ML022680286

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Management and Human Performance Improvement Plan
ML022680286
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 09/18/2002
From: Myers L
FirstEnergy Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, NRC/RGN-III
References
Download: ML022680286 (73)


Text

Davis-Besse Management and Human Performance Improvement Plan September 18, 2002 September 18, 2002 1

Welcome Lew Myers Chief Operating Officer September 18, 2002 2

Desired Outcomes

  • Discuss Management and Human Performance Improvement Plan
  • Discuss the plan for improving our implementation of the Corrective Action Program
  • Review results of the Safety Conscious Work Environment Survey and our plan for improvement September 18, 2002 3

üProactive Safety Culture

üConservative Operations üMeasurable Value to Shareholders

üFENOC Commitment to Safety üCustomer Service

üExceed Customer Expectations Vision

ü Skilled & Flexible Work üAchieve Goals & Objectives Force üPositive Change

ü Feedback Valued in üReward & Recognition Decision-making

ü Open Communication

ü Initiative & Leadership

ü Personal Responsibility for Actions

ü Honesty & Ethical Behavior

ü Management Involvement

ü Knowledge Mission: People providing safe, reliable and cost effective nuclear generation September 18, 2002 4

Designed for restart and to provide for longer-term sustained performance.

Basic Building Blocks Return to Service Plan Restart Overview Panel Reactor Head System Health Resolution Plan Assurance Plan Bob Schrauder Jim Powers Program Compliance Plan Restart Action Plan Restart Test Plan Jim Powers Lew Myers Randy Fast Containment Health Management and Assurance Plan Human Performance Excellence Plan Randy Fast Lew Myers 4

September 18, 2002 5

Root Causes Steve Loehlein Manager - Quality Assessment September 18, 2002 6

Management /

Management Human Issues Initial Performance Technical Excellence Plan Root Cause Condition Report FENOC Missed Opportunities QA Investigation Other Sources:

of Management/

Human Performance Management /Human Issues Performance Non-Technical Improvement Root Cause Plan Objectives Actions and Verification of 5 Focus Effectiveness Areas September 18, 2002 7

Root Causes

  • Less than adequate nuclear safety focus
  • Less than adequate implementation of the Corrective Action Program

- Addressing symptoms rather than causes

- Low categorization of conditions

- Inadequate cause determinations

- Inadequate corrective actions

- Inadequate trending

  • Failure to integrate and apply key industry information and site knowledge
  • Non-Compliance with the Boric Acid Corrosion Control Procedure and Inservice Inspection Program September 18, 2002 8

Root Cause Analysis Team

  • Lead: Steve Loehlein (Beaver Valley)
  • Bill Babiak (Perry)
  • Mario DeStefano (Perry)
  • Randy Rossomme (Beaver Valley)
  • Lesley Wildfong (Conger & Elsea)
  • Bill Mugge (Davis-Besse)
  • Joe Sturdavant (Davis-Besse)
  • Bobby Villines (Davis-Besse)
  • Dick Smith (Conger & Elsea)
  • Spyros Traiforos
  • Oversight:

Dorian Conger and Ken Elsea (C&E)

September 18, 2002 9

Management and Human Performance Implementation Plan Dave Eshelman Director - Life Cycle Management September 18, 2002 10

Operations Role in Site Management Head Degradation Safety Focus Failure to Detect Technical CR 02-02581 Root Cause Head Degradation CR 02-00891 CR 02-00891 Quality Assessment Management / Other Management Effectiveness Human Performance Human Performance CR 02-02578 Improvement Root Causes Plan Other Integrated / Collective Cause Review Actions September 18, 2002 11

Management/Personnel Nuclear Safety Culture Development Nuclear Safety Focus Leaders Safety Conscious Work Leadership Behaviors Environment (SCWE) Evaluating Leadership Management Monitoring Feedback and Coaching Standards and Management/

Human Performance Programs/Corrective Action/

Decision-Making Procedure Compliance Leadership Standards Improvement Technical Standards Plan Program Improvements Departmental Standards Implementation Improvements Plant and Equipment Standards Corrective Action Process Safety Focused Decision-Making Procedure Adherence Oversight and Assessments Independent External Oversight FENOC Level Oversight Internal Oversight Management Oversight Review Board Oversight September 18, 2002 12

Senior Management Team Standards

  • We are committed to implementing the FENOC Mission, Vision and Values

_ We will demonstrate our commitment to safety; demonstrate leadership courage with safety first and foremost

_ We will recognize the Value of our people

_ We pledge to uphold the Leadership in Action Principles

_ We will earn the right to lead through our behaviors and actions.

