ML040280597

Submittal of Revision 1 and Revision 2 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

ML040280597
Person / Time
Site:	Davis Besse
Issue date:	01/27/2004
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Caldwell J Region 3 Administrator
References
I-1342
Download: ML040280597 (76)

Text

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FENOC Firstolergy Nuclear Operating Company Ma& 8.W l &

Vice President - Nuclear 5501 North Slate Route 2 Oak Harbor, Ohio 43449 419-321-7676 Fax: 4 19-32I - 7582 Docket Number 50-346 License Number NF'F-3 Serial Number 1- 1342 J a n u a r y 2 7 , 2004 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I11 801 Warrenville Road Lisle, IL 60532-435 1

Subject:

Submittal of Revision 1 and Revision 2 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

Dear Mr. Caldwell:

On November 23,2003 (Serial 1-1336), the FirstEnergy Nuclear Operating Company (FENOC) submitted the Integrated Report to Support Restart of the Davis-Besse Nuclear Power Station.

Appendix D of the Integrated Report contained Revision 0 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14. As stated in the introduction of the Operational Improvement Plan, this plan is a living document and will be periodically updated and revised to address completed actions and add new initiatives.

The Operational Improvement Plan Operating Cycle 14 was revised on December 26,2003 and again on January 20,2004 to include additional initiatives, change the owners of key actions as a result of recent management organizational changes, and to update existing initiatives as they are completed. The purpose of this letter is to submit Revision 1 and Revision 2 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14 as enclosures to this letter. Revision 2 dated January 20,2004, supercedes all previous revisions in their entirety.

Commitments are identified in the attached Commitment List. Also, it should be noted that FirstEnergy Nuclear Operating Company may periodically update this document in the future and will submit any subsequent revisions to the Nuclear Regulatory Commission.

If you have any questions or require further information, please contact Mr. Gregory A. Dunn, Manager -

Regulatory Affairs, at (41 9) 321-8450.

Sincerely yours,

Docket Number 50-346 License Number NPF-3 Serial Number 1-1342 Page 2 GB Attachment Enclosures cc: USNRC Document Control Desk John A. Grobe, Chairman NRC 0350 Panel J. B. Hopkins, DB-1 NRCMRR 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- 1342 Attachment Page 1 of 8 COMMITMENT LIST The following list identifies those actions committed to by the 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 information and are not regulatory commitments.

Please notify the Manager - Regulatory Affairs (419-321-8450) at the DBNPS of any questions regarding this document or associated regulatory commitments.

The following commitments are based on Revision 2 of the Davis-Besse Operational Improvement Plan Operating Cycle 14.

COMMITMENTS DUE DATE Organizational Effectiveness Improvement Initiative

1. Improve individual and organizational performance and alignment through June 30,2004 development and utilization of alignment maps at the Department/Section levels

2. Implement FENOC Business Practices for:

a) Focused Self-Assessments March 3 1 2004 b) Ongoing Self-Assessments March 3 1 2004 c) Benchmarking March 31,2004 d) Quarterly Collective SignificanceReviews Periodic through Cycle 14

3. Directors and Managers to attend a Leadership Academy to improve June 30,2004 management skills

4. Provide formal Management Observation Skills Training June 30,2004

5. Enhance the Management Observation Program by ensuring personnel June 30,2004 providing oversight monitoring are familiar with DBBP-OPS-000 1 Operations Expectations and Standards

6. Improve trending of major plant evolutions utilizing the Management June 30,2004 Observation Program to track performance and feedback

7. Provide face-to-face communications training to all site supervisors and June 30,2004 above

8. Re-evaluate all Davis-Besse supervisors to assess competency for current December 3 1 2005 positions

9. Conduct Supervisor and Manager Talent Management Talks March 31,2004

10. Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings Periodic through Cycle 14 in accordance with Davis-Besse Business Practices

Docket Number 50-346 License Number NPF-3 Serial Number 1-1342 Attachment Page 2 of 8 COMMITMENTS DUE DATE Operations Improvement Initiative

1. Implement the Operations Excellence Plan:

a. Implement Operations Leadership Improvements March 3 1,2004

b. Implement the 5 year staffing plan March 31, 2004

c. Implement improvements to Operations work stations September 30,2004

d. Implement common FENOC Operations work process tools December 3 1,2004

2. Improve Operator knowledge, skills and abilities through testing, training December 3 1,2004 and mentoring

3. Implement the Operations Improvement Action Plan, including: March 3 1, 2004

a. StrengtheningOperating Crews, including assessment of operators, training on procedure use, and improving command and control

b. StrengtheningOperating Procedures, including validation of key operating procedures and use of reverse pre-job briefs

c. StrengtheningOperations Management, including use of Operations Oversight Managers until no longer needed

d. StrengtheningIndependent Oversight of Operations

4. Strengthen Communications within Operations March 3 1,2004

5. Benchmark Conduct of Operations March 31,2004

6. Align Performance Indicators to Conduct of Operations March 3 1,2004

Docket Number 50-346 License Number NPF-3 Serial Number 1-1342 Attachment Page 3 of 8 COMMITMENTS DUE DATE Maintenance Improvement Initiative

1. Improve Maintenance training and standards through post-job evaluations, March 3 1,2004 use of operating experience, and lessons learned from rework activities

2. Improve Maintenance effectiveness through the assessment of work June 30,2004 planning, scheduling, and implementation during critical equipment outages

3. Improve Maintenance Supervision through training and development September 30,2004

4. Improve Maintenance individual commitment area to establish improved December 3 1,2004 ownership and accountability of Plant materiel condition

