete Complete testing, training and mentoring Page 9 of 33 Revision 8

Davis-Besse Nuclear Power Station K. Ostrowski K. Ostrowski K. Ostrowski Operational Improvement Plan Cycle 14 Complete Complete Complete

2. Operations Improvement Initiative continued Key Actions
3. Implement the Operations Improvement Implementation Action Plan, including:
a. Strengthening Operating Crews, including assessment of operators, training on procedure use, and improving command and control
b. Strengthening Operating Procedures, including validation of key operating procedures and use of reverse pre-job briefs
c. Strengthening Operations Management, including use of Operations Oversight Managers until no longer needed
d. Strengthening Independent Oversight of Operations
4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations
16. Alian Performance Indicators to Conduct of Operations Sponsor: 6. Allen Owner I Completion K. Ostrowski I Complete I

Y I

I Page 10 of 33 Revision 8

Davis-Besse Nuclear Power Station M. Stevens M. Stevens M. Stevens M. Stevens Operational Improvement Plan Cycle 14 Complete Complete Co m p I ete Complete

3. Maintenance improvement Initiative DESIRED OUTCOME: Improved Ownership and Materiel Condition of the Davis-Besse Nuclear Power Station Key Actions 1. Utilize post-job evaluations, operating experience, and lessons learned from rework activities to identify improvements in Maintenance training and standards
2. Perform an assessment of Maintenance effectiveness in work planning, scheduling, and implementation of critical equipment outages to identify improvements
3. Implement improvements of Maintenance Supervision through training and development
4. Implement actions in the Maintenance individual commitment area to establish improved ownership and accountability of Plant materiel condition Sponsor: B. Allen Owner I Completion Page I I of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

3. Maintenance Improvement Initiative continued Key Actions abilities to identify improvement actions and incorporate into training
a. Perform skill and knowledge testing to identify areas for
b. Incorporate any identified training needs into training
5. Perform testing of Maintenance staff knowledge, skills and imp rovemen t material Owner M. Trump bonsor: B. Allen Completion Corn p I et e 2"d Qtr 2005 Page 12 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I,

I

4. Training Improvement Initiative DESIRED OUTCOME: Improved Individual And Organizational Performance through Training Key Actions 1. Implement actions to improve individual and organizational performance and alignment by developing and providing training on design and configuration control to appropriate site staff
2. Establish engineering positional qualification requirements based on the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers Owner M. Trump M. Trump Completion Com p I ete Complete I

Page 13 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Key Actions

1. Common Process
5. Work Management Improvement Initiative Owner W. Mugge DESIRED OUTCOME: Provide for the effective and efficient cross-organizational utilization of resources in achieving a high standard of plant materiel condition by conducting the right work at the right time for the right reasons Sponsor: B. Allen Corn plet ion Complete Complete through Cycle 14 Complete Complete I1
e. Monitor and improve Order quality Page 14 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Sponsor: B. Allen Completion Complete Complete Com pl et e Complete Corn pl ete

5. Work Management Improvement Initiative continued I

Key Actions

a. Complete walk-down and validation of the Order backlog to ensure proper category, priority, consolidation and elimination of invalid orders
b. Complete Cycle Plan identifying equipment outages and providing the framework for addressing backlog Order priorities and results of the System Health Report
c. Develop performance indicators to monitor and manage Order backlog
3. Outage Performance
2. Maintenance Backlog Reduction
a. Forced Outage Schedule template and readiness
b. Mid-Cycle Outage Preparation
c. Clarify expectations and improve contractor performance
d. 1 4'h Refueling Outage Preparation Complete 2/28/06 Owner W. Mugge W. Mugge W. Bentley C. Hawley W. Bentlev I

