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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)
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Text

. FimtEnergy Nuclear Operating Company 5501 Norrh Sfate Roufe 2 Oak Harbor. Ohio 43449 Matk 8. Bezilla 4 79-321-7676 Vice President - Nuclear Fax: 419-321-7582 Doc ket N umber 5 0-346 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~krerStation (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 i n 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 i n comniitments from Revision 7 to Revision 8 identified in bold italicized text.

Docket N uni be r 50-346 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.

I f 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 o f 8 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 (419-321 -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.

COMMITMENTS DUE DATE

1. Organizational Effectiveness Improvement Initiative
1. Improve individual and organizational performance through June 30,2005 development and utilization of alignment tools at the Department/Section levels
2. Implement FENOC Business Practices for:

a) Focused Self-Assessments Complete b) Ongoing Self-Assessments Comp 1et e c) Benchmarking Complete d) Semi-Annual Collective Significance Self-Assessments Complete

3. Directors and Managers to attend a Leadership Academy to improve Complete management ski 11s
4. Provide formal Management Observation Skills Training Complete 5 . Enhance the Management Observation Program by ensuring Co ni p 1ete personnel providing oversight monitoring are familiar with DBBP-OPS-000 1, Operations Expectations and Standards
6. Implement actions to improve trending of major plant evolutions Complete utilizing the Management Observation Program to track performance and feedback
7. Provide face-to-face communications training to all site supervisors Comp 1ete and above
8. Re-evaluate all Davis-Besse supervisors to assess competency for December 3 1,2005 current positions
9. Conduct Supervisor and Manager Talent Management Talks C om p 1et e I O . Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Periodic through Cycle 14 Meetings i n accordance with Davis-Besse Business Practices

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

2. Operations Improvement Initiative I . Implement Operations Improvements:
a. Initiate Operations Leadership Improvements Complete
b. Initiate the 5 year staffing plan Coni p 1ete
c. Implement improvements to Operations work stations Coni p 1ete
d. Implement common FENOC Operations work process tools Conrplete 2 . Improve Operator knowledge, skills and abilities through testing, Conrplere training and nientoring
3. Implement the Operations Improvement Action Plan, including: Comp 1ete
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 C onip 1et e 5 . Benchmark Conduct of Operations C onip 1et e
6. Align Perforniance Indicators to Conduct of Operations 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
2. Perform an assessment of Maintenance effectiveness work planning, Complete scheduling, and implementation of critical equipment outages to identify improvements
3. Implement improvements of Maintenance Supervision through Complete training and development
4. Implen~entactions in the Maintenance individual commitment area Contplete 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
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 Conip 1ete 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 Cortiplete the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1409 Page 4 of 8 COMMITMENTS DUE DATE 5 . Work Management Improvement Initiative

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

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

6. Engineering

- Improvement Initiative

1. Implement actions to improve Safety Margin:
a. Determine the Safety Margin for the top 10 Risk Significant Coni p 1et e Systems and develop a plan to improve safety margins
b. Electrical System coordination improvements Tlt roirgli Cycle I4
c. Masonry/block wall re-analyses and design changes Tlirorrglr Cycle 14
d. Service Water improvements Through Cycle 14
2. Perform additional Latent Issues Reviews Periodic through Cycle 14
3. Implement the Design Calculation Improvement Plan Through Cycle 14
4. Enhance plant equipment performance through the FENOC Through Cycle 14 Equipment Re1i abi 1it y Program
5. Develop and implement the plan to enhance System Engineering Complete ownership of plant systems in support of Operations
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 Complete Requests and develop a plan to reduce and maintain the backlogs to that level
8. Perfomi on-going self-assessments to determine if the problem Periodic through Cycle 14 solving process, NOP-ER-3001 has been properly implemented during the previous period
9. Perform independent outside assessments of the effectiveness of Periodic through Cycle 14 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 Corr1plete populate with 5 systems
11. Expand the role of the Engineering Assessment Board (EAB) to Comp 1ete include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations
12. Establish criteria and modify appropriate procedures to restrict the Conip 1et e use of At-Risk Changes in the plant modification process