5. Improve Maintenance staff knowledge, skills and abilities through testing, December 3 1,2004 training and mentoring Training Improvement Initiative

1. Improve individual and organizational performance and alignment by September 30,2004 developing and providing training on design and configuration control to appropriate site staff

2. Establish engineering positional qualification requirements based on the December 3 1,2004 standard FEiNOC Engineering Organization and complete qualification training for incumbent and new engineers

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1342 Attachment Page 4 of 8 COMMITMENTS DUE DATE Work Management Improvement Initiative

1. Common Process

a. Complete training and mentoring to support the effective transition into March 3 1,2004 the FENOC Work Management Process

b. Resolve gaps in process implementation and station procedures June 30,2004

c. Perform quarterly assessments of Condition Reports and Workweek Periodic through Cycle 14 critiques to ensure opportunities for improvement are addressed

d. Implement Risk Management process to improve station knowledge and March 3 1,2004 awareness

e. Monitor and improve Order quality June 30,2004

2. Maintenance Backlog Reduction

a. Complete walk-down and validation of the Order backlog to ensure Complete proper category, priority, consolidation and elimination of invalid orders

b. Complete Cycle Plan identifying equipment outages and providing the March 3 1, 2004 framework for addressing backlog Order priorities and results of the System Health Report

c. Develop performance indicators to monitor and manage Order backlog Complete

3. Outage Performance

a. Forced Outage Schedule template and readiness March 31,2004

b. Mid-Cycle Outage Preparation 1 mo. prior to Mid-Cycle Outage

c. Clarify expectations and improve contractor performance December 31,2004

d. 14" Refueling Outage Preparation December 3 1,2005

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1342 Attachment Page 5 of 8 COMMITMENTS DUE DATE Engineering Improvement Initiative

1. Implement actions to improve Safety Margin:

a. Determine the Safety Margin for the top 10 Risk Significant Systems June 30.2004 and develop a plan to improve safety margins

b. Electrical System coordination improvements December 3 1,2005

c. Masonryhlock wall re-analyses and design changes December 3 1,2005

d. Service Water improvements Periodic through Cycle 14

2. Perform additional Latent Issues Reviews Periodic through Cycle 14

3. Implement the Design Calculation Improvement Plan Periodic through Cycle 14

4. Enhance plant equipment performance through the FENOC Equipment Periodic through Cycle 14 Reliability Program

5. Develop and implement the plan to enhance System Engineering ownership December 3 1,2004 of plant systems in support of Operations

6. Schedule and conduct additional Program Compliance Reviews including: December 3 1,2004

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 June 30,2004 Requests and develop a plan to reduce and maintain the backlogs to that level

8. Perform semiannual effectiveness reviews 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 ATLAS software for electronic maintenance of design basis June 30,2004 information and populate with 5 systems

11. Expand the role of the Engineering Assessment Board (EAB) to include the Complete review of Engineering Root Causes and Apparent Causes and Engineering Calculations

12. Establish criteria and modify appropriate procedures to restrict the use of June 30,2004 At-Risk Changes in the plant modification process

13. Re-institute the use of Quarterly System Health Reports and Design Basis Complete Assessment Reports

14. Assign a Program Owner for the Problem Solving Process March 3 1,2004

15. Develop and begin implementation of the Technical Issues Resolution March 3 1, 2004 Process

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1342 Attachment Page 6 of 8 COMMITMENTS DUE DATE 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 assessment utilizing an independent outside December 3 1,2004 organization

4. Provide SCWE training to Site employees who have not completed the March 3 1, 2004 SCWE portion of the Site Employee Orientation Manual

5. Provide refresher training on SCWE and Safety Culture to Davis-Besse March 3 1,2004 and Supervisors and above September 30,2004

6. NQA to perform two Safety Culture Assessments December 3 1,2004/05

7. Employee Concerns Program group to perform two surveys of the Safety December 3 1,2004/05 Conscious Work Environment Procedure Imurovement Initiative

1. Perform Self-Assessmentson procedure use and adherence Periodic through Cycle 14

2. Review the Davis-Besse procedure change process to ensure alignment with March 3 1, 2004 FENOC standards for procedure preparation and revisions

3. Provide training on procedure use and adherence June 30,2004

4. Perform follow-up effectiveness reviews on procedure use and adherence December 3 1,2004

Docket Number 50-346 License Number NPF-3 Serial Number 1-1342 Attachment Page 7 of 8 COMMITMENTS DUE DATE Corrective Action Program Improvement Initiative

1. Implement the Apparent Cause Improvement Plan:

a. Strengthen procedural requirements for apparent cause evaluations, Complete including analytical methods to be used

b. Corrective Action Review Board review of Apparent Cause Evaluations Complete until standards are consistently met C. Identify Apparent Cause Evaluators Complete

d. Develop Training Program and Expectations and provide training to the Initial Training Complete Apparent Cause Evaluators Additional Training (Initial Evaluator Classes and Additional Classes in 2004) March 3 1,2004

e. Qualify the trained Apparent Cause Evaluators using the Systematic March 3 1,2004 Approach to Training

f. On an interim basis, rotate team of apparent cause evaluators to Support Complete Services g- Company Nuclear Review Board (CNRB) review of selected Apparent Periodic through Cycle 14 Cause Evaluations

2. Establish the appropriate level of workload for Condition Report March 3 1,2004 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 June 30,2004 Action Program using industry peers

