ML061800258

Closure of Davis-Besse Operational Improvement Plan

ML061800258
Person / Time
Site:	Davis Besse
Issue date:	06/27/2006
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Caldwell J Region 3 Administrator
References
1-1460
Download: ML061800258 (38)

Text

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FirstEnsrgy Nuclear Operating Company 5501 Norlh Stale Roule 2 Oak Harbor Ohio 43449 Mark E. Wl!4 Vice President - Nuclear 419-321-7676 Fax: 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1460 June 27, 2006 Mr. James L. Caldwell Regional Administrator, Region 111 U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352

Subject:

Closure of the Davis-Besse Nuclear Power Station Operational Improvement Plan for Operating Cycle 14 and the Integrated Report to Support Restart -

Appendix A Commitments for Cycle 14

Dear Mr. Caldwell:

Under letter (Serial Number 1-1336) dated November 23, 2003, FirstEnergy Nuclear Operating Company (FENOC) submitted the Integrated Report to Support Restart of the Davis-Besse Nuclear Power Station (DBNPS). This report provided an overall discussion of the DBNPS restart activities from the Thirteenth Refueling Outage, including plans established to achieve and sustain long-term improvement in performance at the DBNPS.

Appendix A of the report listed the post-restart actions committed to by the DBNPS in the report. These commitments pertained to Operating Cycle 14. The Operational Improvement Plan (OIP) for Operating Cycle 14 was included as Appendix D to the report. The OIP was developed to ensure continued improvements and sustained performance in nuclear safety and plant operation and to provide a managed transition to normal plant operations and refueling outages. DBNPS letter Serial Number 3026, dated February 6,2004, was submitted to the NRC, which contained additional Cycle 14 actions and clarified that the Cycle 14 time period included the Fourteenth Reheling Outage (l4RFO). During Cycle 14, FENOC staff periodically provided the status of OIP initiatives to the Nuclear Regulatory Commission staff.

The completion of the Fourteenth Refueling Outage (14RFO) marks the closure of the initiatives outlined in the OIP for Operating Cycle 14 and the completion of the commitments in Appendix A of the Integrated Report to Support Restart and its supplement. Revision I O of the OIP documents the final status of the OIP initiatives and is enclosed with this letter.

RECEIVE0 JUN 2 92006

Docket Number 50-346 License Number NPF-3 Serial Number 1-1460 Page 2 of 2 If you have any questions or require further information, r._ase contact Mr. Clark A.

Price, Manager-Regulatory Compliance, at (419) 321-8585.

LJS Attachment Y

Enclosure cc:

USNRC Document Control Desk NRC Branch Chief, Region I11 DB-1 NRC/NRR Project Manager DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1-1460, Page 1 of 1 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.

COMMITMENTS None DUE DATE N/A

Docket Number 50-346 License Number NPF-3 Serial Number 1-1 460 Enclosure Operational Improvement Plan for Cycle 14 Revision 10 (34 pages follow)

Davis-Besse Nuclear Power Station

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Operational improvement Plan Cycle 14 Table of Contents Paze Introduction...........................................................................................

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

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

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

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

25

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

26

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

29

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

30

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

33 Page 1 of 33 Revision 10

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 (DBNPS), the Leadership Team 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 provided 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 13th 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 Retum to Service Plan and the Building Block Plans. However, additional improvements were required to achieve world class performance and to ensure that the safety barriers that failed to detect the significant RPV Head degradation were 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 he grouped into the areas of Nuclear Safety Culture; ManagementTersonnel Development; Standards and Decision-making; Oversight and Assessments; and Programs/Corrective 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 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 ensured that the improvements made to Davis-Besse are built to last.

This plan was 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 was a living document periodically updated and revised to address completed actions, added new initiatives as determined, and was approved by the Senior Leadership Team.

Revision 10 of this Plan documents the final status of the OIP initiatives and safety barrier attributes. Going forward, the DBNPS-level plans in support of the FENOC Business and Excellence Plan are designed to drive continuous improvement at the DBNPS.

Page 2 of 33 Revision 10

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 first bamer 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 bamers.

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

Page 3 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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M. Bezilla

1.

Organizational Effectiveness Improvement B. Allen

2.

Operations Improvement B. Allen

3.

Maintenance Improvement B. Allen

4.

Training Improvement B. Allen

5. Work Management Improvement S. Loehlein

6.

Engineering Improvement M. Bezilla

7.

Continuous Safety Culture Improvement M. Bezilla

8.

Procedure Improvement M. Bezilla

9.