Docket Number 50-346 License Nuniber NPF-3 Serial Nuniber 1- 1409 At t achm et 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 Conip 1et e Design Basis Assessment Reports
14. Assign a Program Owner for the Problem Solving Process Complete
15. Develop and implenient actions necessary to improve the Conip 1et e technical issues problem solving capabilities in the Engineering organization.
7. Continuous Safety Culture Improvement Initiative 1 . Monitor Safety Culture on a monthly basis Periodic through Cycle 14
2. Assess Safety Culture using the FENOC Business Practice December 3 1, 2005
3. Perform a Safety Culture assessnient utilizing an independent Corrrplete outside organization
4. Provide SCWE training to Site employees who have not Complete completed the SCWE portion of the Site Employee Orientation Manual 5 . Provide refresher training on SCWE and Safety Culture to Davis- Complete Besse Supervisors and above
6. NQA to perfomi two Safety Culture Assessments 2004 Cortiplete 4Quarter 2005
7. Employee Concerns Program group to perform two surveys of the 2004 Corriplete Safety Conscious Work Environment 4 Quarter 2005
8. Perform an effectiveness assessment of the corrective actions Coni p 1ete taken in response to the November 2003 SCWE survey results
8. Procedure Improvement Initiative
1. Perform Self-Assessments on procedure use and adherence Periodic through Cycle 14
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 Conip 1et e
4. Perform follow-up effectiveness reviews on procedure use and September 30, 2005 adherence

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

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

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

10. Internal and External Oversight Improvement Initiative
1. Supplement quality oversight with off-site assistance to improve C on1p 1et e objectivity and ensure assessments are sufficiently critical
2. Supplement management oversight with off-site assistance to Conip 1et e improve objectivity and ensure assessments are sufficiently critical
3. Focus more quality oversight on cross-functional activities and Complete interfaces
4. Review and revise the master assessment plan at all three FENOC Co ni p 1et e sites 5 . Conduct an external assessment to evaluate the progress of Com p 1et e organizational improvements in the areas of critical self-assessments and performance observations
6. Utilize INPO Assist Visits to assess the effectiveness of Cotrrplere Improvement Initiatives
7. Perforni Quality Oversight of Engineering using the Continuous Periodic through Cycle 14 Assessnient Process
8. Conduct assessment activities of the Corrective Action Program Periodic through Cycle 14 to evaluate effectiveness of corrective actions taken to improve impletnentation and improve trend evaluation

Docket Number 50-346 Liccnse Number NPF-3 Serial Number 1-1 409 Page 1 o f 4 CHANGES TO CYCLE 14 OPERATIONAL IMPROVEMENT PLAN, REV. 8 ACTION/PI TITLE CHANGE NUMBER Key Actions Sponsor List, Page 6 Changed sponsor of Initiative 10 Internal and External Oversight Improvement to J. Rinckel. (Transfer of duties from reorganization is comDlete) 3.5 Perform testing of Extended due date to Second Quarter Maintenance staff knowledge, 2005.

skills and abilities to identify improvement actions and Divided this commit men t into two incorporate into training. parts in the OIP. Actions taken through 12/31/04 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.

6.lb Implement actions to improve safety margin: Electrical system coordination improvements 6.lc lniprove Safety Margin:

Masonryiblock wall re-analysis and design changes 9.lg Company Nuclear Review Changed owner from R. Hansen to 1.

Board (CNRB) review of selected Apparent Cause Evaluations

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1409 At t aclimen t 2 Page 2 of 4 ACTlONlPl NUMBER TITLE CHANGE Performance Indicators 1-04 Individual Error Rate The Fleet PI Reference number changed to D-HP-01.

1-05 Employee willingness to raise This Performance Indicator will be concerns assessed through the annual SCWE survey.

1-06.2 Operator Work Arounds - Added ranking criteria and reworded Level 2 Obi ective/Goal.

1-1 1 Employee Willingness to Use Added the Annual Safety Culture the Corrective Action Assessment as a source reference.

Pro gram Delete NQA.

Changed owner from Griffith to Am i don .

1-12 Worker Confidence in Changed owner from Griffith to Raising Safetv Concerns Amidon.

P-0 1 Corrective Action Program Changed grading criteria for weighted Effectiveness 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.

____

P-06 Program and Process Error The Fleet PI Reference number Rate changed to D-HP-02.

M-05 Management Field Changed PI Reference in the Observations are self-critical Operational Improvement Plan to Annual Safety Culture Assessment, NQA Field Observations and Management Observations.

Changed to annual PI reporting.

