ML040280597

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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 Cleveland Electric icon.png
Issue date: 01/27/2004
From: Bezilla M
FirstEnergy Nuclear Operating Co
To: Caldwell J
Region 3 Administrator
References
I-1342
Download: ML040280597 (76)
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Text

FENOC -

Firstolergy Nuclear Operating Company 5501 North Slate Route 2 Oak Harbor, Ohio 43449 Ma& 8. W l &

Vice President - Nuclear 419-321-7676 Fax: 4 19-32 I-7582 Docket Number 50-346 License Number NF'F-3 Serial Number 1 - 1342 January 27, 2004 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I11 80 1 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.

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

a)

Focused Self-Assessments b)

Ongoing Self-Assessments c)

Benchmarking d)

Quarterly Collective Significance Reviews Directors and Managers to attend a Leadership Academy to improve management skills Provide formal Management Observation Skills Training Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-000 1 Operations Expectations and Standards Improve trending of major plant evolutions utilizing the Management Observation Program to track performance and feedback Provide face-to-face communications training to all site supervisors and above Re-evaluate all Davis-Besse supervisors to assess competency for current positions Conduct Supervisor and Manager Talent Management Talks

10. Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings in accordance with Davis-Besse Business Practices DUE DATE June 30,2004 March 3 1 2004 March 3 1 2004 March 31,2004 Periodic through Cycle 14 June 30,2004 June 30,2004 June 30,2004 June 30,2004 June 30,2004 December 3 1 2005 March 31,2004 Periodic through Cycle 14

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

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. Strengthening Operating Crews, including assessment of operators, training on procedure use, and improving command and control
b. Strengthening Operating Procedures, including validation of key operating procedures and use of reverse pre-job briefs
c. Strengthening Operations Management, including use of Operations Oversight Managers until no longer needed
d. Strengthening Independent Oversight of Operations
4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations
6. Align Performance Indicators to Conduct of Operations March 3 1,2004 March 31,2004 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, use of operating experience, and lessons learned from rework activities
2. Improve Maintenance effectiveness through the assessment of work 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 March 3 1,2004 June 30,2004 Training Improvement Initiative
1. Improve individual and organizational performance and alignment by developing and providing training on design and configuration control to appropriate site staff
2. Establish engineering positional qualification requirements based on the standard FEiNOC Engineering Organization and complete qualification training for incumbent and new engineers September 30,2004 December 3 1,2004

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

1. Common Process
a. Complete training and mentoring to support the effective transition into
b. Resolve gaps in process implementation and station procedures
c. Perform quarterly assessments of Condition Reports and Workweek critiques to ensure opportunities for improvement are addressed
d. Implement Risk Management process to improve station knowledge and awareness
e. Monitor and improve Order quality
a.

the FENOC Work Management Process

2. Maintenance Backlog Reduction Complete walk-down and validation of the Order backlog to ensure proper category, priority, consolidation and elimination of invalid orders
b. Complete Cycle Plan identifying equipment outages and providing the framework for addressing backlog Order priorities and results of the System Health Report
c. Develop performance indicators to monitor and manage Order backlog
a. Forced Outage Schedule template and readiness
b. Mid-Cycle Outage Preparation
3. Outage Performance
c.
d. 14" Refueling Outage Preparation Clarify expectations and improve contractor performance DUE DATE March 3 1,2004 June 30,2004 Periodic through Cycle 14 March 3 1, 2004 June 30,2004 Complete March 3 1, 2004 Complete March 31,2004 1 mo. prior to Mid-Cycle Outage December 31,2004 December 3 1,2005

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

1. Implement actions to improve Safety Margin:
a. Determine the Safety Margin for the top 10 Risk Significant Systems and develop a plan to improve safety margins
b. Electrical System coordination improvements
c. Masonryhlock wall re-analyses and design changes
d. Service Water improvements
2. Perform additional Latent Issues Reviews
3. Implement the Design Calculation Improvement Plan
4. Enhance plant equipment performance through the FENOC Equipment Reliability Program
5. Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations
6. Schedule and conduct additional Program Compliance Reviews including:
a. Qualification of Program Owners
b. Development of Program Manuals
c. Creation of Performance Indicators
7. Establish the appropriate level of workload for Engineering Change Requests and develop a plan to reduce and maintain the backlogs to that level
8. Perform semiannual effectiveness reviews to determine if the problem solving process, NOP-ER-3001 has been properly implemented during the previous period Perform independent outside assessments of the effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations
10. Implement ATLAS software for electronic maintenance of design basis information and populate with 5 systems
11. Expand the role of the Engineering Assessment Board (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations At-Risk Changes in the plant modification process Assessment Reports
9.
12. Establish criteria and modify appropriate procedures to restrict the use of
13. Re-institute the use of Quarterly System Health Reports and Design Basis
14. Assign a Program Owner for the Problem Solving Process
15. Develop and begin implementation of the Technical Issues Resolution Process DUE DATE June 30.2004 December 3 1,2005 December 3 1,2005 Periodic through Cycle 14 Periodic through Cycle 14 Periodic through Cycle 14 Periodic through Cycle 14 December 3 1,2004 December 3 1,2004 June 30,2004 Periodic through Cycle 14 Periodic through Cycle 14 June 30,2004 Complete June 30,2004 Complete March 3 1,2004 March 3 1, 2004

