ML053110306

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Submittal of Revision 9 of Operational Improvement Plan Operating Cycle 14
ML053110306
Person / Time
Site: Davis Besse 
Issue date: 10/31/2005
From: Bezilla M
FirstEnergy Nuclear Operating Co
To: Caldwell J
NRC/RGN-III
References
1-1443
Download: ML053110306 (47)
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Text

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FistEnsrgy Nuclear Operating Cmpany 5501 North Slate Roule 2 Oak Harbor Ohio 43449 Mark 8. W l k ~

Vice President - Nucleai 4 19-321-7676 Fax 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 October 3 1.2005 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I11 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352

Subject:

Submittal of Revision 9 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14

Dear Mr. Caldwell:

The purpose of this letter is to submit Revision 9 of the Davis-Besse Nuclear Power Station (DBNPS) Operational Improvement Plan Operating Cycle 14, dated October 21, 2005, to the Nuclear Regulatory Commission (NRC). By letter dated April I, 2005, the FirstEnergy Nuclear Operating Company (FENOC) submitted Revision 8 (DBNPS Letter Serial Number 1.1409) of the DBNPS Operational Improvement Plan Operating Cycle 14. The NRC letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order, (DBNPS Letter Log Number 1-4524) requires FENOC to notify the NRC of changes in the actions committed to in this Plan. The DBNPS Operational Improvement Plan, Revision 9, supercedes all previous revisions in their entirety.

This revision to the Plan includes the identification of initiative actions completed since the prior revision of the Plan and changes to barrier attribute performance indicators as detailed in of this letter. Additional changes to barrier attribute performance indicators beyond the level of detail level described in the Operational Improvement Plan are included as of this letter. The changes to the barrier attribute performance indicators were discussed with Ms. Lipa and Mr. Thomas of your staff on October 4, 2005.

Regulatory commitments are identified in the Commitment List (Attachment 1) with changes in commitments from Revision 8 to Revision 9 identified in bold italicized text.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 2 of 2 FENOC will update the DBNPS Operational Improvement Plan Operating Cycle 14 periodically to provide a status of the actions, and will submit subsequent revisions to the NRC following these changes.

If you have any questions or require further information, please contact Mr. Clark A. Price, Manager - Regulatory Compliance, at (419) 321-8585.

Sincerely yours,

,j2LX5 LJS Attachments Enclosure cc:

USNRC Document Control Desk C. A. Lipa, Chief, Reactor Projects Branch 4 W. A. Macon, DB-1 NRUNRR Project Manager C. S. Thomas, DB-I Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Attachment I Page I 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 Compliance (419-321-8585) at the DBNPS of any questions regarding this document or associated regulatory commitments.

The following commitments are based on Revision 9 of the Davis-Besse Operational Improvement Plan Operating Cycle 14. Changes from previous commitments in Revision 8 of the Operational Improvement Plan are identified in bold Italics.

COMMITMENTS I. Oraanizational Effectiveness Improvement Initiative I. Improve individual and organizational performance through development and utilization of alignment tools at the DepartmentISection levels

2. Implement FENOC Business Practices for:

a)

Focused Self-Assessments b)

Ongoing Self-Assessments c) Benchmarking d) Semi-Annual Collective Significance Self-Assessments

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-0001, Operations Expectations and Standards
6. Implement actions to 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. Re-evaluate 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 Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete December 3 I, 2005 Complete Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Attachment I Page 2 of 8 COMMITMENTS

2. Operations Improvement Initiative I, Implement Operations Improvements:
a. Initiate Operations Leadership Improvements
b. Initiate the 5 year staffing plan
c. Implement improvements to Operations work stations
d. Implement common FENOC Operations work process tools
2. Improve Operator knowledge, skills and abilities through testing, training and mentoring
3. Implement the Operations Improvement Action Plan, including:
a. Strengthening Operating Crews, including assessment of operators, training on procedure use, and improving command and control
b. Strengthening Operating Procedures, including validation of key operating procedures and use of reverse pre-job briefs
c. Strengthening Operations Management, including use of Operations Oversight Managers until no longer needed
d. Strengthening Independent Oversight of Operations
4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations
6. Align Performance Indicators to Conduct of Operations DUE DATE Complete Complete Complete Complete Complete Complete Complete Complete Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 3 of 8 COMMITMENTS DUE DATE