4. Reestablish the Corrective Action Program trending process Complete

5. Provide Apparent Cause training to Managers March 3 1, 2004

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1342 Attachment Page 8 of 8 COMMITMENTS DUE DATE Internal and External Oversight Improvement Initiative

1. Supplement quality oversight with off-site assistance to improve objectivity Complete and ensure assessments are sufficiently critical

2. Supplement management oversight with off-site assistance to improve Complete objectivity and ensure assessments are sufficiently critical

3. Focus more quality oversight on cross-functional activities and interfaces March 3 1, 2004

4. Review and revise the master assessment plan at all three FENOC sites March 3 1,2004

5. Conduct an external assessment to evaluate the progress of organizational June 30.2004 improvements in the areas of Critical Self-Assessments and Performance Observations

6. Utilize INPO Assist Visits to assess the effectiveness of Improvement December 31,2004 Initiatives

7. Perform Quality Oversight of Engineering using the Continuous Periodic through Cycle 14 Assessment Process

8. Conduct assessment activities of the Corrective Action Program to evaluate Periodic through Cycle 14 effectiveness of corrective actions taken to improve implementation and improve trend evaluation

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1342 Davis-Besse Nuclear Power Station Operati on a1 Improvement P1an Operating Cycle 14 Revision 1 December 26,2003 (32 pages to follow)

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DavislBesse 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 barriers 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 barriers 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 ProgramslCorrective 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 barriers 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.

Page 2 of 31 Revision 1

Davis-Besse Nuclear Power Station

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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 fust 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 bamer to ensure nuclear safety.

To guide the individual in performing their required job fbnctions, 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 bamers 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 identi@

differences fiom 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.

Page 3 of 31 Revision I

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 This illustration represents how the four safety barriers failed, allowing the degradation of the RFV 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 A

I I

E lndividuaI Management Page 4 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14 1 Barriers Demonstratin@FENOCs Strong Safety Focus 1 C L H

A L FENOC Vision:

1 People with a strong safety E focus delivering N top fleet operating G performance E Comaetent Strong Exaerienced lndeaendent lndiuidual Programs Management Oversight Page 5 of 31 Revision 1

DavislBesse 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 fkrther strengthen each of the four barriers. Details for each initiative are provided in the following pages.

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5" - d M. Bezilla 1. Organizational Effectiveness Improvement X X B. Allen 2. Operations Improvement X X X B. Allen 3. Maintenance I mprovement X X B. Allen 4. Training Improvement X X B. Allen 5. Work Management Improvement X X J. Powers 6. Engineering Improvement X X X M. Bezilla 7. Continuous Safety Culture Improvement X X R. Schrauder 8. Procedure I mprovement X R. Schrauder 9. Corrective Action Program Improvement X X X L. Myers I O . Internal and External Oversight Improvement X X Page 6 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 ME: lmproved Hu nce, Leadership and Team Alignment I

Owner Completion

1. Improve individual and organizational performance and J. Reddington alignment through development and utilization of alignment maps at the DepartmenVSection levels

2. Implement FENOC Business Practices for: L. Dohrmann a) Focused Self-Assessments lst Qtr 2004 b) Ongoing Self-Assessments 1 Qtr 2004 c) Benchmarking 1 Qtr 2004 d) Quarterly Collective Significance Reviews through Cycle 14

3. Directors and Managers to attend a Leadership Academy D. Haskins 2ndQtr 2004 to improve management skills

4. Provide formal Manaaement IL Observation Skills Trainina u

J. Reddington 2 Qtr 2004 I Page 7 of 31 Revision I

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Owner Completion

5. Enhance the Management Observation Program by K. Fehr Znd Qtr 2004 ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards

6. Improve trending of major plant evolutions utilizing the K. Fehr 2d Qtr 2004 Management Observation Program to track performance and feedback

7. Provide face-to-face communications training to all site D. Haskins Znd Qtr 2004 supervisors and above

8. Re-evaluate all Davis-Besse supervisors to assess D. Haskins 4th Qtr 2005 competency for current positions

9. Conduct Supervisor and Manager Talent Management D. Haskins lst Qtr 2004 Talks I O . 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 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I.Implement the Operations Excellence Plan:

a. Implement Operations Leadership Improvements M. Roder 1" Qtr 2004

b. Implement the 5 year staffing plan M. Roder lst Qtr 2004

c. Implement improvements to Operations work stations S. Wise 3rdQtr 2004

d. Implement common FENOC Operations work process T. Stallard 4thQtr 2004 tools

2. Improve Operator knowledge, skills and abilities through J. Reddington 4'h Qtr 2004 testing, training and mentoring Page 9 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 ponsor: B. Allen Completion

3. Implement the Operations Improvement Action Plan, including: 1 M. Roder 4'hQtr 2003

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 Ist Qtr 2004

5. Benchmark Conduct of Operations M. Rsder 1st Qtr 2004

6. Align Performance Indicators to Conduct of Operations 1 M.Roder I Is' Qtr 2004 Page I O of 31 Revision 1

Davis-Besse Nuclear Power Station ~ _ -_

Operational improvement Plan Cycle 14

3. Maintenanc provement Initiat ive riel Condition of the Davis-Besse 1

3onsor: B. Allen Owner Completion

1. Improve Maintenance training and standards through M. Stevens- 1 Qtr 2004 post-job evaluations, use of operating experience, and lessons learned from rework activities

2. Improve Maintenance effectiveness through the assessment M. Stevens Znd Qtr 2004 of work planning, scheduling, and implementation during critical equipment outages

3. Improve Maintenance Supervision through training and M. Stevens 3rdQtr 2004 development

4. Improve Maintenance individual commitment area to M. Stevens 4th Qtr 2004 establish improved ownership and accountability of Plant materiel condition

5. Improve Maintenance staff knowledge, skills and abilities J. Reddington qfhQtr 2004 through testing, training and mentoring Page I 1 of 31 Revision 1

DavislBesse Nuclear Power Station Operational improvement Plan Cycle 14 t Initiative ES

. .Key-Actions. .,.