September 18, 2002 13

Objectives of the Plan

  • Actions

- Identification of Actions

- Designation of Restart Actions

- Designation of Responsible Managers

- Schedule for Activities

  • Verification of Effectiveness

- Performance Indicators and Goals

- Assessments

  • Plan is a Living Document long after restart September 18, 2002 14

Improvements in Safety Culture Objective:

FENOC has the following objective for safety culture at Davis-Besse:

Nuclear, radiological, and personnel safety have the highest priority and take precedence over other objectives, such as cost and production. Personnel feel free to raise safety concerns without fear of retaliation, and concerns are investigated and resolved in a timely manner.

September 18, 2002 15

Nuclear Safety Culture Initiatives

  • New Management: FENOC Executive; Senior DB
  • Safety Focus Training
  • People Team
  • Business Plan Alignment of Performance Incentives September 18, 2002 16

Nuclear Safety Culture Initiatives

  • Employee communication opportunities:

C's meetings; Town Hall Meetings

- ROP Employee Meetings

  • Case Study Training
  • Management Oversight Improvements:

- Management Monitoring Program

- Management Observation Scheduling September 18, 2002 17

Verification of Effectiveness

  • Self-Identification of Adverse Conditions indicator. The goal for restart is 80% or more.

- Self-Assessments - Each group will include an evaluation of the safety focus.

- Management Observations

- SCWE Assessments - Conduct periodic assessments of SCWE at Davis-Besse. The goal for restart is to have an improving trend in SCWE.

September 18, 2002 18

Improvements in Management/

Personnel Development Objective FENOC has the following objective for its management of Davis-Besse:

Managers are experienced, have high safety standards, and are involved in directing and overseeing plant activities.

September 18, 2002 19

Improvements in Management/

Personnel Development

  • New Management team
  • Standards for Management
  • Operations Improvement Plan
  • Supervisory Evaluations
  • Leadership in Action Training
  • Foundations for Leadership
  • Ownership for Excellence
  • Management Monitoring Process September 18, 2002 20

Verification of Effectiveness Indicators

  • Management Monitoring

- Quality of pre-job briefs

- Proper safety practices and equipment

- Effective communications

- Supervisory behaviors

- Procedure or document use

- Use of Station Error-Prevention tools

  • Individual -error rate per 10,000 person-hours worked. The goal for restart is 0.50
  • Accept As-Is disposition of Condition Reports September 18, 2002 21

Verification of Effectiveness Assessments

  • Restart Overview Panel September 18, 2002 22

Improvements in Standards and Decision-Making Objective FENOC has the following objective for decision-making and technical assessments at Davis-Besse:

Decision-making and technical standards have a nuclear safety focus, have technical rigor, account for operating experience, and seek to correct problems rather than justifying acceptance of the problems.

September 18, 2002 23

Improvements in Standards and Decision-Making

  • Decision-Making Nuclear Operating Procedure
  • Establish Technical Staff Expectations
  • Improvements in Use of Operating Experience
  • Increased Resource Sharing with FENOC Plants
  • Augmentation of the Engineering Staff
  • FENOC Hierarchy of Documents
  • Operations Oversight Executive September 18, 2002 24

Improvements in Standards and Decision-Making

  • Operations Excellence Plan
  • Plant Labeling Improvements and Equipment
  • Case Study
  • Training on Technical Standards
  • Creation of a Management Observation Program
  • Establishment of an Engineering Assessment Board September 18, 2002 25

Verification of Effectiveness Indicators

  • Assessment of Decision-Making Nuclear Operating Procedure
  • Engineering Assessment Board Indicators
  • Management Observation
  • Open Control Room Deficiencies
  • Open Operator Work-Arounds

Oversight and Assessment Objective FENOC has the following objective for oversight and assessments at Davis-Besse:

Davis-Besse has provisions for oversight and assessments, which are effective in identifying and correcting problems before they adversely affect safety and quality.