3. Maintenance Improvement Initiative I, Utilize post-job evaluations, operating experience, and lessons Complete learned from rework activities to identify improvements in Maintenance training and standards scheduling, and implementation of critical equipment outages to identify improvements
3. Implement improvements of Maintenance Supervision through C o m p I e t e training and development
4. Implement actions in the Maintenance individual commitment area Complete to establish improved ownership and accountability of Plant materiel condition
5. Perform testing of Maintenance staff knowledge, skills and abilities to identify improvement actions and incorporate into training
2. Perform an assessment of Maintenance effectiveness work planning, Complete Complete
4. Training. Improvement Initiative 1, Implement actions to improve individual and organizational Complete performance and alignment by developing and providing training on design and configuration control to appropriate site staff the standard FENOC Engineering Organization and complete qualification training for incumbent and new engineers
2. Establish engineering positional qualification requirements based on Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Attachment I Page 4 of 8 COMMITMENTS

5. Work Management Imorovement 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
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
3. Outage Performance
a. Forced Outage Schedule template and readiness
b. Mid-Cycle Outage Preparation
c. Clarify expectations and improve contractor performance
d. 14'h Refueling Outage Preparation DUE DATE Complete Complete Periodic through Cycle 14 Complete Complete Complete Complete Complete Complete Complete Complete February 28,2006

Docket Number SO-346 License Number NPF-3 Serial Number 1-1443 Page 5 of 8 COMMITMENTS DUE DATE

6. Engineering Improvement Initiative I. 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 December 3 1,2005
c. Masonry/block 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 Periodic through Cycle 14 Equipment Reliability Program
5. Develop and implement the plan to enhance System Engineering Complete ownership of plant systems in support of Operations
6. Schedule and conduct additional Program Compliance Reviews Complete 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 on-going self-assessments 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
10. Implement electronic accessibility of design basis information and populate with 5 systems I I. 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 Complete Complete Periodic through Cycle 14 Periodic through Cycle 14 Complete Complete Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 6 of 8 COMMITMENTS Engineering, Improvement Initiative (Contd)

13. Re-institute the use of Quarterly System Health Reports and Design
14. Assign a Program Owner for the Problem Solving Process
15. Develop and implement actions necessary to improve the technical Basis Assessment Reports issues problem solving capabilities in the Engineering organization.
7. 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 S. 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
8. Perform an effectiveness assessment of the corrective actions taken in response to the November 2003 SCWE survey results
8. Procedure Improvement Initiative I. 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 DUE DATE Complete Complete Complete Periodic through Cycle 14 December 3 1,2005 Complete Complete Complete 2004 Complete 41h Quarter 2005 2004 Complete qLh Quarter 2005 Complete Periodic through Cycle 14 Complete Complete Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 7 of 8 COMMITMENTS

9. Corrective Action Program Improvement Initiative
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. Qualify 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
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 DUE DATE Complete Complete Complete Complete Complete Complete Periodic through Cycle 14 Complete Complete Complete Complete

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 8 of 8 COMMITMENTS

10. Internal and External Oversight Improvement Initiative I. 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
7. Perform Quality Oversight of Engineering using the Continuous Assessment Process
8. 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 Complete Complete Complete Complete Periodic through Cycle 14 Periodic through Cycle 14

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 1 of 1 M-04 M-07 M-08 0-01.1 Various CYCLE 14 OPERATIONAL IMPROVEMENT PLAN REVISION 9 CHANGES Effectiveness of Safety Conscious Work Environment Review Team (SCWERT) in Avoiding Discrimination Claims - SCWERT Non-Concurrence Ratio Talent Management and Personnel Development Leadership Development Field Activity Assessments: Field Observations TITLE NUMBER Condition Report Self-Identified Rate CHANGE Change goal from 2 90% of Condition Reports self-identified to 2 80% of Condition Reports self-identified Change goal from 10% to 25%.