1. Improve individual and organizational performance and J. Reddington 3" Qtr 2004 alignment by developing and providing training on design and configuration control to appropriate site staff

2. Establish engineering positional qualification requirements J. Reddington 4thQtr 2004 based on the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers Page 12 of 31 Revision I

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

vement Initiative

1. Common Process Owner G. Dunn Completion 1

a. Complete training and mentoring to support the effective 1 Qtr 2004 transition into the FENOC Work Management Process

b. Resolve gaps in process implementation and station 2"d Qtr 2004 procedures

c. Perform quarterly assessments of Condition Reports and through Cycle 14 Workweek critiques to ensure opportunities for improvement are addressed

d. Implement Risk Management process to improve station 1 Qtr 2004 knowledge and awareness

e. Monitor and improve Order quality 2"d Qtr 2004 Page 13 of 31 Revision 1

Davis-Besse Nuclear Power Station ~

Operational Improvement Plan Cycle 14 Owner Completion

2. Maintenance Backlog Reduction G. Dunn

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 1" Qtr 2004 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 Complete I

a. Forced Outage Schedule template and readiness 1 Qtr 2004

b. Mid-Cycle Outage Preparation 1 mo. prior to Mid-Cycle Outage

c. Clarify expectations and improve contractor performance 4'hQtr 2004

d. I4'h Refueling Outage Preparation 4thQtr 2005 Page 14 of 31 Revision l E

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 ment Initiative ring products, increased access to nd confinued improvemenf in Sponsor: J. Powers Owner Completion

1. Implement actions to improve Safety Margin: J. Grabnar

a. Determine the Safety Margin for the top 10 Risk Significant 2"' Qtr 2004 Systems and develop a plan to improve safety margins

b. Electrical System coordination improvements 4thQtr 2005

c. Masonry/block wall re-analyses and design changes 4thQtr 2005

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 J. Rogers through Cycle 14 Equipment Reliability Program

5. Develop and implement the plan to enhance System B. Boles 4th Qtr 2004 Engineering ownership of plant systems in support of Operations Page I 5 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 t Initiative continu Sponsor: J. Powers Owner i. .Completion

6. Schedule and conduct additional Program Compliance J. Powers 4'h Qtr 2004 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 2ndQtr 2004 Change Requests and develop a plan to reduce and maintain the backlogs to that level

8. Perform semiannual effectiveness reviews to determine if the B. Boles through Cycle 14 problem solving process, NOP-ER-3001 has been properly implemented during the previous period

9. Perform independent outside assessments of the J. Powers through Cycle 14 effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations I O Implement ATLAS software for electronic maintenance of C. Hawley Znd Qtr 2004 design basis information and populate with 5 systems Page 16 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 nt Initiative continued SDonsor: J. Powers Owner Completion

11. Expand the role of the Engineering Assessment Board J. Wilcox 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 2ndQtr 2004 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 1" Qtr 2004

15. Develop and begin implementation of the Technical Issues C. Hawley 1" Qtr 2004 Resolution Process Page 17 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 provement Initiative D impro Safety Culture Power Station SDonsor: M. Bezilla y Actions Owner Completion

1. Monitor Safety Culture on a monthly basis M. Bezilla through Cycle 14

2. Assess Safety Culture using the FENOC Business M. Bezilla 4'h Qtr 2005 Practice

3. Perform a Safety Culture assessment utilizing an M. Bezilla 4'h Qtr 2004 independent outside organization

4. Provide SCWE training to Site employees who have not L. Griffith 1 Qtr 2004 completed the SCWE portion of the Site Employee Orientation Manual

5. Provide refresher training on SCWE and Safety Culture to J. Reddington Is' ti 3rdQtr 2004 Davis-Besse Supervisors and above

6. NQA to perform two Safety Culture Assessments S. Loehlein 4'h Qtr 2004/05

7. Employee Concerns Program group to perform two L. Griffith 4'h Qtr 2004/05 surveys of the Safety Conscious Work Environment Page 18 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 dherence and sfanc rrdized S

. Owner ompl

1. Perform Self-Assessments on procedure use and R. Schrauder through Cycle 14 adherence

2. Review the Davis-Besse procedure change process to L. Dohrmann 1 Qtr 2004 ensure alignment with FENOC standards for procedure preparation and revisions

3. Provide training on procedure use and adherence J. Reddington Znd Qtr 2004

4. Perform follow-up effectiveness reviews on procedure L. Dohrmann 4'h Qtr 2004 use and adherence Page 19 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

. Owner

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 Initial Complete /

training to the Apparent Cause Evaluators Additional 1st Qtr (Initial Evaluator Classes and Additional Classes in 2004) 2004

e. Qualtfy the trained Apparent Cause Evaluators using the J. Reddington lst Qtr 2004 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 F. VonAhn through Cycle 14 selected Apparent Cause Evaluations Page 20 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