M -06 Effectiveness of Management The Fleet PI Reference number and Supervisors 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 Talent Management and Removed monthly from the Goal Personnel Development statement in the Operational Improvement Plan. This is a semi-I annual Performance Indicator.

I 34-08 Leadership Development Removed monthly from the Goal statement in the Operational I-----

Improvement Plan. This is a semi-annual Performance Indicator.

0-01.2 Completion of Primary Added criteria for Year-to-Date and Elements Y ear-End Expectancy.

r--- 0-02 Investigation Responsiveness to DBOV Identified CRs 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.

0-03 CR DBOV Review Changed from measuring the 90 of CR I Tim el i ness 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 CA DBOV Verification Changed from measuring the % of CA Timeliness 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.

0-05 Timeliness of NQA Audit Deleted use of calendar days from end Report Issuances 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 Cycle 14 Introduction To ensure continued improvements and sustained performance in Nuclear Safety and Plant Operation at the Davis-Besse Nuclear Power Station, the Leadership Team has developed 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 Operational Improvement Plan Cycle 14 1 Barriers Demonstrating FENOCs Strong Safety Focus 1 C L H

A L FENOC Vision:

L People with a strong safety E

G c focus delivering top Feet operating performance E Strong Experienced Independent Competent Individual Programs Management Oversight 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. ~

Barriers Enhanced

- -

Davis-Besse Initiatives E!! ECT)

-

8 f Sponsor & b

- -

M. Bezilla 1. Organizational Effectiveness Improvement X B. Allen 2. Operations Improvement X X B. Allen 3. Maintenance Improvement X B. Allen 4. Training Improvement X B. Allen 5. Work Management Improvement X S. Loehlein 6. Engineering Improvement X X M. Bezilla 7. Continuous Safety Culture Improvement X M. Bezilla 8. Procedure Improvement X M. Bezilla 9. Corrective Action Program Improvement X X J. Rinckel IO. Internal and External Oversight Improvement 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 Owner I-!

M. Trump nsor: M. Bezilla 2"dQtr 2005 development and utilization of alignment tools at the Department/Sect ion I eveIs

2. Implement FENOC Business Practices for: L. Dohrmann a) Focused Self-Assessments Complete b) Ongoing Self-Assessments Complete c) Benchmarking Complete d) Semi-Annual Collective Significance Self-Assessments Complete (Included in Focused Self-Assessment Business Practice)
3. Directors and Managers to attend a Leadership Academy D. Haskins Complete to improve management skills
4. Provide formal Management Observation Skills Training J. Reddington Complete Page 7 of 33 Revision 8

Davis-Besse Nuclear Power Station Operat ionaI I mprovement Plan Cycle 14 1 Organizational Effectiveness Improvement Initiative continued iponsor: M. Bezilla Key Actions Owner Completion

5. Enhance the Management Observation Program by K. Fehr Complete ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards
6. Implement actions to improve trending of major plant K. Fehr Complete evolutions utilizing the Management Observation Program to track performance and feedback
7. Provide face-to-face communications training to all site D. Haskins Complete supervisors and above
8. Re-evaluate all Davis-Besse supervisors to assess D. Haskins 4thQtr 2005 competency for current positions
9. Conduct Supervisor and Manager Talent Management D. Haskins Complete Talks
10. Continue with the 4 Cs meetings, D-B Team Meetings, M. Lark-Landis through Cycle 14 Town Hall Meetings in accordance with Davis-Besse Business Practices 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 mnsor: B. Allen Key Actions Owner Completion
1. Implement Operations Improvements:
a. Initiate Operations Leadership Improvements K. Ostrowski CompIete
b. Initiate the 5 year staffing plan K. Ostrowski CompIete
c. Implement improvements to Operations work stations D. lmlay Complete
d. Implement common FENOC Operations work process K Ostrowski Complete tools
2. Improve Operator knowledge, skills and abilities through M. Trump Complete testing, training and mentoring Page 9 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

2. Operations Improvement Initiative continued Sponsor: 6. Allen Key Actions Owner I Completion
3. Implement the Operations Improvement Implementation Action K. Ostrowski I Complete 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 K. Ostrowski Complete
5. Benchmark Conduct of Operations K. Ostrowski Complete 1

I

6. Alian Performance Indicatorsto Conduct of Operations Y I K. Ostrowski I Complete Page 10 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