Corrective Action Program Improvement I

J. Rinckel

10. Internal and External Oversight Improvement 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.

Davis-Besse Initiatives Sponsor Barriers Enhanced r

9 -

X X

X X

X X

X X

X -

i Page 6 of 33 Revision 10

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

1. Organizational Effectiveness Improvement Initiative Complete 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 DepartmentISection levels a) Focused Self-Assessments b) Ongoing Self-Assessments c) Benchmarking d) Semi-Annual Collective Significance Self-Assessments

2. Implement FENOC Business Practices for:

(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 ponsor: M. Barilla Completion Complete Complete Complete Complete Complete Complete Page I of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 I. Organizational Effectiveness Improvement Initiative continued II 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 I O. 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 iponsor: M. Bezilla Completion Complete Complete Complete Complete Complete Complete Page 8 of 33 Revision 10

Davis-Besse Nuclear Power Station Key Actions

1. 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

2. Improve Operator knowledge, skills and abilities through I

tools testing, training and mentoring 0 pera t i ona I I m prove men t PI an Cycle 14 Owner K. Ostrowski K. Ostrowski D. lmlay K Ostrowski M. Trump

2. Operations Improvement Initiative DESIRED OUTCOME: Establish the clear leadership role of Operations through improved Organizational fictiveness and Alignment to the FENOC Processes ponsor: B. Allen Completion Complete Complete Complete Complete Complete Page 9 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

2. Operations Improvement Initiative continued Key Actions

3. Implement the Operations Improvement Implementation 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 Owner K. Ostrowski K. Ostrowski K. Ostrowski K. Ostrowski ponsor: B. Allen Completion Complete Complete Complete Complete Page 10 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

3. Maintenance Improvement Initiative DESIRED OUTCOME: Improved Ownership and Materiel Condition of the Davis-Besse Nuclear Power Station II II 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 Owner M. Stevens M. Stevens M. Stevens M. Stevens lonsor: B. Allen Completion Complete Complete Complete Complete Page 11 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

3. Maintenance Improvement Initiative continued Key Actions 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

5. Perform testing of Maintenance staff knowledge, skills and improvement material I

4 Owner M. Trump Completion Page 12 of 33 Revision 10

Davis-Besse Nuclear Power Station Key Actions

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 Opera t i ona I I m prove men t Plan Cycle 14 Owner M. Trump M. Trump

4. Training Improvement Initiative DESIRED OUTCOME: /mproved Individual And Organizational Performance through 3onsor: B. Allen Completion Complete Complete Page130f33 Revision 10

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

1. Common Process

5. Work Management Improvement Initiative DESIRED OUTCOME: Provide for the effiective and efficient cross-organizational utilization of resources in achieving a high standard of plant materiel condition by conducting the right work at the right time for the right reasons Owner Completion W. Mugge Complete training and mentoring to support the effective transition into the FENOC Work Management Process Resolve gaps in process implementation and station procedures Perform quarterly assessments of Condition Reports and Work Week critiques to ensure opportunities for improvement are addressed Implement Risk Management process to improve station knowledge and awareness Monitor and immove Order aualitv

b.

C.

d.

Complete Complete Complete Complete ComDlete

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

5. Work Management Improvement Initiative continued 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

a. Forced Outage Schedule template and readiness

b. Mid-Cycle Outage Preparation

c. Clarify expectations and improve contractor performance

d. 1 4'h Refueling Outage Preparation Owner W. Mugge W. Mugge W. Bentley C. Hawley W. Bentley Sponsor: B. Alien Completion Complete Complete Complete Complete Complete Complete Complete Page 15 of33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative DESIRED OUTCOME: Improved quality of Engineering products, increased access to Design Basis information, and continued improvement in Sakty Margins of the Station Key Actions

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 S

Owner J. Grabnar B. Boles J. Grabnar R Hovland B. Boles msor: S. Loehlein Completion Complete Complete Complete Complete Complete Complete Complete Complete Page 16 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. E ng i nee ri ng I m prove men t In it iat ive continued 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 I O. Implement electronic accessibility of design basis information and populate with 5 systems Owner R Hovland J. Grabnar R Hovland C. Price J. Grabnar onsor: S. Loehlein Completion Complete Complete Complete Complete Complete

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

6. Engineering Improvement Initiative continued S

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

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 implement actions necessary to improve the technical issues problem solving capabilities in the Engineering organization.

Owner J. Powers J. Grabnar B. Boles J. Grabnar B. Boles C. Hawley msor: S. Loehlein Completion Complete Complete Complete Complete Complete Page 18 of 33 Revision 10

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

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 ponsor: M. Bezillr Completion Complete Complete Complete Complete Complete 2004 Complete 2005 Complete 2004 Complete 2005 Complete Complete Page 19 of 33 Revision 10

Davis-Besse Nuclear Power Station 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 1

preparation and revisions

3. Provide training on procedure use and adherence

14. Perform follow-up effectiveness reviews on procedure 1

use and adherence

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Operational Improvement Plan Cycle 14 Owner M. Trump L. Dohrmann J. Reddington M. Trump

8. Procedure Improvement Initiative DESIRED OUTCOME: Improved procedure use and adherence and standardized Completion Complete Complete Complete Complete procedure change process II Page 20 of 33 Revision 10