-I onsor: R. Schrauder Owner Completion

2. Establish the appropriate level of workload for Condition L. Dohrmar n lstQtr 2004 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 L. Dohrmann 2ndQtr 2004 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 lstQtr 2004 I'

Page 21 of 31 Revision 1

DavisBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Sponsor: L. Myers Owner Completion

1. Supplement quality oversight with off-site assistance to S. Loehlein Complete improve objectivity and ensure assessments are sufficiently critical

2. Supplement management oversight with off-site M. Roder Complete assistance to improve objectivity and ensure assessments are sufficiently critical

3. Focus more quality oversight on cross-functional activities S. Loehlein lst Qtr 2004 and interfaces

4. Review and revise the master assessment plan at all three S. Loehlein lst Qtr 2004 FENOC sites

5. Conduct an external assessment to evaluate the progress L. Myers 2"d Qtr 2004 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 4'h Qtr 2004 Improvement Initiatives Page 22 of 31 Revision 1

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14

7. Perform Quality Oversight of Engineering using the Continuous Assessment Process 1 S. Loehlein 1 through Cycle 14

8. Conduct assessment activities of the Corrective Action S. Loehlein through Cycle 14 Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation Page 23 of 31 Revision I

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14 Safetv Barrier Attributes and Goals Safety Barrier 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 rating 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.

Page 24 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

-Item 1-01 1-02 1-03 1-04 Individual Error Rate -< 0.29 individual errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked based on Reddington P-03 a 12 week rolling average 1-05 Procedure and Orders use Improving trend in Management Observations associated Allen To be and adherence with Procedure and Order use and adherence developed 1-06 Employee willingness to raise 2 90% of individuals are willing to raise concerns to their Loehlein NQA concerns supervisors or the Employee Concerns Program Interviews 1-07 Number of Operator -< 1 Level 1 and 2 Work Arounds Roder R-I0 Work Arounds -

AND Implementation plans for each Work Around 1-08 Number of Control Room -c 1 deficiencies Roder R-09 Deficiencies -

AND Each deficiency corrected within 1 operating cycle 1-09 Percent of self-identified -> 90% of Condition Reports are self-identified Dohrmann P-05 Condition Reports (CRs)

Page 25 of 31 Revision I

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item Attribute Owner PI Source 1-10 Cross-functional teamwork -> 75 Risk Assessment Indicator Dunn FENOC Risk Assessment The Risk Assessment Indicator assesses each unit's risk of Performance achieving safe and reliable operation. This indicator Indicator for accomplishes this by measuring elements related to the Davis-Besse 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 1-11 SRO reviews for Operability -> 95% of SRO review required Condition Reports were Roder CA-01 are performed in a timely reviewed for operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> manner 1-12 1-13 Employee willingness to use the Corrective Action Program Worker confidence in raising 5% of individuals are not willing to use the Corrective Action Program

> 90% of workers believe they can raise nuclear safety or 1I I

Griffith Griffith SCWE/NQA Surveys SCWE/NQA safety concerns quality concerns without fear of retaliation Surveys 1-14 Training Programs meet > 2.5 Training Program Performance Indicator Reddington P-02 industry standards and effectively improve station performance as measured by NOBP-TR-1501 I-?5 Licensed Operator -> 95% pass rate in the Licensed Operator Requalification Reddington To be Requalification Training Training Program developed Page 26 of 31 Revision I

Davis-Besse Nuclear Power Station Operational lmprovement Plan Cycle 14 Effectiveness of Condition -> 14 Corrective Action Program Effectiveness I Dohrmann 1 P-01 Report Process P-02 Condition Report (CR) category accuracy

-> 90% CR category accuracy rate I Dohrmann I CA-08 P-03 Apparent Cause evaluation -> 90% acceptance rate of Apparent Cause evaluations Dohrmann CA-05 quality (as determined by the CAR6 Apparent Cause Subcommittee)

P-04 Maintenance Rule System -> 0.987 Reliability Boles S-05 Reliability P-05 Number of Maintenance Rule No repeat Maintenance Rule (a)(l) systems within the Boles New Plant (a)(l) Systems operating cycle Engineering PI P-06 Program and Process Error - 0.30 Program and process errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Reddington P-04 Rate worked P-07 Maintenance Rework - 2.5 % rework Steagall Maintenance Rework PI

~

Number of late Preventative 0 PMs past their late or defer to date Dunn KPI-WM-06 MaintenanceActivities -AND

< 10% of PMs closed beyond 60% of the allowed grace Engineering Calculation -< 1.0 score based on a 12 week rolling average Grabnar To be Quality (as measured by the Engineering Assessment Board developed Calculation Subcommittee)

Page 27 of 31 Revision I

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 The Quality of Engineering -< 0.5 score based on a 12 week rolling average Grabnar EN-03 Products (as measured by the Engineering Assessment Board)

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

M-03 NRC Allegation Ratio < 2 times the industry average of NRC allegations M-04 Effectiveness of Safety -< 15% SCWERT Non-Concurrence Ratio Conscious Work Environment -AND Review Team (SCWERT) in 2 times the industry average of NRC retaliation SCWE 1-3 avoiding discrimination claims ;llegations M-05 Management Observations are > 90% of the management observations performed are Fehr Semiannual self critical self-criticaland recommended corrective actions were Assessments

- implemented M-06 Effectiveness of Management Managers and supervisors are generally effective with a Loehlein NQA Field and Supervisors few exceptions Assessments M-07 Improvements in Management - > 75% of open positions are filled within four months of the D. Haskins To be Staffing requisition receiving final approval developed

-AND Talent Management is in place for manager level positions and above

-AND Talent Management Candidates fill 1 70% of open leadership positions Page 28 of 31 Revision 1

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

I

.. Barrier Attributes u-Item Attribute Goal Owner PI Source M-08 Reactivity Management -c 1 Level 2 Reactivity ManagementEvent per year Roder Operations

-AND Reactivity 0 Level 1 Reactivity Management Events per year. Management PI M-09 Fuel Integrity Zero fuel defects Kelley R-07 AND FRlp < 5.0E-4 microcuries/gram.