3. Maintenance Improvement Initiative continued bonsor: B. Allen Key Actions Owner Completion
5. Perform testing of Maintenance staff knowledge, skills and M. Trump abilities to identify improvement actions and incorporate into training
a. Perform skill and knowledge testing to identify areas for CornpIete improvement
b. Incorporate any identified training needs into training 2"dQtr 2005 material 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 Owner Completion
1. Implement actions to improve individual and organizational M. Trump CompIete performance and alignment by developing and providing training on design and configuration control to appropriate site staff
2. Establish engineering positional qualification requirements M. Trump Complete based on the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers I Page 13 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

5. Work Management Improvement Initiative 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 Key Actions Owner Cornpletion
1. Common Process W. Mugge Complete Complete through Cycle 14 Complete 1I e. Monitor and improve Order quality Complete Page 14 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

5. Work Management Improvement Initiative continued Sponsor: B. Allen Key Actions Owner Completion
2. Maintenance Backlog Reduction W. Mugge
a. Complete walk-down and validation of the Order backlog Complete to ensure proper category, priority, consolidation and elimination of invalid orders
b. Complete Cycle Plan identifying equipment outages and Complete providing the framework for addressing backlog Order priorities and results of the System Health Report
c. Develop performance indicators to monitor and manage Complete Order backlog
3. Outage Performance
a. Forced Outage Schedule template and readiness W. Mugge Complete
b. Mid-Cycle Outage Preparation W. Bentley Cornplete I
c. Clarify expectations and improve contractor performance C. Hawley Complete I
d. 14'h Refueling Outage Preparation W. Bentlev 2/28/06 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 SI onsor: S. Loehlein Key Actions Owner Completion
1. Implement actions to improve Safety Margin: J. Grabnar
a. Determine the Safety Margin for the top 10 Risk Complete Significant Systems and develop a plan to improve safety margins
b. Electrical System coo rdination improvements through Cycle 14
c. Masonryhlock wall re-analyses and design changes through Cycle 14
d. Service Water improvements through Cycle 14
2. Perform additional Latent Issues Reviews B. Boles through Cycle 14
3. Implement the Design Calculation Improvement Plan J. Grabnar through Cycle 14
4. Enhance plant equipment performance through the FENOC R Hovland through Cycle 14 Equipment Reliability Program
5. Develop and implement the plan to enhance System B. Boles Complete Engineering ownership of plant systems in support of ODerations Page 16 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative continued I ionsor: S. Loehlein Key Actions Owner Completion
6. Schedule and conduct additional Program Compliance R Hovland Complete 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 J. Grabnar Complete 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 R Hovland through Cycle 14 problem solving process, NOP-ER-3001 has been properly implemented during the previous period
9. Perform independent outside assessments of the C. Price through Cycle 14 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 J. Grabnar Complete and DoDulate with 5 svstems Page 17 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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

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

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

8. Procedure Improvement Initiative DESIRED OUTCOME: Improved procedure use and adherence and standardized procedure change process Sponsor: M. Bezilla Key Actions Owner Completion
1. Perform Self-Assessments on procedure use and M. Trump through Cycle 14 adherence
2. Review the Davis-Besse procedure change process to L. Dohrmann Complete ensure alignment with FENOC standards for procedure preparation and revisions
3. Provide training on procedure use and adherence J. Reddington Complete
4. Perform follow-up effectiveness reviews on procedure M. Trump 3'd Quarter 2005 use and adherence 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 Sponsor: M. Bezilla Key Actions Owner Completion
1. Implement the Apparent Cause Improvement Plan:
a. Strengthen procedural requirements for apparent cause L. Dohrmann Complete evaluations, including analytical methods to be used
b. Corrective Action Review Board review of Apparent Cause L. Dohrmann Complete Evaluations until standards are consistently met
c. Identify Apparent Cause Evaluators Managers Complete
d. Develop Training Program and Expectations and provide J. Reddington Complete training to the Apparent Cause Evaluators (Initial Evaluator Classes and Additional Classes in 2004)
e. Qualify the trained Apparent Cause Evaluators using the J. Reddington Complete Systematic Approach to Training
f. On an interim basis, rotate team of apparent cause L. Dohrmann Complete evaluators to Support Services
g. Company Nuclear Review Board (CNRB) review of J. Rinckel through Cycle 14 selected Apparent Cause Evaluations Page 21 of 33 Revision 8