September 18, 2002 27

Oversight and Assessment

  • New Oversight Groups

- Creation of a Restart Overview Panel

- Establishment of an Engineering Assessment Board

- Creation of Restart Readiness Reviews by the Senior Management Team September 18, 2002 28

Oversight and Assessment Permanently Strengthen Existing Groups

  • Improvements in Corrective Action Review Board
  • Improvements in Senior Training Council
  • Improvements in Engineering product reviews (Engineering Assessment Board)
  • Improvements in the Project Review Committee
  • Improvements in Quality Assessment
  • Improvements in the Company Nuclear Review Board September 18, 2002 29

Oversight and Assessment New permanent assessments activities

  • Restart Readiness Reviews
  • Periodic System Reviews
  • Periodic Program Reviews
  • Improved Expectations and Standards for Oversight
  • Weekend Duty Oversight
  • Management Observation Program September 18, 2002 30

Verification of Effectiveness Performance Indicators

  • Management Assessment of Readiness for Restart
  • Corrective Action Program is effectively implemented to support restart
  • Engineering products support restart
  • Quality Assessment will track the number of Condition Reports it prepares
  • Quality Assessment will track the number of Condition Reports it prepares that involve a repeat of previous conditions identified September 18, 2002 31

Improvements in Programs/Corrective Action/Procedure Compliance Objective FENOC has the following objective for programs, corrective action and procedure adherence at Davis-Besse:

Programs comply with NRC regulations, incorporate applicable operating experience, and are effectively implemented.

Adverse conditions (including adverse trends) are promptly identified and documented. The root causes of significant conditions adverse to quality are identified, actions are taken to preclude recurrence of the conditions, and the preventive actions are effective. Personnel comply with procedures as written, or obtain proper revisions as needed.

September 18, 2002 32

Programs/Corrective Action/Procedure Compliance Initiatives Actions to Improve Programs

  • Program Compliance Building Block Plan

- Program Ownership

- Expectations for Program Ownership

- Improvements to the Ownership Model

- Qualification Process for Owners

- Improvements to the Self-Assessment Program September 18, 2002 33

Programs/Corrective Action/Procedure Compliance Initiatives Actions to Improve Program/Procedure Compliance:

  • Reinforcing Standards for Procedure Compliance
  • Emphasis on Procedure Compliance at Morning Meetings
  • Management Observations September 18, 2002 34

Programs/Corrective Action/Procedure Compliance Initiatives Specific Program Changes

  • In-service Inspection (ISI)
  • Corrective Action program September 18, 2002 35

Programs/Corrective Action/Procedure Compliance Initiatives Improvements in Corrective Action

  • Improvements in Operability Reviews
  • Improvements in Categorization of Adverse Conditions
  • Improvements in Cause Determinations
  • Improvements in Corrective Actions
  • Improvements in Improvements in Trending
  • Improvements in the Corrective Action Review Board
  • Improvements in Causal Analysis Review Group September 18, 2002 36

Verification of Effectiveness Performance Indicators

  • Programs and Procedure Compliance

- Individual program health indicator

- Program and Process Errors The goal for restart is 0.7 per 10,000 person-hours

- Condition Reports due to failure to follow procedures

- Management observations of procedure compliance September 18, 2002 37

Verification of Effectiveness Performance Indicators

  • Corrective Actions

- Categorization Adequacy The goal is to have 95% or better

- Root Cause Quality The goal of 90% or better has been established

- Corrective Action Adequacy The goal is 90% or better

- Repeat Events

- Timeliness of Corrective Actions September 18, 2002 38

Verification of Effectiveness Assessments

  • Programs and Procedure Compliance

- Program Reviews

- Quality Assessment audits of procedure compliance.

- Human Performance Evaluation System (HPES) analysis

- Quality Assessment surveillances of procedure compliance September 18, 2002 39

Verification of Effectiveness Assessments

  • Corrective Actions

- Engineering Assessment Board review of corrective actions

- Independent assessment of the adequacy of corrective actions on a semiannual basis.