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1342 Attachment Page 6 of 8 COMMITMENTS Continuous Safety Culture Improvement Initiative

1. Monitor Safety Culture on a monthly basis
2. Assess Safety Culture using the FENOC Business Practice
3. Perform a Safety Culture assessment utilizing an independent outside organization
4. Provide SCWE training to Site employees who have not completed the SCWE portion of the Site Employee Orientation Manual
5. Provide refresher training on SCWE and Safety Culture to Davis-Besse Supervisors and above
6. NQA to perform two Safety Culture Assessments
7. Employee Concerns Program group to perform two surveys of the Safety Conscious Work Environment DUE DATE Periodic through Cycle 14 December 3 1,2005 December 3 1,2004 March 3 1, 2004 March 3 1,2004 and September 30,2004 December 3 1,2004/05 December 3 1,2004/05 Procedure Imurovement Initiative
1. Perform Self-Assessments on 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 Corrective Action Program Improvement Initiative

1. Implement the Apparent Cause Improvement Plan:
a.
b.

C.

d.
e.
f.

g-Strengthen procedural requirements for apparent cause evaluations, including analytical methods to be used Corrective Action Review Board review of Apparent Cause Evaluations until standards are consistently met Identify Apparent Cause Evaluators Develop Training Program and Expectations and provide training to the Apparent Cause Evaluators (Initial Evaluator Classes and Additional Classes in 2004)

Qualify the trained Apparent Cause Evaluators using the Systematic Approach to Training On an interim basis, rotate team of apparent cause evaluators to Support Services Company Nuclear Review Board (CNRB) review of selected Apparent Cause Evaluations DUE DATE Complete Complete Complete Initial Training Complete Additional Training March 3 1,2004 March 3 1,2004 Complete Periodic through Cycle 14

2. Establish the appropriate level of workload for Condition Report Evaluations and Corrective Actions and develop a plan to reduce the backlogs to those levels
3. Perform a focused Self-Assessment of implementation of the Corrective Action Program using industry peers
4. Reestablish the Corrective Action Program trending process Complete
5. Provide Apparent Cause training to Managers March 3 1,2004 June 30,2004 March 3 1, 2004

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1342 Attachment Page 8 of 8

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COMMITMENTS Internal and External Oversight Improvement Initiative Supplement quality oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical Supplement management oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical Focus more quality oversight on cross-functional activities and interfaces Review and revise the master assessment plan at all three FENOC sites Conduct an external assessment to evaluate the progress of organizational improvements in the areas of Critical Self-Assessments and Performance Observations Utilize INPO Assist Visits to assess the effectiveness of Improvement Initiatives Perform Quality Oversight of Engineering using the Continuous Assessment Process Conduct assessment activities of the Corrective Action Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation DUE DATE Complete Complete March 3 1, 2004 March 3 1,2004 June 30.2004 December 31,2004 Periodic through Cycle 14 Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1342 Davis-Besse Nuclear Power Station Operati on a1 Improvement P1 an Operating Cycle 14 Revision 1 December 26,2003 (32 pages to follow)

FirstEnergy Nuclear Operating Company

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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

~-

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.

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

Comaetent lndiuidual Strong Exaerienced lndeaendent Programs Management Oversight strong safety focus delivering top fleet operating performance FENOC Vision:

People with a 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.

M. Bezilla B. Allen B. Allen B. Allen B. Allen J. Powers M. Bezilla R. Schrauder R. Schrauder L. Myers

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Organizational Effectiveness Improvement Operations Improvement Maintenance I m prove men t Training Improvement Work Management Improvement Engineering Improvement Continuous Safety Culture Improvement Procedure I m provement Corrective Action Program Improvement Internal and External Oversight Improvement Barriers.

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

1. Improve individual and organizational performance and alignment through development and utilization of alignment maps at the DepartmenVSection levels a) Focused Self-Assessments b) Ongoing Self-Assessments c) Benchmarking d) Quarterly Collective Significance Reviews to improve management skills
2. Implement FENOC Business Practices for:
3. Directors and Managers to attend a Leadership Academy
4. Provide formal Manaaement Observation Skills Trainina Owner J. Reddington L. Dohrmann D. Haskins J. Reddington Completion lst Qtr 2004 1 Qtr 2004 1 Qtr 2004 through Cycle 14 2nd Qtr 2004 2 Qtr 2004 IL u

I Page 7 of 31 Revision I

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14

5.
6.
7.
8.
9.

I O.

Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-000 1, Operations Expectations and Standards Improve trending of major plant evolutions utilizing the Management Observation Program to track performance and feedback Provide face-to-face communications training to all site supervisors and above Re-evaluate all Davis-Besse supervisors to assess competency for current positions Conduct Supervisor and Manager Talent Management Talks Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings in accordance with Davis-Besse Business Practices Owner K. Fehr K. Fehr D. Haskins D. Haskins D. Haskins M. Lark-Landis Completion Znd Qtr 2004 2d Qtr 2004 Znd Qtr 2004 4th Qtr 2005 lst Qtr 2004 through Cycle 14 Page 8 of 31 Revision 1

Davis-Besse Nuclear Power Station I.

Implement the Operations Excellence Plan:

a. Implement Operations Leadership Improvements
b. Implement the 5 year staffing plan
c. Implement improvements to Operations work stations
d. Implement common FENOC Operations work process
2. Improve Operator knowledge, skills and abilities through tools testing, training and mentoring Operational Improvement Plan Cycle 14 M. Roder M. Roder S. Wise T. Stallard J. Reddington 1" Qtr 2004 lst Qtr 2004 3rd Qtr 2004 4th Qtr 2004 4'h Qtr 2004 Page 9 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

3. Implement the Operations Improvement Action Plan, including:
a. Strengthening Operating Crews, including assessment of 1

M. Roder 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 ponsor: B. Allen Completion 4'h Qtr 2003
4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations I

st Qtr 2004 1 st Qtr 2004 M. Rsder

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 proveme n t I n it i a t ive riel Condition of the Davis-Besse
1. Improve Maintenance training and standards through post-job evaluations, use of operating experience, and lessons learned from rework activities
2. Improve Maintenance effectiveness through the assessment of work planning, scheduling, and implementation during critical equipment outages development establish improved ownership and accountability of Plant mat e riel co nd it ion
5. Improve Maintenance staff knowledge, skills and abilities
3. Improve Maintenance Supervision through training and
4. Improve Maintenance individual commitment area to 1

Owner M. Stevens-M. Stevens M. Stevens M. Stevens J. Reddington through testing, training and mentoring 3onsor: B. Allen Completion 1 Qtr 2004 Znd Qtr 2004 3rd Qtr 2004 4th Qtr 2004 qfh Qtr 2004 Page I 1 of 31 Revision 1

DavislBesse Nuclear Power Station

1. Improve individual and organizational performance and alignment by developing and providing training on design and configuration control to appropriate site staff
2. Establish engineering positional qualification requirements based on the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers Operational improvement Plan J. Reddington 3" Qtr 2004 J. Reddington 4th Qtr 2004 Cycle 14 t In it iat ive ES

..Key-Actions.

Page 12 of 31 Revision I

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

vement Initiative

1. Common Process
a. Complete training and mentoring to support the effective transition into the FENOC Work Management Process
b. Resolve gaps in process implementation and station procedures
c. Perform quarterly assessments of Condition Reports and Workweek critiques to ensure opportunities for improvement are addressed knowledge and awareness
d. Implement Risk Management process to improve station
e. Monitor and improve Order quality Owner G. Dunn Completion 1 1 Qtr 2004 2"d Qtr 2004 through Cycle 14 1 Qtr 2004 2"d Qtr 2004 Page 13 of 31 Revision 1

Davis-Besse Nuclear Power Station Complete 1" Qtr 2004 Complete 1 Qtr 2004 1 mo. prior to Mid-Cycle Outage 4'h Qtr 2004 4th Qtr 2005

~

Operational Improvement Plan Cycle 14 I

2. Maintenance Backlog Reduction
a. Complete walk-down and validation of the Order backlog to ensure proper category, priority, consolidation and elimination of invalid orders
b. Complete Cycle Plan identifying equipment outages and providing the framework for addressing backlog Order priorities and results of the System Health Report
c. Develop performance indicators to monitor and manage Order backlog
a. Forced Outage Schedule template and readiness
b. Mid-Cycle Outage Preparation
c. Clarify expectations and improve contractor performance
d. I 4'h Refueling Outage Preparation Owner G. Dunn Completion Page 14 of 31 Revision l E-

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 men t Initiative ring products, increased access to nd confinued improvemenf in

1. Implement actions to improve Safety Margin:
a. Determine the Safety Margin for the top 10 Risk Significant Systems and develop a plan to improve safety margins
b. Electrical System coordination improvements
c. Masonry/block wall re-analyses and design changes
d. Service Water improvements
2. Perform additional Latent Issues Reviews
3. Implement the Design Calculation Improvement Plan
4. Enhance plant equipment performance through the FENOC Equipment Reliability Program
5. Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations Sponsor: J. Powers Owner J. Grabnar B. Boles J. Grabnar J. Rogers B. Boles Completion 2"' Qtr 2004 4th Qtr 2005 4th Qtr 2005 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 4th Qtr 2004 Page I 5 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 t Initiative continu

6.
7.
8.
9.