Page 15 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative DESIRED OUTCOME: Improved quality of Engineering products, increased access to Design Basis information, and continued improvement in Safety Margins of the Station Key Actions
1. Implement actions to improve Safety Margin:
a. Determine the Safety Margin for the top 10 Risk Significant Systems and develop a plan to improve safety margins b. Electrical System coo rd i nation i m p rove men t s
c. Masonryhlock wall re-analyses and design changes
d. Service Water improvements
2. Perform additional Latent Issues Reviews
3. Implement the Design Calculation Improvement Plan
4. Enhance plant equipment performance through the FENOC Equipment Reliability Program
5. Develop and implement the plan to enhance System Engineering ownership of plant systems in support of ODerations SI Owner J. Grabnar B. Boles J. Grabnar R Hovland B. Boles onsor: S. Loehlein Completion Complete through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 Com p let e Page 16 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative continued Key Actions
6. Schedule and conduct additional Program Compliance Reviews including:
a. Qualification of Program Owners
b. Development of Program Manuals
c. Creation of Performance Indicators
7. Establish the appropriate level of workload for Engineering Change Requests and develop a plan to reduce and maintain the backlogs to that level
8. Perform on-going self-assessments to determine if the problem solving process, NOP-ER-3001 has been properly implemented during the previous period
9. Perform independent outside assessments of the effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations
10. Implement electronic accessibility of design basis information and DoDulate with 5 svstems I

Owner R Hovland J. Grabnar R Hovland C. Price J. Grabnar ionsor: S. Loehlein Completion Complete Complete through Cycle 14 through Cycle 14 Complete Page 17 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative continued Key Actions
11. Expand the role of the Engineering Assessment Board (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations
12. Establish criteria and modify appropriate procedures to restrict the use of At-Risk Changes in the plant modification process
13. Re-institute the use of Quarterly System Health Reports and Design Basis Assessment Reports
14. Assign a Program Owner for the Problem Solving Process
15. Develop and implement actions necessary to improve the technical issues problem solving capabilities in the Engineering organization.

SI Owner J. Powers J. Grabnar B. Boles J. Grabnar B. Boles C. Hawley onsor: S. Loehlein Completion Complete Complete Complete Complete Complete Page 18 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

7. Continuous Safety Culture Improvement Initiative DESIRED OUTCOME: Demonstrate a continuously improving Safety Culture at the Davis-Besse Nuclear Power Station Key Actions
1. Monitor Safety Culture on a monthly basis
2. Assess Safety Culture using the FENOC Business Practice
3. Perform a Safety Culture assessment utilizing an independent
4. Provide SCWE training to Site employees who have not outside organization completed the SCWE portion of the Site Employee Orientation Manual Davis-Besse Supervisors and above
5. Provide refresher training on SCWE and Safety Culture to
6. NQA to perform two Safety Culture Assessments
7. Employee Concerns Program group to perform two surveys of the Safety Conscious Work Environment
8. Perform an effectiveness assessment of the corrective actions taken in resDonse to the November 2003 SCWE survey results Owner C. Price D. Haskins C. Price L. Griffith M. Trump R. Hruby R. Amidon R. Hansen iponsor: M. Bezilla Completion through Cycle 14 4th Qtr 2005 Complete Complete Complete 2004 Complete 4th Qtr 2005 2004 Complete 4'h Qtr 2005 Complete Page 19 of 33 Revision 8

Davis-Besse Nuclear Power Station Key Actions

1. Perform Self-Assessments on procedure use and adherence
2. Review the Davis-Besse procedure change process to ensure alignment with FENOC standards for procedure preparation and revisions
3. Provide training on procedure use and adherence
4. Perform follow-up effectiveness reviews on procedure use and adherence Operational Improvement Plan Cycle 14 Owner M. Trump L. Dohrmann J. Reddington M. Trump
8. Procedure Improvement Initiative DESIRED OUTCOME: Improved procedure use and adherence and standardized procedure change process Sponsor: M. Bezilla Completion through Cycle 14 Complete Complete 3'd Quarter 2005 Page 20 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

9. Corrective Action Program Improvement Initiative DESIRED OUTCOME:

Improved effectiveness and implementation of the Corrective Action Program demonstrated through improved Station performance Key Actions