Change title to Talent Management &

Update status to show completed actions

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Page 1 of I CHANGES TO BARRIER A'ITRIBUTE PERFORMANCE INDICATORS OPERATIONAL IMPROVEMENT PLAN OPERATING CYCLE 14, REV. 9 PI NUMBER M-02 M-03 M-04.1 M-04.2 TITLE 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 - SCWERT Non-Concurrence Ratio Effectiveness of Safety Conscious Work Environment Review Team (SCWERT) in Avoiding Discrimination Claims - NRC Retaliation Allegation Ratio CHANGE Change to a four-quarter rolling average.

Change to a four-quarter rolling average.

Change to a four-quarter rolling average.

Change to a four-quarter rolling average.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1443 Enclosure Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14 Revision 9 October 21, 2005 (34 pages to follow)

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Table of Contents Introduction...........................................................................................

2 Barriers To Ensure Nuclear Safety.......................................................

3 Davis-Besse Improvement Initiatives....................................................

6 Improvement Initiative Key Actions......................................................

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

24

. Individual 25

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

28

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

29

. Oversight 31 Page 1 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Introduction To ensure continued improvements and sustained performance in Nuclear Safety and Plant Operation at the Davis-Besse Nuclear Power Station, the Leadership Team has developed this Improvement Plan to focus on key improvement initiatives and safety 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 131h Refueling Outage. During the extended outage, numerous improvements were made in the areas of Safety Culture, Management, Human Performance, System Health and Programs as described in the Return to Service Plan and the Building Block Plans. However, additional improvements are required to achieve world class performance and to ensure that the safety bamers that failed to detect the significant RPV Head degradation are maintained to prevent a recurrence of an event in the future.

As described in the Return to Service Plan, the numerous root causes associated with the Reactor Pressure Vessel Head degradation could be grouped into the areas of Nuclear Safety Culture; Management/Personnel Development; Standards and Decision-making; Oversight and Assessments; and ProgramsKorrective ActionsiProcedure Compliance. Actions described in each of the Building Blocks were designed to address numerous significant improvements in each of those areas. This transition plan of Operational Improvements focuses on the four primary safety bamers of Individual, Programs, Management, and Oversight (as described in the following pages) to ensure improvements realized during the extended outage remain in place and are further built upon to improve performance in the future. This plan will ensure that the improvements made to Davis-Besse are built to last.

This plan will be used by the Davis-Besse Leadership Team on a monthly basis to monitor safety barrier attributes that would provide early detection of declining trends in performance and to focus on major initiatives to achieve operational excellence. This plan is a living document and will be periodically updated and revised to address completed actions and add new initiatives as determined and approved by the Senior Leadership Team.

Page 2 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Barriers To Ensure Nuclear Safe0 The safety of nuclear power relies heavily on the "defense in depth" concept. Nuclear power plants are designed with robust systems and redundant back-up safety systems in the unlikely event of a failure. However, systems and equipment must still be operated, maintained and designed by people to ensure reliability and availability if called upon to perform an intended safety function. The first barrier to ensure safety is the Individual. The operator, maintenance technician, engineer and all the other support personnel play an integral role in monitoring plant status and maintaining systems and equipment in top-notch condition. Thus, ensuring that the individuals that support nuclear power plant operation are highly qualified, trained and motivated to do the best job possible is an essential bamer 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 bamer 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 identify differences from industry norms for early detection of potential weaknesses developing in the safety bamers.

Together these four bamers work in conjunction to contribute to the safe operation of Davis-Besse.