I O Schedule and conduct additional Program Compliance Reviews including:

a. Qualification of Program Owners
b. Development of Program Manuals
c. Creation of Performance Indicators Establish the appropriate level of workload for Engineering Change Requests and develop a plan to reduce and maintain the backlogs to that level Perform semiannual effectiveness reviews to determine if the problem solving process, NOP-ER-3001 has been properly implemented during the previous period Perform independent outside assessments of the effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective act ions, and calculations Implement ATLAS software for electronic maintenance of design basis information and populate with 5 systems Owner J. Powers J. Grabnar B. Boles J. Powers C. Hawley Sponsor: J. Powers i... Completion 4'h Qtr 2004 2nd Qtr 2004 through Cycle 14 through Cycle 14 Znd Qtr 2004 Page 16 of 31 Revision 1

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

11. Expand the role of the Engineering Assessment Board (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations
12. Establish criteria and modify appropriate procedures to restrict the use of At-Risk Changes in the plant modification process
13. Re-institute the use of Quarterly System Health Reports and Design Basis Assessment Reports
14. Assign a Program Owner for the Problem Solving Process
15. Develop and begin implementation of the Technical Issues Resolution Process Owner J. Wilcox J. Grabnar B. Boles J. Grabnar B. Boles C. Hawley Completion Complete 2nd Qtr 2004 Complete 1" Qtr 2004 1" Qtr 2004 Page 17 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 prove men t I n it iat ive D

impro Safety Culture Power Station SDonsor: M. Bezilla y Actions

1. Monitor Safety Culture on a monthly basis
2. Assess Safety Culture using the FENOC Business
3. Perform a Safety Culture assessment utilizing an
4. Provide SCWE training to Site employees who have not Practice independent outside organization completed the SCWE portion of the Site Employee Orientation Manual Davis-Besse Supervisors and above
5. Provide refresher training on SCWE and Safety Culture to
6. NQA to perform two Safety Culture Assessments
7. Employee Concerns Program group to perform two surveys of the Safety Conscious Work Environment Owner M. Bezilla M. Bezilla M. Bezilla L. Griffith J. Reddington S. Loehlein L. Griffith Completion through Cycle 14 4'h Qtr 2005 4'h Qtr 2004 1 Qtr 2004 Is' ti 3rd Qtr 2004 4'h Qtr 2004/05 4'h Qtr 2004/05 Page 18 of 31 Revision 1

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

1. Perform Self-Assessments on procedure use and adherence
2. Review the Davis-Besse procedure change process to ensure alignment with FENOC standards for procedure preparation and revisions
3. Provide training on procedure use and adherence
4. Perform follow-up effectiveness reviews on procedure use and adherence S

. Owner R. Schrauder L. Dohrmann J. Reddington L. Dohrmann rrdized ompl through Cycle 14 1 Qtr 2004 Znd Qtr 2004 4'h Qtr 2004 Page 19 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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

. Owner L. Dohrmann L. Dohrmann Managers J. Reddington J. Reddington L. Dohrmann F. VonAhn Complete Complete Complete Initial Complete /

Additional 1 st Qtr 2004 lst Qtr 2004 Complete through Cycle 14 Page 20 of 31 Revision 1

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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

Owner L. Dohrmar I -

n L. Dohrmann L. Dohrmann L. Dohrmann onsor: R. Schrauder Completion lst Qtr 2004 2nd Qtr 2004 Complete lst Qtr 2004 Page 21 of 31 Revision 1

DavisBesse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Supplement quality oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical
2. Supplement management oversight with off-site assistance to improve objectivity and ensure assessments are sufficiently critical
3. Focus more quality oversight on cross-functional activities and interfaces
4. Review and revise the master assessment plan at all three FENOC sites
5. Conduct an external assessment to evaluate the progress of organizational improvements in the areas of Critical Self-Assessments and Performance Observations
6. Utilize INPO Assist Visits to assess the effectiveness of Improvement Initiatives Owner S. Loehlein M. Roder S. Loehlein S. Loehlein L. Myers M. Bezilla Sponsor: L. Myers Completion Complete Complete lst Qtr 2004 lst Qtr 2004 2"d Qtr 2004 4'h Qtr 2004 Page 22 of 31 Revision 1

DavislBesse Nuclear Power Station

8. Conduct assessment activities of the Corrective Action Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation Operational Improvement Plan Cycle 14 S. Loehlein through Cycle 14
7. Perform Quality Oversight of Engineering using the Continuous Assessment Process 1 S. Loehlein 1 through Cycle 14 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 Individual Error Rate Procedure and Orders use and adherence concerns Number of Operator Work Arounds Number of Control Room Deficiencies Percent of self-identified Employee willingness to raise Condition Reports (CRs)

Operational Improvement Plan

< 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 Improving trend in Management Observations associated Allen To be with Procedure and Order use and adherence developed NQA supervisors or the Employee Concerns Program Interviews Roder R-I 0 2 90% of individuals are willing to raise concerns to their Loehlein

< 1 Level 1 and 2 Work Arounds AND Implementation plans for each Work Around c 1 deficiencies Roder R-09 AND Each deficiency corrected within 1 operating cycle