1. Implement the Apparent Cause Improvement Plan:
a. Strengthen procedural requirements for apparent cause evaluations, including analytical methods to be used
b. Corrective Action Review Board review of Apparent Cause Evaluations until standards are consistently met
c. Identify Apparent Cause Evaluators
d. Develop Training Program and Expectations and provide training to the Apparent Cause Evaluators (Initial Evaluator Classes and Additional Classes in 2004)
e. Qualify the trained Apparent Cause Evaluators using the Systematic Approach to Training
f. On an interim basis, rotate team of apparent cause evaluators to Support Services
g. Company Nuclear Review Board (CNRB) review of selected Apparent Cause Evaluations Owner L. Dohrmann L. Dohrmann Managers J. Reddington J. Reddington L. Dohrmann J. Rinckel Sponsor: M. Bezilla Completion Complete Complete Complete Complete Complete Complete through Cycle 14

=-

Page 21 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

9. Corrective Action Program Improvement Initiative continued Key Actions
2. Establish the appropriate level of workload for Condition Report Evaluations and Corrective Actions and develop a plan to reduce the backlogs to those levels
3. Perform a focused Self-Assessment of implementation of the Corrective Action Program using industry peers
4. Reestablish the Corrective Action Program trending process
5. Provide Apparent Cause training to Managers I

Owner L. Dohrmann C. Price L. Dohrmann L. Dohrmann Sponsor: M. Bezilla Completion Complete Complete Complete Complete Page 22 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I

10. Internal and External Oversight Improvement Initiative DESIRED OUTCOME:

Oversight activities are provided to ensure improved Station performance and the integrity of the Safety Barriers are sustained at the highest levels Key Actions

~~

1. Supplement quality oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical
2. Supplement management oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical
3. Focus more quality oversight on cross-functional activities and interfaces
4. Review and revise the master assessment plan at all three FENOC sites
5. Conduct an external assessment to evaluate the progress of organizational improvements in the areas of critical self-assessments and performance observations
6. Utilize INPO Assist Visits to assess the effectiveness of I mwovement Initiatives S

Owner S. Loehlein K. Ostrowski S. Loehlein S. Loehlein L. Myers M. Bezilla msor: R. Hansen Completion Co m p I ete Co m p I ete Complete Complete Complete Complete Page 23 of 33 Revision 8

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14

10. Internal and External Oversight Improvement Initiative continued Key Actions
7. Perform Quality Oversight of Engineering using the Continuous Assessment Process
8. Conduct assessment activities of the Corrective Action Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation Owner R. Hruby R. Hruby iponsor: R. Hansen Completion through Cycle 14 through Cycle 14 Page 24 of 33 Revision 8

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Safety Barrier Attributes and Goals Safety Bamer attributes and goals have been identified within this plan to provide a focus on key parameters to assess and ensure that safety barriers are being maintained. These attributes, which are grouped by each of the four barriers, will be monitored monthly by the Davis-Besse Leadership Team.

Performance indicators contain the criteria for monitoring each attribute. Some attributes will be monitored by periodic assessments such as surveys or self-assessments to determine if the goal for that attribute is being met. Monitoring sources for the performance indicators referenced in the Barrier Attributes are identified in the table below:

Kev Performance Indicator Monitoriw Sources OIP MPR FENOC Monthly Performance Report SHAR SCWE Health Assessment Report Operational Improvement Plan Performance Indicator Report Page 25 of 33 Revision 8

I DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Individual Barrier Attributes Item Attribute Goal Owner PI Reference Monitoring Source 1-01 Human Performance Success Days (Event Free Clock)

> 40 days on average Trump D-SPO-03 MPR 1-02 OSHA Recordable Injuries (industrial Safety Performance)

< 4 OSHA Recordable injuries per year Trump D-SPO-02 MPR

< 2 events in any 4 consecutive quarters Harder 1-03 OIP 1-03 1-04 1-05 Radiation Protection Events Individual Error Rate Employee willingness to raise concerns D-HP-01 MPR

< 0.36 individual errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />

> 90% of individuals are willing to raise concerns to their supervisors or the Employee Concerns Program Level 1 :

Level 1 Work Arounds goal in accordance with FENOC Monthly Performance Indicator AND Level 2:

Provide Operations with reliable equipment and system controls to operate the station.