-=

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

9. Corrective Action Program Improvement Initiative continued Sponsor: M. Bezilla Key Actions Owner Completion
2. Establish the appropriate level of workload for Condition L. Dohrmann Complete 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 C. Price Complete the Corrective Action Program using industry peers
4. Reestablish the Corrective Action Program trending L. Dohrmann Complete process
5. Provide Apparent Cause training to Managers L. Dohrmann Complete I

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 S msor: R. Hansen

~~

Key Actions Owner Completion

1. Supplement quality oversight with off-site assistance to S . Loehlein CompI ete improve objectivity and ensure assessments are sufficiently critical
2. Supplement management oversight with off-site K. Ostrowski CompIete assistance to improve objectivity and ensure assessments are sufficiently critical
3. Focus more quality oversight on cross-functional activities S . Loehlein Complete and interfaces
4. Review and revise the master assessment plan at all three S. Loehlein Complete FENOC sites
5. Conduct an external assessment to evaluate the progress L. Myers Complete of organizational improvements in the areas of critical self-assessments and performance observations
6. Utilize INPO Assist Visits to assess the effectiveness of M. Bezilla Complete Imwovement Initiatives Page 23 of 33 Revision 8

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14

10. Internal and External Oversight Improvement Initiative continued iponsor: R. Hansen Key Actions Owner Completion
7. Perform Quality Oversight of Engineering using the R. Hruby through Cycle 14 Continuous Assessment Process
8. Conduct assessment activities of the Corrective Action R. Hruby through Cycle 14 Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation 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 Operational Improvement Plan Performance Indicator Report MPR FENOC Monthly Performance Report SHAR SCWE Health Assessment 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 Monitoring Reference Source 1-01 Human Performance -

> 40 days on average Trump D-SPO-03 MPR Success Days (Event Free Clock) 1-02 OSHA Recordable -

< 4 OSHA Recordable injuries per year Trump D-SPO-02 MPR Injuries (industrial Safety Performance) 1-03 Radiation Protection -

< 2 events in any 4 consecutive quarters Harder 1-03 OIP Events 1-04 Individual Error Rate -

< 0.36 individual errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Trump D-HP-01 MPR 1-05 Employee willingness to -

> 90% of individuals are willing to raise Amidon SCW E OIP raise concerns concerns to their supervisors or the Employee Annual Concerns Program Survey 1-06 Operator Work Arounds Level 1: Ostrowski D-EMC-10 MPR Level 1 Work Arounds goal in accordance with 1-06.1 FENOC Monthly Performance Indicator AND Level 2: 1-06.2 01P 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.

1-07 Control Room Control Room Deficiencies goal in accordance Ostrowski D-EMC-09 MPR Deficiencies with FENOC Monthlv Performance Indicator Page 26 of 33 Revision 8

,

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Individual Barrier Attributes Item Attribute Goal Owner PI Monitoring Reference Source 1-08 Condition Report 2 90% of Condition Reports are self-identified Price 1-08 OIP Self-Identified Rate 1-09 Risk Performance 2 75 Risk Assessment Indicator Ostrowski D-SPO-01 MPR Indicator (indicator of Cross- The Risk Assessment Indicator assesses each functional teamwork) 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 1-10 Condition Report -> 95% of SRO review required Condition Ostrowski 1-1 0 OIP SRO Review Reports were reviewed for operability within 24 (SRO reviews for hours Operability are performed in a timely manner) 1-11 Employee willingness to -

< 5% of individuals are not willing to use the Arnidon SCW E OIP use the Corrective Corrective Action Program Survey and Action Program Annual Safety Culture Assessment Page 27 of 33 Revision 8

I Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Individual Barrier Attributes Item Attribute Goal Owner I PI Reference I Monitoring Source 1-12 Worker confidence in > 90% of workers believe they can raise nuclear Amidon SCWUNQA OIP raising safety concerns safety or quality concerns without fear of Surveys retaliation

_____~

1-13 Training Programs meet 2 2.5 Training Program Performance Indicator Trump 1-1 3 OIP industry standards and effectively improve station performance as measured by NOBP-TR-1501 1-14 Licensed Operator ReaualificationTraining

-

> 95% pass rate in the Licensed Operator Requalification Training Program Trump I I 01P Page 28 of 33 Revision 8