> 90% of Condition Reports are self-identified Dohrmann P-05 Cycle 14 Item 1-01 1-02 1

1-04 1-05 1-06 1-07 1-08 1-09 Page 25 of 31 Revision I

Davis-Besse Nuclear Power Station Item 1-1 0 Operational Improvement Plan Attribute Cross-functional teamwork Cycle 14 1-1 1 1-12 1-1 3 1-14 I-? 5 SRO reviews for Operability are performed in a timely manner Employee willingness to use the Corrective Action Program Worker confidence in raising safety concerns Training Programs meet industry standards and effectively improve station performance as measured by Licensed Operator Requalification Training NOBP-TR-1501

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

> 75 Risk Assessment Indicator Roder The Risk Assessment Indicator assesses each unit's risk of achieving safe and reliable operation. This indicator accomplishes this by measuring elements related to the probability and consequence of station events. Examples of elements making up this indicator include Probabilistic Safety Assessment, Aggregate System Health, Schedule Adherence, Activities Resulting in Reduced Trip-Logic, Schedule Stability, Scrams, Derates, Unplanned entry into Tech Specs, Entry into Abnormal Procedures

> 95% pass rate in the Licensed Operator Requalification Training Program Owner Reddington Dunn Griffith 1

5% of individuals are not willing to use the Corrective Action Program I

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

Griffith quality concerns without fear of retaliation

> 2.5 Training Program Performance Indicator Reddington PI Source FENOC Risk Assessment Performance Indicator for Davis-Besse CA-0 1 SCWE/NQA Surveys S C W E/N QA Surveys P-02 To be developed Page 26 of 31 Revision I

Davis-Besse Nuclear Power Station

> 90% acceptance rate of Apparent Cause evaluations (as determined by the CAR6 Apparent Cause Subcommittee)

> 0.987 Reliability No repeat Maintenance Rule (a)(l) systems within the operating cycle

- 0.30 Program and process errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked

- 2.5 % rework 0 PMs past their late or defer to date AND

< 10% of PMs closed beyond 60% of the allowed grace Operational lmprovement Plan Cycle 14 Dohrmann CA-05 Boles S-05 Boles New Plant Engineering PI Reddington P-04 Steagall Maintenance Rework PI Dunn KPI-WM-06 P-02 P-03 P-04 P-05 P-06 P-07 Engineering Calculation Quality Effectiveness of Condition Report Process Condition Report (CR) category accuracy Apparent Cause evaluation quality Grabnar To be

< 1.0 score based on a 12 week rolling average (as measured by the Engineering Assessment Board Calculation Subcommittee) developed Maintenance Rule System Reliability Number of Maintenance Rule (a)(l) Systems Program and Process Error Rate Maintenance Rework

~

Number of late Preventative Maintenance Activities

> 14 Corrective Action Program Effectiveness I Dohrmann 1 P-01

> 90% CR category accuracy rate I Dohrmann I CA-08 Page 27 of 31 Revision I

Davis-Besse Nuclear Power Station Fehr Loehlein D. Haskins Operational Improvement Plan Semiannual Assessments NQA Field Assessments To be Cycle 14 M-03 M-04 M

M-06 M-07 The Quality of Engineering Products Satisfaction of employees using the Employee Concerns Program (ECP)

NRC Allegation Ratio Effectiveness of Safety Conscious Work Environment AND

< 0.5 score based on a 12 week rolling average (as measured by the Engineering Assessment Board)

> 75% of employees that use the Employee Concerns Program report being satisfied with the process

< 2 times the industry average of NRC allegations

< 15% SCWERT Non-Concurrence Ratio Review Team (SCWERT) in avoiding discrimination claims

llegations 2 times the industry average of NRC retaliation Management Observations are self critical Effectiveness of Management and Supervisors Improvements in Management Staffing

> 90% of the management observations performed are self-critical and recommended corrective actions were implemented Managers and supervisors are generally effective with a few exceptions

> 75% of open positions are filled within four months of the requisition receiving final approval AND Talent Management is in place for manager level positions and above AND Talent Management Candidates fill 1 70% of open leadership positions Grabnar EN-03 SCWE 1-3 developed Page 28 of 31 Revision 1

Davis-Besse Nuclear Power Station Goal c 1 Level 2 Reactivity Management Event per year AND 0 Level 1 Reactivity Management Events per year.

Operational Improvement Plan Owner PI Source Roder Operations Reactivity Management PI Cycle 14 USAR, Design Criteria Manual, System Description, Design Basis updates completed within 3 months of schedule I..

I u-Item -

M-08 Grabnar To be developed M-09 M-I 0 M-1 I M-I 2 M-13 Barrier Attributes Attribute Reactivity Management Fuel Integrity Maintenance Order Backlog Number of Temporary Modifications Backlog of Procedure Change Requests (PCRs)

Design Basis Maintenance Zero fuel defects FRlp < 5.0E-4 microcuries/gram.