- Quality Assessment detailed audits of the adequacy of corrective actions September 18, 2002 40

Overall Performance Indicators to Measure Improvement

  • Self-Identification of Adverse Conditions The goal for restart is 80%
  • Open Control Room Deficiencies The goal is to have zero at restart
  • Open Operator Work-Arounds The goal is to have zero at restart
  • Root Cause Quality The goal is 90% or better September 18, 2002 41

Overall Performance Indicators to Measure Improvement

  • EAB Indicators of quality
  • Total Maintenance Backlog The goal for restart is less than 500
  • Open Modifications The goal for restart is less than 200
  • Open Procedure Change Request The goal for restart is 250
  • Restart Training Completion September 18, 2002 42

Corrective Action Process Improvement Dave Gudger, Manager - Performance Improvement Corrective Action Process Owner September 18, 2002 September 18, 2002 43

Corrective Action Process Improvement Purpose

  • To discuss the Corrective Action Program improvement plan to address the following items:

- Corrective Action Program issue

- Interim/Compensatory measures established for assurance of program integrity

- Approach to long-term improvement plan September 18, 2002 44

Corrective Action Process Improvement Corrective Action Program Issue

  • Non-Technical Root Cause identified that the implementation of the Corrective Active Program was less than adequate as indicated by the following:

- Addressing symptoms rather than causes

- Low categorization of conditions

- Inadequate corrective actions

- Inadequate trending

Program elements determined to be adequate September 18, 2002 45

Performance Improvement Organization MANAGER - PERFORMANCE IMPROVEMENT Dave Gudger SUPERVISOR - CORRECTIVE RECOVERY SUPERVISOR - SELF ACTION PROGRAM IMPROVEMENT EVALUATIONS PROGAMS Brian T. Hennessy Tony F. Silakoski

  • TBD CREST ADMINISTRATION PROGRAM REVIEW TEAM ROOT/BASIC/APPARENT (RECORDS) ROOT CAUSE - CAP CAUSE & TRAINING REPORT WRITING CREST SOFTWARE CARB ADMINISTRATION CAUSAL ANALYSIS REVIEW GROUP - CARG SELF-EVALUATION/

TRENDING AND SELF-ASSESSMENT PERFORMANCE INDICATORS CAP SELF-ASSESSMENT/

EFFECTIVENESS REVIEW HUMAN PERFORMANCE RECORDS CLOSEOUT NRC SUPPORT FOR RESTART OBSERVATION PROGRAM OPERATING EXPERIENCE PROGRAM REVIEW TEAM COMMUNICATION PLAN/

NOP/PROG. GUIDE ROOT CAUSE - OE TRAINING IMPLEMENTATION CAP/CREST TRAINING 46 September 18, 2002

Interim and Compensatory Measures Completed Compensatory Measures

  • Barrier Analysis
  • Corrective Action Program owners directly involved with management categorization
  • Standards enhanced for Senior Reactor Operator reviews
  • Causal Analysis Review Group established
  • Corrective Action Review Board chaired by Plant Manager
  • Corrective Action expert facilitation
  • Corrective Action Program closure review September 18, 2002 47

Major Improvement Initiatives New Causal Analysis Review Group Functions

- Ensure cause quality and programmatic requirement adherence

- Provide peer review feedback to evaluator and approver for long term quality behavior improvements

- Used as a Corrective Action Program Users' Group

- Develop individual departmental corrective action improvement plans in coordination with the Program Owner and other sections and department September 18, 2002 48

Major Improvement Initiatives NEW CAP Performance Indicators

Purpose:

To monitor transition to improved quality and ownership.

Establishing Performance Category Measures for each program attribute to be in place by September 30th.

Productivity Timeliness Efficiency Quality Effectiveness September 18, 2002 49

Root Cause / CAP Focused Assessment September 18, 2002 50

Conclusion We understand what the Corrective Action Program issues are. We have interim measures to address them. We are developing a long-term improvement plan.

September 18, 2002 51

DAVIS-BESSE Safety Conscious Work Environment Independent Assessment Presentation for NRC Meeting September 18, 2002 L.W. Pearce 52 September 18, 2002 52

Agenda

  • Assessment Structure and Methodology
  • Survey Results
  • Actions to Address Assessment Findings
  • Conclusion September 18, 2002 53

Structure and Methodology Team:

Ken Woessner (FirstEnergy QA)

Stewart Ebneter (Ind. Consultant, Former NRC Senior Manager)

George Edgar & Paul Zaffuts (Morgan Lewis)

Four Core Criteria and Thirteen Attributes Derived From NRC Policy Statement:

Worker willingness to Raise Concerns / Management Support for Raising Concerns.