Minimize Operations Level 2 Work Arounds to 11 and prioritize to be worked through the Work Management process.

Control Room Deficiencies goal in accordance with FENOC Monthlv Performance Indicator Trump Amidon OIP SCW E Annual Survey D-EMC-10 1-06.1 Operator Work Arounds Ostrowski MPR 1-06 1-07 1-06.2 01 P MPR Control Room Deficiencies Ostrowski D-EMC-09 Page 26 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item 1-08 1-09 1-1 0 1-1 1 Attribute Condition Report Self-Identified Rate Risk Performance Indicator (indicator of Cross-functional teamwork)

Condition Report SRO Review (SRO reviews for Operability are performed in a timely manner)

Employee willingness to use the Corrective Action Program Individual Barrier Attributes Goal 2 90% of Condition Reports are self-identified 2 75 Risk Assessment Indicator The Risk Assessment Indicator assesses each units risk of achieving safe and reliable operation. This indicator accomplishes this by measuring elements related to the probability and consequence of station events. Examples of elements making up this indicator include Probabilistic Safety Assessment, Aggregate System Health, Schedule Adherence, Activities Resulting in Reduced Trip-Logic, Schedule Stability, Scrams, Derates, Unplanned entry into Tech Specs, Entry into Abnormal Procedures

> 95% of SRO review required Condition Reports were reviewed for operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

< 5% of individuals are not willing to use the Corrective Action Program Owner Price Ostrowski Ostrowski Arnidon PI Reference 1-08 D-SPO-01 1-1 0 SCW E Survey and Annual Safety Culture Assessment Monitoring Source OIP MPR OIP OIP Page 27 of 33 Revision 8

I Item Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Attribute Amidon 1-1 2 SCWUNQA OIP Surveys 1-1 3 1-1 4 Trump Worker confidence in raising safety concerns 1-1 3 OIP Training Programs meet industry standards and effectively improve station performance as measured by NOBP-TR-1501 Licensed Operator Reaualification Training Individual Barrier Attributes Goal

> 90% of workers believe they can raise nuclear safety or quality concerns without fear of retaliation

_ _ _ _ _ ~

2 2.5 Training Program Performance Indicator

> 95% pass rate in the Licensed Operator Requalification Training Program PI I Monitoring Owner I Reference Source Trump I

01 P I

Page 28 of 33 Revision 8

DavislBesse Nuclear Power Station Goal 2 8 Corrective Action Program Index Rating Operational Improvement Plan Owner Price Cycle 14 P-04 P-05 P-06 P-07 Proqrams Barrier Attributes Maintenance Rule System Reliability Number of Maintenance Rule (a)( 1 ) Systems Program and Process Error Rate Maintenance Rework I Itern I No repeat Maintenance Rule (a)(l) systems within the operating cycle

< 0.36 Program and Process Errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked Attribute Hovland Trump PI Reference P-08 Monitoring Source Number of late Preventative Maintenance Activities 0 PMs past their late or defer to date AND c 10% of PMs closed beyond 60% of the allowed grace period Mugge D-SPO-05 MPR P-01 Corrective Action Program (Effectiveness of Corrective Action Proaram) 2 90% CR category accuracy rate I

Price P-02 01 P Condition Report (CR) category accuracy Apparent Cause evaluation quality P-02 P-03 P-03 OIP evaluations P-04 01 P P-05 OIP MPR D-H P-02

~

< 1.0% rework Maintenance Rework PI OIP Dominy P-08 01 P Page 29 of 33 Revision 8