Page 3 of 33 Revision 9

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

Davis-Besse Initiatives Sponsor M. Bezilla B. Allen B. Allen B. Allen B. Allen S. Loehlein M. Bezilla M. Bezilla M. Bezilla J. Rinckel

1.

Organizational Effectiveness Improvement

2.

Operations Improvement

3.

Maintenance Improvement

4.

Training Improvement

5.

Work Management Improvement

6.

Engineering Improvement

7.

Continuous Safety Culture Improvement

8.

Procedure Improvement

9.

Corrective Action Program Improvement IO. Internal and External Oversight Improvement Barriers Enhanced Page 6 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Organizational Effectiveness Improvement Initiative DESIRED OUTCOME: Improved Human Performance, Leadership and Team Alignment through Critical Self-assessments, Use of Operating Experience, Industry Benchmarking and Communications Key Actions 1. Improve individual and organizational performance through development and utilization of alignment tools at the DepartmenVSection levels a) Focused Self-Assessments b) Ongoing Self-Assessments c) Benchmarking d) Semi-Annual Collective Significance Self-Assessments
2. Implement FENOC Business Practices for:

I (Included in Focused Self-Assessment Business Practice)

3. Directors and Managers to attend a Leadership Academy
4. Provide formal Management Observation Skills Training to improve management skills Owner M. Trump L. Dohrmann D. Haskins J. Reddinaton ponsor: M. Berill, Completion Complete Complete Complete Complete Complete Complete ComDlete Page 7 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

1. Organizational Effectiveness Improvement Initiative continued Key Actions
5. Enhance the Management Observation Program by ensuring personnel providing oversight monitoring are familiar with DBBP-OPS-0001, Operations Expectations and Standards
6. Implement actions to 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. Re-evaluate 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 I/

Owner K. Fehr K. Fehr D. Haskins D. Haskins D. Haskins M. Lark-Landis iponsor: M. Berilla Completion Complete Complete Complete 4h Qtr 2005 Complete through Cycle 14 Page 8 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Key Actions Owner I Completion

1. Implement Operations improvements:
a. Initiate Operations Leadership Improvements Page 9 of 33 Revision 9 K. Ostrowski Complete
b. initiate the 5 year staffing plan

, K. Ostrowski

c. implement improvements to Operations work stations 1

D. lmlay I

Complete Complete

2. Improve Operator knowledge, skills and abilities through testing, training and mentoring M. Trump Complete

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

4. Strengthen Communications within Operations
5. Benchmark Conduct of Operations
6. Align Performance Indicators to Conduct of Operations
2. Operations Improvement Initiative continued 7-K. Ostrowski K. Ostrowski K. Ostrowski II Key Actions Owner

<. Ostrowski 2onsor: B. Allen Completion Complete Complete Complete Comdete Page 10 of 33 Revision 9

Davis-Besse Nuclear Power Station Key Actions

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

,2. Perform an assessment of Maintenance effectiveness in work planning, scheduling, and implementation of critical equipment outages to identify 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 Operational Improvement Plan Cycle 14 Owner Completion M. Stevens Complete M. Stevens Complete M. Stevens Complete M. Stevens Complete Page 11 of 33 Revision 9

Davis-Besse Nuclear Power Station Key Actions Owner Operational Improvement Plan Cycle 14 Completion

5. Perform testing of Maintenance staff knowledge, skills and abilities to identify improvement actions and incorporate into training
a. Perform skill and knowledge testing to identify areas for
b. Incorporate any identified training needs into training improvement material M. Trump Complete Complete Page 12of33 Revision 9

Davis-Besse Nuclear Power Station Key Actions Owner Operational Improvement Plan Cycle 14 Completion 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 M. Trump M. Trump Complete Complete Page 13 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

5. Work Management Imp rove men t I nit i at ive DESIRED OUTCOME: Provide for the effective and efficient cross-organizational utiliza tion of resources in achieving a high standard of plant materiel condition by conducting the right work at the right time for the right reasons Sponsor: 6. Aller Key Actions I. 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 Work Week 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 W. Mugge Completion Complete Complete through Cycle 1L Complete Complete Page 14 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Key Actions