Effectiveness of ECP/Ombudsman Program.

Managements Effectiveness in Resolving Issues Using Normal Processes.

Managements Effectiveness in Detecting and Preventing Retaliation and Chilling Effect.

September 18, 2002 54

Structure and Methodology Data Sources:

Survey of Large FENOC and Contractor Personnel Sample.

SCWE-Related Policies, Procedures, and Work Practices.

SCWE Performance Indicators.

Diagnostic Quiz on SCWE Principles Provided to 20 Management Personnel.

Interviews of Selected Personnel.

September 18, 2002 55

Survey Results - Willingness of Workers to Raise Concerns KEY SURVEY QUESTIONS AGREE OR STRONGLY AGREE 1999 1/2002 8/2002

+ Ability to challenge non-conservative 48% 81% 70%

decision by management?

+ Feel free to approach mgmt. with 80% 92% 80%

nuclear/quality concerns?

+ Raise nuclear/quality concerns w/out 73% 89% 72%

fear of retaliation?

PERFORMANCE INDICATOR 1999 2000 2001 7/2002 2308 3253 3478 5700 Condition reports initiated ------------------

(annualized)

Although workers are writing CRs in increasing numbers, they have declining confidence in their ability to approach management with concerns or challenge non-conservative management decisions.

September 18, 2002 56

Survey Results - Management Support for Raising Concerns KEY SURVEY QUESTIONS AGREE OR STRONGLY AGREE 1999 1/2002 8/2002

+ Mgmt wants concerns reported? 84% 86% 76%

+ Mgmt is willing to listen to problems? 47% 72% 63%

+ Constructive criticism is encouraged? 44% 70% 52%

+ Mgmt. cares more about identification / NA NA 39%

resolution of nuclear/quality concerns than cost/schedule?

There has been an erosion in worker perception of managements commitment to encourage, address, and resolve concerns.

September 18, 2002 57

Survey Results - ECP/Ombudsman KEY SURVEY QUESTIONS AGREE OR STRONGLY AGREE 1999 1/2002 8/2002

+I can use ECP/Ombudsman without 59% 85% 70%

fear of reprisal?

+ECP/Ombudsman will maintain 56% 77% 66%

confidentiality?

+Upper management supports the ECP/ NA 77% 60%

Ombudsman program?

PERFORMANCE INDICATOR 1999 2000 2001 7/2002 Ombudsman contacts -------------------------- 5 21 18 42 (annualized)

Ombudsman investigations ------------------- 4 6 2 12 (annualized)

  • Contacts are increasing while necessary resources devoted to Ombudsman program are not.
  • Workers continue to use Ombudsman program as alternative to line management.
  • However, perceived lack of management support of the Ombudsman could lead to erosion of worker confidence in ability of program to adequately address issues.

September 18, 2002 58

Survey Results - Effectiveness in Resolving Issues Using Normal Processes KEY SURVEY QUESTIONS AGREE OR STRONGLY AGREE 1999 1/2002 8/2002

+ CAP is effective to identify potential 41% 82% 57%

nuclear safety / quality issues?

+ Free to report concerns using CAP 69% 87% 71%

without fear of reprisal?

+ Issues in CAP are prioritized 59% 70% 41%

appropriately, investigated thoroughly, and timely resolved?

+ CAP effective to timely resolve 44% 68% 42%

conditions adverse to quality?

+ CAP effective to address root causes 45% 75% 45%

and broader implications of nuclear safety / quality issues?

PERFORMANCE INDICATOR 1999 2000 2001 8/2002 NRC allegations (2002) ------------------------- 3 0 2 25*

(as of 9/1)

  • At least 4 of the 25 referred allegations were initiated by non D-B personnel.

September 18, 2002 59

Survey Results - Mgmt Effectiveness in Detecting and Preventing Retaliation KEY SURVEY QUESTIONS AGREE OR STRONGLY AGREE 1999 1/2002 8/2002

+ I have been adequately trained on the NA NA 72%

various processes for reporting and documenting nuclear / quality concerns?

+ My supervisors / managers have been NA NA 61%

adequately trained on the various processes for reporting and documenting nuclear / quality concerns?

+ I have been subject to HIRD for raising NA NA Yes - 7%

nuclear / quality concerns? (26)

+ I know of instances in which workers in NA NA Yes - 12%

my workgroup have been subject to HIRD (46) for raising nuclear / quality concerns?