M-I 0 Maintenance Order Backlog Online: Dunn c 50 Corrective Maintenance Orders KPI-WM-02 AND

< 450 Elective Maintenance Orders KPI-WM-02 Outaqe (prior to the startup from 14RFO):

c 250 Corrective/ElectiveMaintenance Orders MA41 M-1I Number of Temporary -c 5 during the Operating Cycle Boles Plant Modifications -And Engineering 0 related to equipment and design deficiencies after restart PI from major outages M-I 2 Backlog of Procedure Change -c 100 open Priority 1 and 2 Procedure Change Requests Dohrmann PR-01 Requests (PCRs)

M-13 Design Basis Maintenance USAR, Design Criteria Manual, System Description, Design Grabnar To be Basis updates completed within 3 months of schedule developed Page 29 of 31 Revision 1

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 ributes I Field Activity Assessments Responsiveness to QA Identified Issues Condition Report NQA Review 1004 Corrective Action NQA Verification I *-05 Timeliness of NQA Audit Report Issuance Use of Industry Peer Support 100% utilization of the scheduled INPO Assist Visits for Bezilla To be 2004 developed Page 30 of 31 Revision 1

Docket Number 50-346 License Number NPF-3 Serial Number 1-1342 Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14 Revision 2 January 20,2004 (32 pages to follow)

FirstEnergy Nuclear Operating Company DavislBesse 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 ............................................................................................ 27

. Management ....................................................................................... 28

. Oversight ............................................................................................ 30 Examples of Performance Indicators ..................................................... 31 Page 1 of 31 Revision 2

Davis-Besse Nuclear Power Station OperationaI Improvernent Plan Cycle 14 Introduction To ensure continued improvements and sustained performance in Nuclear Safety and Plant Operatiori at the Davis-Besse Nuclear Power Station, the Leadership Team has developed this Improvement Plan to focus on key improvement initiatives and safety barriers 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 fiom the significant Reactor Pressure Vessel Head degradation identified at the beginning of the 13h Reheling 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 barriers that failed to detect the significant RPV Head degradation are maintained to prevent a recurrence of an event in the hture.

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 ActionsProcedure 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 barriers 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 fhther built upon to improve performance in the fbture. 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.

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 Barriers To Ensure Nuclear Safe@

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 fmt 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 Ouersight I

I E

N m

E Individual Management Page 4 of 31 Revision 2

Davis-Besse Nuclear Power Station ~~

Operational Improvement Plan Cycle 14 I

I i

[Barriers Demonstrating FENOCs Strong Safety Focus C

H A

L FENOC Vision:

L People with a strong safety E focus delivering N top fleet operating G performance E tompetent Strong Experienced Indenendent Individual Programs Management Oversight I

Page 5 of 31 Revision 2

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 w ill provide additional improvements to further strengthen each of the four barriers. Details for each initiative are provided in the following pages.

M. Bezilla 1. Organizational Effectiveness Improvement perations I e X B. Allen 3. Maintenance Improvement X X

B. Allen X J. Powers X M. Bezilla 7. Continuous Safety Culture Improvement X R. Schrauder 8. Procedure Improvement X R. Schrauder 9. Corrective Action Program Improvement X L. Myers IO. Internal and External Oversight Improvement -

Page 6 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational lmprovement Plan Cycle 14 I.Improve individual and organizational performance and J. Reddington 2ndQtr 2004 alignment through development and utilization of "alignment maps" at the DepartmenVSection levels L. Dohrmann I" Qtr 2004 1 Qtr 2004 Is* Qtr 2004 through Cycle 14

3. Directors and Managers to attend a Leadership Academy D. Haskins 2ndQtr 2004 to improve management skills

4. Provide formal Management Observation Skills Training -

J. Reddinaton 2ndQtr 2004 Page 7 of 31 Revision 2

Davis=BesseNuclear Power Station Operational Improvement Plan Cycle 14

5. Enhance the Management Observation Program by 2dQtr 2004 ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards K. Fehr 2 Qtr 2004

7. Provide face-to-face communications training to all site D. Haskins Znd Qtr 2004 supervisors and ab to assess D. Haskins qfhQtr 2005

9. Conduct Supervisor and Manager Talent Management D. Haskins lst Qtr 2004 Talks IO. 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 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Implement the Operations Excellence Plan:

a. lmplemen K. Ostrowski 1' Qtr 2004 the 5 year staffing plan K. Ostrowski 1' Qtr 2004 improvements to Opera D. lmlay 3'clQtr 2004

d. Implement common FENOC Operations work process T. Stallard 4thQtr 2004 k , skills rough J. Reddington 4th Qtr 2004 Page 9 of 31 Revision 2 I

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14 Implement the Operations Improvement ImplementationAction Plan, including:

I K. Ostrowski Ist Qtr 2004

b. Strengthening Operating Procedures, including validation of ures and use o

d. Strengthening Independent Oversight of Operations

4. Strengthen Communications within Operations K. Ostrowski Ist Qtr 2004

5. Benchmark Conduct of Operations K. Ostrowski 1st Qtr 2004

6. Align Performance Indicators to Conduct of Operations K. Ostrowski Ist Qtr 2004 Page I O of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I.Improve Maintenance training and standards through M. Stevens lstQtr 2004 post-job evaluations, use of operating experience, and lessons learned from rework activities M. Stevens 2ndQtr 2004 M. Stevens 3rdQtr 2004 M. Stevens 4thQtr 2004 materiel condition

5. Improve Maintenance staff knowledge, skills and abilities J. Reddington 4'hQtr 2004 through testing, training and mentoring Page 11 of 31 Revision 2

s~aau!6ua 11 Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14

1. Common Process W. Mugge 1 Qtr 2004 2"d Qtr 2004 through Cycle 14

d. Implement Risk Management process to improve station 1 Qtr 2004 knowledge and awareness

e. Monitor and improve Order quality 2ndQtr 2004 Page 13 of 31 Revision 2

POOZ J1O ISL Davis=BesseNuclear Power Station Operational Improvement Plan Cycle 14

1. Implement actions to improve Safety Margin: J. Grabnar 2ndQtr 2004 qfhQtr 2005 4thQtr 2005

d. Service Water improvements through Cycle 14 additional Latent Issues Revie B. Boles through Cycle 14 esign Calculation I J. Grabnar through Cycle 14 quipment performa J. Rogers through Cycle 14 bility Program

5. Develop and implement the plan to enhance System B. Boles 4th Qtr 2004 Engineering ownership of plant systems in support of Operations Page I 5 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Schedule and conduct additional Program Compliance J. Powers 4'h Qtr 2004 Reviews including:

a. Qualification of Program Owners

b. Development of Program Manuals

c. Creation of Performance Indicators J. Grabnar 2"dQtr 2004

8. Perform semiannual effectiveness reviews to determine if the B. Boles through Cycle 14 problem solving process, NOP-ER-3001 has been properly implemented during the previous period

9. Perform independent outside assessments of the J. Powers through Cycle 14 effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations I O . Implement ATLAS software for electronic maintenance of C. Hawley 2ndQtr 2004 design basis information and populate with 5 systems Page 16 of 31 Revision 2

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

11. Expand the role of the Engineering Assessment Board J. Wilcox Cornplete (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations J. Grabnar 2"dQtr 2004

13. Re-institute the use of Quarterly System Health Reports and 9.Boles Complete Design Basis Assessment Reports J. Grabnar m Owner for the Pr Solving Process B. Boles lst Qtr 2004

15. Develop and begin implementation of the Technical Issues C. Hawley 1 Qtr 2004 Resolution Process Page I 7 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Monitor Safety Culture on a monthly basis through Cycle 14 4thQtr 2005 4thQtr 2004 L. GrifFith IS' Qtr 2004

5. Provide refresher training on SCWE and Safety Culture to J. Reddington lSt& 3" Qtr 2004 Davis-Besse Supervisors and above

6. NQA to perform two Safety Culture As S. Loehlein qfhQtr 2004/05

7. Employee Concerns Program group to perform two L. Griffith qfhQtr 2004/05 survevs of the Safetv Conscious Work Environment Page 18 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I.Perform Self-Assessments on procedure use and R. Schrauder through Cycle 14 L. Dohrmann lstQtr 2004 ent with FENOC standa J. Reddington 2"d Qtr 2004 L. Dohrmann 4thQtr 2004 I

Page 19 of 31 Revision 2

Davis-Besse Nuclear Power Station

1. Implement the Apparent Cause Improvement Plan:

a. I requirement PPare use L. Dohrmann Complete analytical me to be

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 Initial Complete /

training to the Apparent Cause Evaluators Additional 1st Qtr (Initial Evaluator Classes and Additional Classes in 2004) 2004

e. Qualify the trained Apparent Cause tors using the J. Reddington lst Qtr 2004 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 F. VonAhn through Cycle 14 I

selected Apparent Cause Evaluations Page 20 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

'e continued -5, ,

2. Establish the appropriate level of workload for Condition lstQtr 2004 Report Evaluations and Corrective Actions and develop a plan to reduce the backlogs to those levels

3. 2ndQtr 2004

4. Reestablish the Corrective Action Program trending L. Dohrmann Complete process L. Dohrmann IS'Qtr 2004 I'

Y, Page 21 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14

1. Supplement quality oversight with off-site assistance to S. Loehlein Complete improve objectivity and ensure assessments are sufficiently critical agement oversigh K. Ostrowski Complete

' objectivity

. Focus more quality oversight on c S. Loehlein lstQtr 2004 and interfaces ise the master asses plan at all three S. Loehlein lstQtr 2004

5. Conduct an external assessment to evaluate the progress L. Myers 2ndQtr 2004 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 4thQtr 2004 Improvement Initiatives Page 22 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

~~ ~

Page 23 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 4 4 Safetv Barrier Attributes and Goals Safety Barrier 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 rating 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.