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
3. Outage Performance
2. Maintenance Backlog Reduction I
5. Work Management Improvement Initiative continued
c. Clarify expectations and improve contractor performance
d. 1 4'h Refueling Outage Preparation Owner W. Mugge C. Hawley W. Bentley Complete Complete Complete Complete Complete Complete 2/28/06 Page 15 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Eng i nee ri ng I m proveme n t I n it iat ive DESIRED OUTCOME: Improved quality of Engineering products, increased access to Design Basis information, and continued improvement in Safe& Margins of the Station Key Actions I. 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
1. Enhance plant equipment performance through the FENOC Equipment Re1 ia bi I i ty Program
5. Develop and implement the plan to enhance System Engineering ownership of plant systems in support of Operations S

Owner J. Grabnar B. Boles J. Grabnar R Hovland B. Boles onsor: S. Loehlein Completion Complete through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 through Cycle 14 Complete Page 16 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. En g i nee r i n g I m prove men t I n it i at ive continued I I Key Actions
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 on-going self-assessments 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
10. Implement electronic accessibility of design basis information and populate with 5 systems Owner R Hovland J. Grabnar R Hovland C. Price J. Grabnar lonsor: S. Loehleir Completion Complete Complete through Cycle 14 through Cycle 14 Complete Page 17 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative continued

~

Key Actions

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 Design Basis Assessment Reports
13. Re-institute the use of Quarterly System Health Reports and
14. Assign a Program Owner for the Problem Solving Process
15. Develop and implement actions necessary to improve the technical issues problem solving capabilities in the Engineering organization.

S Owner J. Powers J. Grabnar B. Boles J. Grabnar B. Boles C. Hawley msor: S. Loehlein Completion Complete Complete Complete Complete Complete Page18of33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

7. Continuous Safety Culture Improvement Initiative DESIRED OUTCOME: Demonstrate a continuously improving Safety Culture at the Davis-Besse Nuclear Power Station Key Actions
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
4. Provide SCWE training to Site employees who have not II 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
8. Perform an effectiveness assessment of the corrective actions taken in response to the November 2003 SCWE survey results Owner C. Price D. Haskins C. Price L. Griffith M. Trump R. Hruby R. Amidon R. Hansen iponsor: M. Bezilla Completion through Cycle 14 4'h Qtr 2005 Complete Complete Complete 2004 Complete 4'h Qtr 2005 2004 Complete 4'h Qtr 2005 Complete Page 19 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

8. Procedure Improvement Initiative DESIRED OUTCOME: Improved procedure use and adherence and standardized procedure change process Key Actions
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 Owner M. Trump L. Dohrmann J. Reddington M. Trump Sponsor: M. Berilla Completion through Cycle 14 Complete Complete Complete Page 20 of 33 Revision 9

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

9. Corrective Action Program Improvement Initiative DESIRED OUTCOME:

Improved effectiveness and implementation of the Corrective Action Program demonstrated through improved Station through Cycle 14 performance II Key Actions

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. Qualify 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 iponsor: M. Bezilk Completion Complete Complete Complete Complete Complete Complete Page 21 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

9. Corrective Act ion Program Imp rove men t I n it ia t ive continued Key Actions
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 Owner L. Dohrmann C. Price L. Dohrmann L. Dohrmann Sponsor: M. Berilla Completion Complete Complete Complete Complete Page 22 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle I 4 Oversight Improvement Initiative DESIRED OUTCOME:

Oversight activities are provided to ensure improved Station performance and the integrity of the Safety Barriers are sustained at the highest levels Key Actions

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 ImDrovement Initiatives Owner S. Loehlein K. Ostrowski S. Loehlein S. Loehlein L. Myers M. Bezilla onsor: R. Hansen Completion Complete Complete Complete Complete Complete Complete Page23of33 Revision 9

