ML040560558

Submittal of Revision 3 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

ML040560558
Person / Time
Site:	Davis Besse
Issue date:	02/19/2004
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Caldwell J NRC/RGN-III
References
1-1348
Download: ML040560558 (11)

Text

FENOC -

FirstEnergy Nuclear Operating Company 5501 North Stale Route 2 Oak Harbor; Ohio 43449 Mark B. Bazilla Vice President - Nuclear 4 19-32 1-7676 Fax: 4 19-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1348 February 19, 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 3 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

Dear Mr. Caldwell:

On January 27,2004 (Serial 1 -1342), the FirstEnergy Nuclear Operating Company (FENOC) submitted Revision 2 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.

The Operational Improvement Plan Operating Cycle 14 was again revised on February 17,2004, to clarify some initiative key actions, update existing initiatives as they are completed, revise completion dates for a number of key actions, and to update barrier attribute performance indicators to be consistent with existing FENOC monthly performance indicators where applicable. Completion dates for some near term key actions were extended one additional calendar quarter as a result of delays in achieving restart and returning to normal plant operations. This delay affected some of the initiatives contained within the Operational Improvement Plan that are intended to be post restart actions to ensure continued improved performance.

This letter submits Revision 3 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14 as an enclosure. Revision 3 dated February 17,2004, supercedes all previous revisions in their entirety.

Regulatory commitments are identified in the attached Commitment List. The changes in commitments from Revision 2 to Revision 3 are identified in bold italics. FENOC may periodically update this document and will submit 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.

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1 348 Page 2 GB Attachment Enclosure cc:

USNRC Document Control Desk John A. Grobe, Chairman NRC 0350 Panel J. B. Hopkins, DB-1 NRCNRR 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 1-1 348 Attachment Page 1 of 8 COMMITMENT LIST The following list identifies those actions committed to by FENOCs Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments.

Please notify the Manager - Regulatory Affairs (41 9-32 1-8450) at the DBNPS of any questions regarding this document or associated regulatory commitments.

The following commitments are based on Revision 3 of the Davis-Besse Operational Improvement Plan Operating Cycle 14. Changes from previous commitments in Revision 2 of the Operational Improvement Plan are identified in bold Italics.

COMMITMENTS Orpanizational Effectiveness Improvement Initiative

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

2. Implement FENOC Business Practices for:

a)

Focused Self-Assessments b)

Ongoing Self-Assessments c)

Benchmarking d)

Quarterly Collective Significance Reviews

3. Directors and Managers to attend a Leadership Academy to improve management skills

4. Provide formal Management Observation Skills Training

5. Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-000 1,

Operations Expectations and Standards

6. ImpZenzent actions tu improve trending of major plant evolutions utilizing the Management Observation Program to track performance and feedback

7. Provide face-to-face communications training to all site supervisors and above

8. Reevaluate all Davis-Besse supervisors to assess competency for current positions

9. 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 September 30,2004 March 3 1 2004 March 3 1 2004 June 30,2004 June 30,2004 September 30,2004 June 30,2004 June 30,2004 June 30,2004 June 30,2004 December 3 1, 2005 March 3 1,2004 Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 348 Attachment Page 2 of 8 COMMITMENTS ODerations ImDrovement Initiative DUE DATE

1. Implement Operations Improvements:

a. Initiate Operations Leadership Improvements March 3 1,2004

b. Initiate the 5 year staffing plan March 3 1,2004

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:

Complete

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 June 30,2004 June 30,2004

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 348 Attachment Page 3 of 8 COMMITMENTS DUE DATE Maintenance Imorovement Initiative

1. Utilize post-job evaluations, operating experience, and lessons learned from rework activities to identi& improvements in Maintenance training and standards

2. Perform an assessment of Maintenance effectiveness work planning, scheduling, and implementation of critical equipment outages to idenrifi) improvements

3. Implement improvements of Maintenance Supervision through training and development

4. Implement actions in the Maintenance individual commitment area to establish improved ownership and accountability of Plant materiel condition 5. Perform testing ofMaintenance staff knowledge, skills and abilities to identi& improvement actions and incorporate into training June 30,2004 September 30,2004 September 30,2004 December 3 1,2004 December 3 1,2004 Traininp Improvement Initiative

1. Implement actions to improve individual and organizational performance and alignment by developing and providing training on design and configuration control to appropriate site staff

2. Establish engineering positional qualification requirements based on the standard FENOC 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 1-1348 Attachment Page 4 of 8 COMMITMENTS Work Management ImDrovement 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. 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 the FENOC Work Management Process

2. Maintenance Backlog Reduction

3. Outage Performance DUE DATE June 30,2004 September 30,2004 Periodic through Cycle 14 June 30,2004 June 30,2004 Complete June 30,2004 Complete March 3 1,2004 1 mo. prior to Mid-Cycle Outage

c. Clarify expectations and improve contractor performance December 3 1,2004

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

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 348 Attachment Page 5 of 8

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COMMITMENTS EnPineerinP Improvement Initiative Implement actions to improve Safety Margin:

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

b. Electrical System coordination improvements

c. Masonryblock wall re-analyses and design changes

d. Service Water improvements Perform additional Latent Issues Reviews Implement the Design Calculation Improvement Plan Enhance plant equipment performance through the FENOC Equipment Reliability Program Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations Schedule and conduct additional Program Compliance Reviews including:

a. Qualification of Program Owners

b. Development of Program Manuals

c. Creation of Performance Indicators Establish the appropriate level of workload for Engineering Change Requests and develop a plan to reduce and maintain the backlogs to that level 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 electronic accessibility of design basis information and populate 1 1. Expand the role of the Engineering Assessment Board (EAB) to include the with 5 systems review of Engineering Root Causes and Apparent Causes and Engineering Calculations At-Risk Changes in the plant modification process Assessment Reports

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 September 30,2004 Complete June 30,2004 Complete March 3 1,2004 June 30,2004

Docket Number 50-346 License Number NPF-3 Serial Number 1-1348 Attachment Page 6 of 8

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COMMITMENTS Continuous Safetv Culture Improvement Initiative Monitor Safety Culture on a monthly basis Assess Safety Culture using the FENOC Business Practice Perform a Safety Culture assessment utilizing an independent outside organization Provide SCWE training to Site employees who have not completed the SCWE portion of the Site Employee Orientation Manual Provide refresher training on SCWE and Safety Culture to Davis-Besse Supervisors and above NQA to perform two Safety Culture Assessments Employee Concerns Program group to perform two surveys of the Safety Conscious Work Environment Perform an effectiveness assessment of the corrective actions taken in response to the November 2003 SCWE survey results 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 June 30,2004 Procedure Improvement Initiative Perform Self-Assessments on procedure use and adherence Periodic through Cycle 14 Review the Davis-Besse procedure change process to ensure alignment with June 30,2004 FENOC standards for procedure preparation and revisions Provide training on procedure use and adherence June 30,2004 Perform follow-up effectiveness reviews on procedure use and adherence December 3 1,2004

Docket Number 50-346 License Number NPF-3 Serial Number 1-1348 Attachment Page 7 of 8

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COMMITMENTS Corrective Action Propram Improvement Initiative Implement the Apparent Cause Improvement Plan:

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

Docket Number 50-346 License Number NPF-3 Serial Number 1-1348 Attachment Page 8 of 8

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COMMITMENTS Internal and External Oversight ImDrovement 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 June 30,2004 June 30,2004 December 3 1,2004 Periodic through Cycle 14 Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1348 Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14 Revision 3 February 17,2004 (32 pages to follow)