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Proqrams Barrier Attributes I I Itern Attribute Goal Owner Price PI Reference D-SPO-05 Monitoring Source MPR P-01 Corrective Action 2 8 Corrective Action Program Index Rating Program (Effectiveness of Corrective Action Proaram)

P-02 Condition Report (CR) category accuracy P-03 Apparent Cause 2 90% CR category accuracy rate I Price P-02 P-03 01P OIP evaluation quality evaluations P-04 Maintenance Rule P-04 01P System Reliability P-05 Number of Maintenance No repeat Maintenance Rule (a)(l) systems Hovland P-05 OIP Rule (a)(1) Systems within the operating cycle P-06 Program and Process -

< 0.36 Program and Process Errors per 10,000 Trump D-HP-02 MPR Error Rate ~

hours worked P-07 Maintenance Rework -< 1.0% rework Dominy Maintenance OIP Rework PI P-08 Number of late 0 PMs past their late or defer to date Mugge P-08 01P Preventative AND Maintenance Activities c 10% of PMs closed beyond 60% of the allowed grace period Page 29 of 33 Revision 8

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

M-02 Satisfaction of > 75% of employees that use the Employee Amidon SCWE 3-4 SHAR employees using the Concerns Program report being satisfied with Employee Concerns the process Program (ECP)

M-03 NRC Allegation Ratio -

< 2 times the industry average of NRC Amidon SCWE 1-2 SHAR alleaations M-04 Effectiveness of Safety -< 15% SCWERT Non-Concurrence Ratio Schrauder SCWE4-5 SHAR Conscious Work AND Environment Review -< 2 times the industry average of NRC SCWE 1-3 SHAR Team (SCWERT) in retaliation allegations avoiding discrimination claims

~~

M-05 Management Field > 80% of the management field observations D. Haskins Annual Safety 01P Observations are self performed are self-critical Culture critical Assessment, NQA Field Observations and Management Observations

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

~~

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

M-07 Talent Management and Goal in accordance with FENOC Performance D. Haskins F-PDE-01 MPR Personnel Development indicator (Semi-Annual)

M-08 Leadership Development Goal in accordance with FENOC Performance D. Haskins F-PDE-02 MPR Indicator (Semi-Annual)

M-09 Reactivity Management -

< 1 Level 2 Reactivity Management Event per Ostrowski D-SPO-10 MPR year AND 0 Level 1 Reactivity Management Events per year.

M-10 Fuel Reliability Zero fuel defects Wilson D-SPO-07 MPR M-11 Maintenance Order Online: M-11.1 01P Backlog < 50 Corrective Maintenance Orders AND

< 450 Elective Maintenance Orders M-11.2 OIP Outaqe (prior to the startup from 14RFO):

< 250 Corrective/Elective Maintenance Orders M-11.3 OIP Page 31 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Item Attribute M-12 Number of Temporary Modifications Goal 5 5 during the Operating Cycle

-

And 0 related to equipment and design deficiencies after restart from major outages Owner Hovland

. Cycle 14 Reference M-12 Monitoring Source OIP Page 32 of 33 Revision 8

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Oversiqht Barrier Attributes Item Attribute Goal Owner PI Monitoring Reference Source 0-01 Field Activity Hruby DB-01 I 01P Assessments Field Observations: 0-01.1 Suspended. Replaced by 0-01.2. 0-01.2 developed to measure compliance with Assessment Program Requirements.

AND Completion of Primary Elements: 0-01.2 01P Deferral of < 1 Primary Element monthly 0-02 Responsiveness to QA Line organization response to Davis-Besse Hruby DB-02 01P Identified Issues Oversight-initiated Condition Reports is within 90% - 110% of the average time required for the line organization to respond to all Condition ReDOrtS.

0-03 Condition Report NQA 100% of Condition Report Investigations Hruby DB-03 OIP Review Timeliness reviewed by NQA are accepted or rejected within 14 days after the investigation was comdete 100% of Corrective Actions verified or rejected Hruby DB-04 by NQA within 30 days

-

< 25 working days from the end of the quarter Hruby DB-05 Audit ReDOrt Issuance 0-06 Use of Industry Peer 100% utilization of the scheduled INPO Assist Donnellon Semi- OIP support Visits for 2004 Annual Assessment Page 33 of 33 Revision 8

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