Online:

c 50 Corrective Maintenance Orders

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

c 250 Corrective/Elective Maintenance Orders c 5 during the Operating Cycle And 0 related to equipment and design deficiencies after restart from major outages c 100 open Priority 1 and 2 Procedure Change Requests AND AND Kelley Dunn Boles Dohrmann R-07 KPI-WM-02 KPI-WM-02 MA41 Plant Engineering PI PR-01 Page 29 of 31 Revision 1

DavislBesse Nuclear Power Station Operational Improvement Plan Cycle 14 1004 I *-05 Field Activity Assessments Responsiveness to QA Identified Issues Condition Report NQA Review Corrective Action NQA Verification Timeliness of NQA Audit Report Issuance Use of Industry Peer Support ributes I

To be developed 100% utilization of the scheduled INPO Assist Visits for 2004 Bezilla 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........................................................

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

24

. Programs............................................................................................

27

. Management.......................................................................................

28

. Oversight............................................................................................

30 Examples of Performance Indicators.....................................................

31 7

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

25 Page 1 of 31 Revision 2

Davis-Besse Nuclear Power Station Ope rat iona I I m provernen t Plan Introduction Cycle 14 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 I

~~

Operational Improvement Plan Cycle 14 I

i C

H A

L L

E N

G E

[Barriers Demonstrating FENOCs Strong Safety Focus I tompetent Strong Experienced Indenendent Individual Programs Management Oversight FENOC Vision:

People with a strong safety focus delivering top fleet operating performance 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 will provide additional improvements to further strengthen each of the four barriers. Details for each initiative are provided in the following pages.

M. Bezilla B. Allen B. Allen J. Powers M. Bezilla R. Schrauder R. Schrauder L. Myers

1.

Organizational Effectiveness Improvement

3.

Maintenance Improvement perations I e

7.

Continuous Safety Culture Improvement

8.

Procedure Improvement

9.

Corrective Action Program Improvement IO. Internal and External Oversight Improvement X

X X

X X

X X

X -

Page 6 of 31 Revision 2

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

Improve individual and organizational performance and alignment through development and utilization of "alignment maps" at the DepartmenVSection levels

3. Directors and Managers to attend a Leadership Academy to improve management skills J. Reddington L. Dohrmann D. Haskins J. Reddinaton
4. Provide formal Management Observation Skills Training 2nd Qtr 2004 I"

Qtr 2004 1 Qtr 2004 Is*

Qtr 2004 through Cycle 14 2nd Qtr 2004 2nd Qtr 2004 Page 7 of 31 Revision 2

Davis=Besse Nuclear Power Station Operational Improvement Plan Cycle 14

5. Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards
7. Provide face-to-face communications training to all site supervisors and ab to assess
9. Conduct Supervisor and Manager Talent Management Talks IO. Continue with the 4 Cs meetings, D-B Team Meetings, Town Hall Meetings in accordance with Davis-Besse Business Practices K. Fehr D. Haskins D. Haskins D. Haskins M. Lark-Landis 2d Qtr 2004 2 Qtr 2004 Znd Qtr 2004 qfh Qtr 2005 lst Qtr 2004 through Cycle 14 Page 8 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Implement the Operations Excellence Plan:
a. lmplemen the 5 year staffing plan improvements to Opera
d. Implement common FENOC Operations work process k

, skills rough K. Ostrowski K. Ostrowski D. lmlay T. Stallard J. Reddington 1 Qtr 2004 1 Qtr 2004 3'cl Qtr 2004 4th Qtr 2004 4th Qtr 2004 I

Page 9 of 31 Revision 2

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

b. Strengthening Operating Procedures, including validation of ures and use o I K. Ostrowski
d. Strengthening Independent Oversight of Operations
4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations
6. Align Performance Indicators to Conduct of Operations K. Ostrowski K. Ostrowski K. Ostrowski I

st Qtr 2004 I

st Qtr 2004 1 st Qtr 2004 I

st 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 post-job evaluations, use of operating experience, and lessons learned from rework activities materiel condition through testing, training and mentoring

5. Improve Maintenance staff knowledge, skills and abilities M. Stevens M. Stevens M. Stevens M. Stevens J. Reddington lst Qtr 2004 2nd Qtr 2004 3rd Qtr 2004 4th Qtr 2004 4'h Qtr 2004 Page 11 of 31 Revision 2

s~aau!6ua 11

Davis-Besse Nuclear Power Station Operational improvement Plan Cycle 14

1. Common Process
d. Implement Risk Management process to improve station knowledge and awareness W. Mugge
e. Monitor and improve Order quality 1 Qtr 2004 2"d Qtr 2004 through Cycle 14 1 Qtr 2004 2nd Qtr 2004 Page 13 of 31 Revision 2