September 18, 2002 60

Actions to Address Assessment Findings

  • The assessment recommendations have been translated into a SCWE Action Plan.

- The SCWE Action Plan has been incorporated into is a part of the Management and Human Performance Improvement Plan.

- Additional management resources from outside Davis-Besse will assist in implementing the Action Plan.

  • Willingness of Workers to Raise Concerns / Management Support for Raising Concerns:

- Perform 2d-level review of survey results to identify any SCWE challenged pockets within the organization.

- Expand Great Catch program.

- Publicize the survey results as a mechanism of change.

- Periodically repeat survey adding targeted questions.

- Continue four Cs meetings program.

- Include SCWE messages in Davis-Besse case study initiative.

September 18, 2002 61

Actions to Address Assessment Findings

  • ECP/Ombudsman:

- Implement industry best practice tools.

- Transform to proactive model.

- Assure no significant issues escape operability / reportability review (see Issue Management Process, below).

  • Effectiveness in Resolving Issues Using Normal Processes:

- Complete Program Compliance Plan Review of CAP and implementing corrective actions.

- Create integrated issue management process to assure timely, coordinated, and effective response to issues received outside CAP.

September 18, 2002 62

Actions to Address Assessment Findings

  • Management Effectiveness in Detecting and Preventing Retaliation:

- Train Officers, Directors, Managers, and Supervisors to detect and avoid retaliation and chilling effects.

- Establish People Team to review significant adverse personnel actions (e.g., discipline above oral reprimand, reductions-in-force, etc.) to prevent retaliation and/or chilling effect, and to respond quickly to any SCWE issues that may arise.

- Establish Issue Management Process to ensure SCWE issues are handled consistently independent of where they are raised initially.

September 18, 2002 63

Conclusion

  • The Results Obtained From the SCWE Assessment Reinforce the Need to Address Davis-Besses SCWE.
  • We Have Developed a SCWE Action Plan To Address the Assessment Results.
  • The Action Plan is Underway.

September 18, 2002 64

Success Criteria and NRC SCWE Attributes

  • Willingness of Employees to Raise Concerns /

Management Support for Raising Concerns.

- Communication of management expectations (applicable to all criteria).

- Supervisory and employee training.

  • Effectiveness of the Ombudsman Program / ECP.

- ECP elements and implementation.

September 18, 2002 65

Success Criteria and NRC SCWE Attributes

  • Managements Effectiveness in Resolving Issues Using Normal Processes.

- The Corrective Action Program.

- Roles and responsibilities of management in resolving employee concerns.

- Allegations raised outside CAP (NRC, HR, ECP).

- Self assessments.

  • Managements Effectiveness in Detecting and Preventing Retaliation and Chilling Effect.

- Response to retaliation and related claims.

- Supervisory training on means to detect and prevent retaliation/chilling effect.

- Contractor responsibilities.

September 18, 2002 66

Conclusions and Closing Comments Lew Myers Chief Operating Officer September 18, 2002 67

Conclusions on the Plan

  • Completed Root Cause Report and Developed Focus Areas
  • Developed Corrective Actions
  • Include Corrective Actions into the Work Plan September 18, 2002 68

Implementation of the Plan Completed Actions

  • New FENOC Management Team
  • New Davis-Besse Leadership Team
  • New Engineering Standards
  • Engineering Assessment Board Established
  • Restart Overview Panel Established September 18, 2002 69

Implementation of the Plan Completed Actions (continued)

  • Operations Oversight Executive added
  • Weekend Duty Requirements
  • Project Review Committee Enhanced Oversight
  • Corrective Action Review Board Enhanced Oversight
  • ROP Meetings with Employees
  • Augmentation of Engineering September 18, 2002 70

Implementation of the Plan Actions Already Underway

  • 4-Cs Meetings
  • Town Hall Meetings
  • ROP and EAB Reviews
  • Equipment Upgrades
  • Management Observations September 18, 2002 71

Signs of Improved Performance

  • We are not where we want to be
  • We are showing Improvement September 18, 2002 72

Overall Conclusions

  • Comprehensive Plan in place
  • We are Implementing the plan
  • We are beginning to see some improvement
  • Additional Improvements Needed September 18, 2002 73