Page 24 of 31 Revision 2

SO-d uueuuyoa

~

603 80-1

!YSMOJJSQ LO-I 90-1 so-I 0-d PO-I

Operational Improvement Plan Cycle 14

~

PI Source 1-10 Cross-functionalteamwork -> 75 Risk Assessment Indicator FENOC Risk Assessment The Risk Assessment Indicator assesses each units risk of Performance achieving safe and reliable operation. This indicator Indicator for accomplishes this by measuring elements related to the Davis-Besse 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 Ostrowski ~ CA-01 are performed in a timely reviewed for operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> manner 1-12 Employee willingness to use -< 5%of individuals are not willing to use the Corrective Griffith SCWUNQA the CorrectiveAction Action Program Surveys Program 1-13 Worker confidence in raising 7 90% of workers believe they can raise nuclear safety or Griffith SCWE/NQA safety concerns quality concerns without fear of retaliation Surveys 1-14 Training Programs meet > 2.5Training Program Performance Indicator Reddington P-02 industry standards and effectively improve station performanceas measured by NOBP-TR-1501 1-15 Licensed Operator -> 95% pass rate in the Licensed Operator Requalification Reddington To be RequalificationTraining Training Program developed Page 26 of 31 Revision 2

Operational Improvement Plan Cycle 14 P-01 Effediveness of Condition Report Process

-> 14 Corrective Action Program Effectiveness Dohrmann I P-01 P-02 Condition Report (CR) category accuracy

-> 90% CR category accuracy rate Dohrrnann I CA-08 P-03 Apparent Cause evaluation -> 90% acceptance rate of Apparent Cause evaluations Dohrmann CA-05 quality (as determined by the CARB Apparent

.. Cause Subcommittee)

P-04 Maintenance Rule System -

> 0.987 Reliability Boles Reliability P-05 Number of Maintenance Rule No repeat Maintenance Rule (a)(l) systems within the Boles New Plant (a)(l) Systems operating cycle Engineering P-06 Program and Process Error .:0.30 Program and process errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Reddington I P-04 Rate worked P-07 Maintenance Rework P-08 Number of late Preventative 2.5 % rework 0 PMs past their late or defer to date Steagall I Maintenance ReworkPI Mugge KPI-WM-06 Maintenance Activities -AND

< 10% of PMs closed beyond 60% of the allowed grace period P-09 Engineering Calculation -c 1.0 score based on a 12 week rolling average Grabnar To be QuaSi (as measured by the Engineering Assessment Board developed Calculation Subcommittee) I Page 27 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14 Item . . ,,\' '.Attribute Owner PI Source M-01 The Quality of Engineering -< 0.5 score based on a 12 week rolling average Grabnar EN-03

- Products (as measured by the EngineeringAssessment Board)

M-02 Satisfactionof employees > 75% of employees that use the Employee Concerns Griffith SCWE 3-4 using the Employee Concerns Program report being satisfied with the process

- Program (ECP) ~- ~~

M-03 NRC Allegation Ratio < 2 times the industry average of NRC allegations Griffith SCWE 1-2 M-04 Effectivenessof Safety -< 15% SCWERT Non-ConcurrenceRatio Schrauder SCWE 4-5 Conscious Work Environment AND Review Team (SCWERT) in avoiding discrimination claims

-< 2 times the industry average of NRC retaliation SCWE 1-3

- ~ _ _ ~~ ~~

allegations M-05 Management Observations are > 90% of the management observations performed are Fehr Semiannual self critical self-critical and recommended corrective actions were Assessments

- implemented M-06 Effectivenessof Management Managers and supetvisors are generally effective with a Loehlein NQA Field and Supervisors few exceptions Assessments M-07 Improvements in Management - > 75% of open positions are filled within four months of the Staffing requisition receivingfinal approval AND Talent Management is in place for manager level positions and above AND Talent Management Candidates fill 2 70% of open

- leadership positions Page 28 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 M-08 Reactivity Management - 1 Level 2 Reactivity Management Event per year AND I Ostrowski I Operations Reactivity M-09 Fuel Integrity 0 Level 1 R e a c t i i Management Events per year.

I I Management PI Zero fuel defects Kelley R-07 AND FRlp e 5.0E-4 microcurie$/gram.

M-I 0 Maintenance Order Backlog Online: Mugge

< 50 Corrective Maintenance Orders KPI-WM-02 AND 450 Elective Maintenance Orders KPI-WM-02 Outaae (prior to the startup from 14RFO):

< 250 CorrectiveElective Maintenance Orders MA41 M-I 1 Number of Temporary - 5 during the Operating Cycle Boles Plant Modifications And Engineering 0 related to equipment and design deficiencies after restart PI from major outages M-12 Backlog of Procedure Change -c 100 open Priority Iand 2 Procedure Change Requests Dohrmann PR-01 Requests (PCRs)

M-13 Design Basis Maintenance USAR, Design Criteria Manual, System Description, Design Grabnar To be Basis updates completed within 3 months of schedule developed Page 29 of 31 Revision 2

Davis-Besse Nuclear Power Station -~ ~~ -

Operational Improvement Plan Cycle 14 0-02 Responsivenessto QA -c 45 days for SCAQ Condition Report Investigations Loehlein DB-02 Identified Issues -

AND

< 60 days for CAQ Condition Report Investigations 0-03 Condition Report NQA -> 90% of Condition Report Investigationsreviewed by NQA Loehlein DB-03 Review are accepted or rejected within 15 days after the investigationwas complete 0-04 Corrective Action NQA -> 90% of Corrective Actions verified or rejected by NQA Loehlein DB-04 Verification within 30 days 0-05 Timeliness of NQA Audit -c 25 working days from the date of the exit conference Loehlein DB-05 Report Issuance 0-06 Use of Industry Peer Support 100% utilization of the scheduled INPO Assist Visits for Bezilla To be 2004 developed Page 30 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Examples of FENOC Performance Indicators for Davis-Besse Page 31 of 31 Revision 2