POOZ J1O ISL

Davis=Besse Nuclear Power Station Operational Improvement Plan

1. Implement actions to improve Safety Margin:
d. Service Water improvements additional Latent Issues Revie esign Calculation I quipment performa bility Program
5. Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations J. Grabnar B. Boles J. Grabnar J. Rogers B. Boles Cycle 14 2nd Qtr 2004 qfh Qtr 2005 4th Qtr 2005 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 4th Qtr 2004 Page I 5 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Schedule and conduct additional Program Compliance Reviews including :
a. Qualification of Program Owners
b. Development of Program Manuals
c. Creation of Performance Indicators
8. Perform semiannual effectiveness reviews to determine if the problem solving process, NOP-ER-3001 has been properly implemented during the previous period
9. Perform independent outside assessments of the effectiveness of Engineering corrective and improvement actions in the areas of modifications, System Engineering, corrective actions, and calculations I O. Implement ATLAS software for electronic maintenance of design basis information and populate with 5 systems J. Powers J. Grabnar B. Boles J. Powers C. Hawley 4'h Qtr 2004 2"d Qtr 2004 through Cycle 14 through Cycle 14 2nd Qtr 2004 Page 16 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

11. Expand the role of the Engineering Assessment Board (EAB) to include the review of Engineering Root Causes and Apparent Causes and Engineering Calculations
13. Re-institute the use of Quarterly System Health Reports and Design Basis Assessment Reports m Owner for the Pr Solving Process
15. Develop and begin implementation of the Technical Issues Resolution Process m

J. Wilcox J. Grabnar

9. Boles J. Grabnar B. Boles C. Hawley Corn plete 2"d Qtr 2004 Complete lst Qtr 2004 1 Qtr 2004 Page I 7 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan

1. Monitor Safety Culture on a monthly basis
5. Provide refresher training on SCWE and Safety Culture to Davis-Besse Supervisors and above
6. NQA to perform two Safety Culture As
7. Employee Concerns Program group to perform two survevs of the Safetv Conscious Work Environment L. GrifFith J. Reddington S. Loehlein L. Griffith Cycle 14 through Cycle 14 4th Qtr 2005 4th Qtr 2004 IS' Qtr 2004 lSt& 3" Qtr 2004 qfh Qtr 2004/05 qfh Qtr 2004/05 Page 18 of 31 Revision 2

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

Perform Self-Assessments on procedure use and ent with FENOC standa R. Schrauder through Cycle 14 L. Dohrmann lst Qtr 2004 J. Reddington 2"d Qtr 2004 L. Dohrmann 4th Qtr 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

b. Corrective Action Review Board review of Apparent Cause
c. Identify Apparent Cause Evaluators
d. Develop Training Program and Expectations and provide training to the Apparent Cause Evaluators (Initial Evaluator Classes and Additional Classes in 2004)
e. Qualify the trained Apparent Cause Systematic Approach to Training
f. On an interim basis, rotate team of apparent cause evaluators to Support Services
g. Company Nuclear Review Board (CNRB) review of selected Apparent Cause Evaluations analytical me to be Evaluations until standards are consistently met tors using the L. Dohrmann L. Dohrmann Managers J. Reddington J. Reddington L. Dohrmann F. VonAhn I

Complete Complete Complete Initial Complete /

Additional 1 st Qtr 2004 lst Qtr 2004 Complete through Cycle 14 Page 20 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

2.
3.
4.

Establish the appropriate level of workload for Condition Report Evaluations and Corrective Actions and develop a plan to reduce the backlogs to those levels Reestablish the Corrective Action Program trending process L. Dohrmann L. Dohrmann I'

Y,

'e continued -5, lst Qtr 2004 2nd Qtr 2004 Complete IS' Qtr 2004 Page 21 of 31 Revision 2

Davis-Besse Nuclear Power Station Operational improvement Plan

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

' objectivity

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

5. Conduct an external assessment to evaluate the progress of organizational improvements in the areas of Critical Self-Assessments and Performance Observations
6. Utilize INPO Assist Visits to assess the effectiveness of Improvement Initiatives Cycle 14 S. Loehlein K. Ostrowski S. Loehlein S. Loehlein L. Myers M. Bezilla Complete Complete lst Qtr 2004 lst Qtr 2004 2nd Qtr 2004 4th Qtr 2004 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 603 0-d uueuu yoa

!YSMOJJSQ

~

80-1 LO-I 90-1 so-I PO-I

Operational Improvement Plan Cycle 14 1-12 1-1 3 1-1 0 are performed in a timely manner Employee willingness to use the Corrective Action Program Worker confidence in raising safety concerns Cross-functional teamwork 1-1 4 1-1 5 Training Programs meet industry standards and effectively improve station performance as measured by Licensed Operator Requalification Training NOBP-TR-1501

> 75 Risk Assessment Indicator The Risk Assessment Indicator assesses each units risk of achieving safe and reliable operation. This indicator accomplishes this by measuring elements related to the probability and consequence of station events. Examples of elements making up this indicator include Probabilistic Safety Assessment, Aggregate System Health, Schedule Adherence, Activities Resulting in Reduced Trip-Logic, Schedule Stability, Scrams, Derates, Unplanned entry into Tech Specs, Entry into Abnormal Procedures