Operational Improvement Plan Cycle 14 Manaaement Barrier Attributes Owner PI Reference Monitoring Source Item Attribute Goal M-01 OIP M-01 The Quality of Engineering Products 5 1.O score based on a (as measured by the Engineering Assessment Board)

Grabnar Amidon

~~

~

SCWE 3-4 SHAR M-02

> 75% of employees that use the Employee Concerns Program report being satisfied with the process Satisfaction of employees using the Employee Concerns Program (ECP)

NRC Allegation Ratio Amidon SCWE 1-2

< 2 times the industry average of NRC alleaations SHAR SHAR SHAR 01 P M-03 M-04 M-05

< 15% SCWERT Non-Concurrence Ratio

< 2 times the industry average of NRC retaliation allegations AND Schrauder SCWE4-5 SCWE 1-3 Effectiveness of Safety Conscious Work Environment Review Team (SCWERT) in avoiding discrimination claims

~~

Management Field Observations are self critical

> 80% of the management field observations performed are self-critical D. Haskins Annual Safety Culture Assessment, NQA Field Observations and Management Observations

Davis-Besse Nuclear Power Station Cycle 14 Operational Improvement Plan Management Barrier Attributes

~~

Owner Monitoring Source Attribute PI Reference Goal Item M-06 Price MPR Effectiveness of Management and Supervisors Managers and supervisors are generally effective with a few exceptions XD-PDE-05 (Management Commitment Area Only)

(Semi-Annual)

(Semi-Annual)

F-PDE-0 1 F-PD E-02 D-SPO-10 Talent Management and Personnel Development Goal in accordance with FENOC Performance indicator D. Haskins MPR M-07 M-08 M-09 M-1 0 M-11 Goal in accordance with FENOC Performance Indicator D. Haskins MPR Leadership Development Ostrowski MPR Reactivity Management

< 1 Level 2 Reactivity Management Event per year AND 0 Level 1 Reactivity Management Events per year.

Fuel Reliability Zero fuel defects Wilson D-SPO-07 MPR 01 P OIP OIP Maintenance Order Backlog M-11.1 M-11.2 M-1 1.3 Online:

< 50 Corrective Maintenance Orders AND

< 450 Elective Maintenance Orders Outaqe (prior to the startup from 14RFO):

< 250 Corrective/Elective Maintenance Orders Page 31 of 33 Revision 8

Davis-Besse Nuclear Power Station Item Attribute Goal M-12 Number of Temporary 5 5 during the Operating Cycle Modifications And 0 related to equipment and design deficiencies after restart from major outages Operational Improvement Plan Cycle 14 Owner H ovla n d M-12 Monitoring.

Reference Source OIP Page 32 of 33 Revision 8

Davis-Besse Nuclear Power Station Owner Hruby Operational Improvement Plan Cycle 14 PI Monitoring Reference Source DB-01 I 01 P 0-01.1 Item 0-01 Attribute Field Activity Assessments 0-02 Audit ReDOrt Issuance Responsiveness to QA Identified Issues 0-03 Oversiq ht Barrier Attributes Condition Report NQA Review Timeliness Goal 0-06 Field Observations:

Suspended. Replaced by 0-0 1.2. 0-0 1.2 developed to measure compliance with Assessment Program Requirements.

AND Completion of Primary Elements:

Deferral of < 1 Primary Element monthly Use of Industry Peer support Line organization response to Davis-Besse Oversight-initiated Condition Reports is within 90% - 1 10% of the average time required for the line organization to respond to all Condition ReDOrtS.

100% of Condition Report Investigations reviewed by NQA are accepted or rejected within 14 days after the investigation was comdete 100% of Corrective Actions verified or rejected by NQA within 30 days

< 25 working days from the end of the quarter 100% utilization of the scheduled INPO Assist Visits for 2004 0-01.2 01 P Hruby DB-02 01 P Hruby DB-03 OIP Hruby DB-04 Hruby DB-05 OIP Semi-Annual Assessment Donnellon Page 33 of 33 Revision 8

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