Davis-Besse Nuclear Power Station Owner R. Hruby R. Hruby Operational Improvement Plan Cycle 14 Completion through Cycle 14 through Cycle 14

10. Internal and External Oversight Improvement Initiative continued Key Actions
7. Perform Quality Oversight of Engineering using the Continuous Assessment Process
8. Conduct assessment activities of the Corrective Action Program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation Page 24 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Sufetv Burrier 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 monitoring each attribute. Some attributes will be monitored by periodic assessments such as surveys or self-assessments to determine if the goal for that attribute is being met. Monitoring sources for the performance indicators referenced in the Barrier Attributes are identified in the table below:

&.f Performance Indicator Monitoring Sources OIP MPR FENOC Monthly Performance Report SHAR SCWE Health Assessment Report Operational Improvement Plan Performance Indicator Reuort Page 25 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item 1-01

~

~

1-02

~

1-03

~

1-04 1-05

~

~

1-06 1-07 Attribute Human Performance Success Days (Event Free Clock)

OSHA Recordable Injuries (Industrial Safety Performance)

Radiation Protection Events Individual Error Rate Employee willingness to raise concerns Operator Work Arounds Control Room Deficiencies Individual Barrier Attributes Owner

> 40 days on average

< 4 OSHA Recordable Injuries per year

< 2 events in any 4 consecutive quarters

< 0.36 individual errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />

> 90% of individuals are willing to raise concerns to their supervisors or the Employee Concerns Program Level 1:

Level 1 Work Arounds goal in accordance with FENOC Monthly Performance Indicator AND Level 2:

Provide Operations with reliable equipment and system controls to operate the station.

Minimize Operations Level 2 Work Arounds to 11 and prioritize to be worked through the Work Management process.

Control Room Deficiencies goal in accordance with FENOC Monthly Performance Indicator Trump Trump Harder Trump Amidon Ostrowski Ostrowski PI D-SPO-02 1-03 D-HP-01 SCWE Annual Survey 1-06.1 D-EMC-10 1-06.2 Lllonitorin!

Source MPR MPR OIP MPR OIP MPR OIP D-EMC-09 MPR Page 26 of 33 Revision 9

Davis-Besse Nuclear Power Station Item

~

1-08 1-09

~

~

1-10

~

1-1 1 Operational Improvement Plan Cycle 14 Attribute Condition Report Self-Identified Rate Risk Performance Indicator (indicator of Cross-functional teamwork)

Condition Report SRO Review (SRO reviews for Operability are performed in a timely manner)

Employee willingness to use the Corrective Action Program Individual Barrier Attributes Goal 80% of Condition Reports are self-identified 75 Risk Assessment Indicator 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 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 /> 95% of SRO review required Condition 5 5% of individuals are not willing to use the Corrective Action Program Owner Price Ostrowski Ostrowski Amidon Pi Reference 1-08 D-SPO-01 1-10 SCWE Survey and Annual Safety Culture Assessment Ylonitorin Source OIP MPR OIP OIP Page 27 of 33 Revision 9

Davis-Besse Nuclear Power Station Item 1-12 1-13 Operational Improvement Plan Cycle 14 I

Attribute Goal Worker confidence in raising safety concerns Training Programs meet industry standards and effectively improve station performance as

> 90% of workers believe they can raise nuclear safety or quality concerns without fear of retaliation 2 2.5 Training Program Performance Indicator I

Individual Barrier Attributes 1-14 TR-1501 Licensed Operator Requalification Training Requalification Training Program

> 95% pass rate in the Licensed Operator Owner Amidon Trump Trump Monitoring SCW ElNQA Surveys Page28of33 Revision 9

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

~

P-01

~

P-02 P-03

~

P-04

~

P-05

~

P-06

~

P-07 P-08

~

Attribute Corrective Action Program (Effectiveness of Corrective Action Program)