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

< 5% of individuals are not willing to use the Corrective Action Program 7 90% of workers believe they can raise nuclear safety or quality concerns without fear of retaliation

> 2.5 Training Program Performance Indicator

> 95% pass rate in the Licensed Operator Requalification Training Program Ostrowski

~

Griffith Griffith Reddington Reddington

~

PI Source FENOC Risk Assessment Performance Indicator for Davis-Besse CA-01 SCWUNQA Surveys SCWE/NQA Surveys P-02 To be developed Page 26 of 31 Revision 2

Operational Improvement Plan Dohrmann Cycle 14 CA-05 P-01 P-02 P-03 P-04 P-05 P-06 P-07 P-08 Mugge Grabnar P-09 KPI-WM-06 To be developed Effediveness of Condition Report Process Condition Report (CR) category accuracy Apparent Cause evaluation quality Maintenance Rule System Reliability Number of Maintenance Rule (a)(l) Systems Program and Process Error Rate Maintenance Rework Number of late Preventative Maintenance Activities Engineering Calculation QuaSi

> 14 Corrective Action Program Effectiveness

> 90% CR category accuracy rate

> 90% acceptance rate of Apparent Cause evaluations (as determined by the CARB Apparent Cause Subcommittee)

> 0.987 Reliability No repeat Maintenance Rule (a)(l) systems within the operating cycle

.: 0.30 Program and process errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked

- 2.5 % rework 0 PMs past their late or defer to date AND

< 10% of PMs closed beyond 60% of the allowed grace period c 1.0 score based on a 12 week rolling average (as measured by the Engineering Assessment Board Calculation Subcommittee)

Dohrmann I P-01 Dohrrnann I CA-08 Boles Boles New Plant Engineering Reddington I P-04 Steagall Maintenance I ReworkPI I

Page 27 of 31 Revision 2

Davis-Besse Nuclear Power Station Owner Grabnar Operational improvement Plan PI Source EN-03 Item -

M M

M-03 Griffith Griffith Schrauder Fehr Loehlein

.,,\\' '.Attribute SCWE 3-4 SCWE 1-2 SCWE 4-5 SCWE 1-3 Semiannual Assessments NQA Field Assessments M-04 M

M-06 M-07 The Quality of Engineering Products Satisfaction of employees using the Employee Concerns Program (ECP)

NRC Allegation Ratio Effectiveness of Safety Conscious Work Environment Review Team (SCWERT) in avoiding discrimination claims

~

~~

~

~

Management Observations are self critical Effectiveness of Management and Supervisors Improvements in Management Staffing Cycle 14

< 0.5 score based on a 12 week rolling average (as measured by the Engineering Assessment Board)

> 75% of employees that use the Employee Concerns Program report being satisfied with the process

~-

~~

< 2 times the industry average of NRC allegations

< 15% SCWERT Non-Concurrence Ratio

< 2 times the industry average of NRC retaliation allegations

> 90% of the management observations performed are self-critical and recommended corrective actions were implemented Managers and supetvisors are generally effective with a few exceptions

> 75% of open positions are filled within four months of the requisition receiving final approval Talent Management is in place for manager level positions and above Talent Management Candidates fill 2 70% of open leadership positions AND AND AND Page 28 of 31 Revision 2

Davis-Besse Nuclear Power Station M-08 Operational Improvement Plan Cycle 14 Reactivity Management M-09 M-I 0 M-I 1 M-12 M-13

- 1 Level 2 Reactivity Management Event per year 0 Level 1 R e a c t i i Management Events per year.

AND Fuel Integrity Zero fuel defects Kelley R-07 AND FRlp e 5.0E-4 microcurie$/gram.

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 Number of Temporary

- 5 during the Operating Cycle Boles Plant Modifications And Engineering 0 related to equipment and design deficiencies after restart PI PR-01 from major outages Backlog of Procedure Change -

c 100 open Priority I and 2 Procedure Change Requests Dohrmann Requests (PCRs)

Design Basis Maintenance To be developed USAR, Design Criteria Manual, System Description, Design Basis updates completed within 3 months of schedule Grabnar Operations I Ostrowski I Reactivity Management I

I PI Page 29 of 31 Revision 2

Davis-Besse Nuclear Power Station 0-02

~~

-~

Operational Improvement Plan Responsiveness to QA Identified Issues Cycle 14 c 45 days for SCAQ Condition Report Investigations

< 60 days for CAQ Condition Report Investigations

> 90% of Condition Report Investigations reviewed by NQA are accepted or rejected within 15 days after the investigation was complete

> 90% of Corrective Actions verified or rejected by NQA within 30 days c 25 working days from the date of the exit conference AND Loehlein Loehlein Loehlein Loehlein 0-03 Condition Report NQA Review 0-04 0-05 0-06 Corrective Action NQA Verification Timeliness of NQA Audit Report Issuance Use of Industry Peer Support DB-02 DB-03 DB-04 100% utilization of the scheduled INPO Assist Visits for 2004 DB-05 Bezilla To be 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

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