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 Goal

> 8 Corrective Action Program Index Rating

> 90% CR category accuracy rate

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

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

< 0.36 Program and Process Errors per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked

< 1.O% rework 0 PMs past their late or defer to date

< 10% of PMs closed beyond 60% of the allowed grace period AND Owner Price Price Price Hovland Hovland Trump Dominy PI Reference D-SPO-05 P-02 P-03 P-04 P-05 D-HP-02 Maintenance Rework PI P-08 Source MPR OIP OIP OIP OIP MPR

~

OIP OIP Page 29 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

~

tern VI-01 VI-02

~

M-03 111-04 M-05 Attribute 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 Field Observations are self critical Manaaement Barrier Attributes Goal

< 1.O score based on a (as measured by the Engineering Assessment Board)

> 75% of employees that use the Employee Concerns Program report being satisfied with the process c 2 times the industry average of NRC allegations

< 25% SCWERT Non-Concurrence Ratio

< 2 times the industry average of NRC retaliation allegations AND

> 80% of the management field observations performed are self-critical Owner Grabnar Amidon Amidon Schrauder D. Haskins PI I Monitoring Reference Source SCWE 3-4 SHPiR SCWE 1-2 SCWE 4-5 SCWE 1-3 Annual Safety 1 OIP Culture Assessment, NQA Field Observations and Management Observations Page 30 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item M-06

~

M-07

~

M-08

~

M-09

~

M-I 0

~

M-I 1 Effectiveness of Management and Supervisors Talent Management and LeadershiplPersonnel Development Leadership Development (Deleted. Incorporated into PI M-07)

Reactivity Management Fuel Reliability Maintenance Order Backlog Manaaement Barrier Attributes Owner Managers and supervisors are generally effective with a few exceptions Goal in accordance with FENOC Performance Indicator NIA 5 1 Level 2 Reactivity Management Event per year

&NJ 0 Level 1 Reactivity Management Events per year.

Zero fuel defects w:

< 50 Corrective Maintenance Orders

&NJ

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

< 250 Corrective/Elective Maintenance Orders Price D. Haskins D. Haskins Ostrowski Wilson PI Reference XD-PDE-05 (Management Commitment Area Only)

F-PDE-01 (Semi-Annual)

F-PDE-01 D-SPO-I 0 D-SPO-07 M-11.1 M-11.2 M-11.3 Monitoring Source MPR MPR

~

MPR MPR MPR OIP OIP OIP Page 31 of 33 Revision 9

Davis-Besse Nuclear Power Station

< 5 during the Operating Cycle And 0 related to equipment and design deficiencies after restart from major outages Operational Improvement Plan Hovland Cycle 14 Manaaement Barrier Attributes Item M-12 Attribute Number of Temporary Modifications Goal I

Owner Monitoring Source Reference Page 32 of 33 Revision 9

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Responsiveness to QA Identified Issues Condition Report NQA Review Timeliness Corrective Action NQA Verification Timeliness Timeliness of NQA Audit Report Issuance Use of Industry Peer support 0-01

~

0-02

~

0-03

~

0-04

~

0-05

~

0-06 Line organization response to Davis-Besse Oversight-initiated Condition Reports is within 90% - 110% of the average time required for the line organization to respond to all Condition Reports.

100% of Condition Report Investigations reviewed by NQA are accepted or rejected within 14 days after the investigation was complete 100% of Corrective Actions verified or rejected by NQA within 30 days c 25 working days from the end of the quarter 100% utilization of the scheduled INPO Assist Visits for 2004 Oversiaht Barrier Attributes Owner Attribute I

Goal Field Activity Assessments Completion of Primary Elements:

Deferral of 5 1 Primary Element monthly Hruby Hruby Hruby Hruby Hruby Donnellon PI Reference 0-01 DB-02 DB-03 DB-04 DB-05 Semi-Annual Assessment klonitoring Source OIP OIP OIP

~

OIP OIP OIP Page 33 of 33 Revision 9

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