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

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

1. Implement the Apparent Cause Improvement Plan:

9. Corrective Action Program Improvement Initiative DESIRED OUTCOME:

Improved efictiveness and implementation of the Corrective Action Program demonstrated through improved Station Owner L. Dohrmann L. Dohrmann Managers J. Reddington J. Reddington L. Dohrmann J. Rinckel iponsor: M. Bezilla Completion Complete Complete Complete Complete Complete Complete Complete Page 21 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Owner L. Dohrmann C. Price L. Dohrmann L. Dohrmann

9. Corrective Action Program Improvement Initiative continued Completion Complete Complete Complete Complete 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 Page 22 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14

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10. Internal and External Oversight Improvement Initiative DESIRED OUTCOME:

Oversight activities am provided to ensure improved Station petformance and the integrity of the Safety Barriers am 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 Improvement Initiatives Sponsor:

R. Hansen Owner I Completion S. Loehlein K. Ostrowski S. Loehlein S. Loehlein L. Myers M. Bezilla Complete Complete Complete Complete Complete Complete I

Page 23 of 33 Revision 10

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

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 R. Hruby R. Hruby

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I O. Internal and External Oversight Improvement Initiative continued Completion Complete Complete Page24of33 Revision 10

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 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:

Performance Indicator Monitoring Sources O P MPR FENOC Monthly Performance Report SHAR SCWE Health Assessment Report Operational Improvement Plan Performance Indicator Report Page 25 of 33 Revision 10

Davis-Besse Nuclear Power Station 1-06.1 1-06.2 Operational Improvement Plan Cycle 14 OIP Item 1-01

~

1-02 1-03

~

1-04 1-05

~

1-06 1-07 Attribute iuman Performance Success Days

Event Free Clock) 3SHA 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 Goal

> 40 days on average

< 4 OSHA Recordable Injuries per year e 2 events in any 4 consecutive quarters e 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 Monthlv Performance Indicator Owner Trump Trump Harder Trump Arnidon Ostrowski Ostrowski Monitoring D-SPO-03 D-HP-01 Annual survey D-RPO-16 I MPR D-RPO--15 Page 26 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item 1-08 1-09 1-10 1-1 1

~

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

> 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 Owner Price Ostrowski Ostrowski Amidon PI Reference 1-08 D-SPO-01 1-10 SCWE Survey and Annual Safety Culture Assessment Monitoring Source OIP MPR OIP OIP Page 27 of 33 Revision 10

Davis-Besse Nuclear Power Station Goal

> 90% of workers believe they can raise nuclear safety or quality concerns without fear of Operational improvement Plan Cycle 14 Owner PI Monitoring Amidon SCWUNQA OIP Reference source surveys Item 1

1-13

> 95% pass rate in the Licensed Operator Requalification Training Program 1-14 TNmp 1-1 4 OIP Attribute Worker confidence in raising safety concerns Training Programs meet industry standards and effectively improve station performance as measured by NOBP-TR-1501 Licensed Operator Requalification Training Individual Barrier Attributes Page 28 of 33 Revision 10

Davis-Besse Nuclear Power Station Goal Owner Operational Improvement Plan PI Cycle I 4

> 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 hours worked

< 1.O% rework

< 0.36 Program and Process Errors per 10,000 0 PMs past their late or defer to date AND

< 10% of PMs closed beyond 60% of the allowed grace period Item Price P-02 Price P-03 Hovland P-04 Hovland P-05 Trump D-HP-02 Dominy Maintenance Rework PI Mugge P-08 P-01 P-02 P

~

P-04 P

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 Monitoring Source MPR OIP OIP OIP OIP MPR OIP OIP Page 29 of 33 Revision 10

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item M-01 M-02 M-03 M-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 e 2 times the industry average of NRC allegations e 25% SCWERT Non-Concurrence Ratio AND e 2 times the industry average of NRC retaliation allegations

> 80% of the management field observations performed are self-critical Owner Grabnar Amidon

~

Amidon Schrauder D. Haskins PI Reference M-01 SCWE3-4 SCWE 1-2 SCWE4-5 SCWE 1-3 bnual Safety Culture Assessment, NQA Field Observations and Management Observations Honitoring source OIP SHAR SHAR SHAR SHAR OIP

Davis-Besse Nuclear Power Station Operational Improvement Plan Cycle 14 Item M-06 M-07 M-08 M-09

~

M-10

~

M-I 1 Attribute 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 Mananement Barrier Attributes Goal Managers and supervisors are generally effective with a few exceDtions Goal in accordance with FENOC Performance Indicator N/A

- 1 Level 2 Reactivity Management Event per year AND 0 Level 1 Reactivity Management Events per year.

Zero fuel defects m:

< 50 Corrective Maintenance Orders

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

< 250 Corrective/Elective Maintenance Orders Owner Price D. Haskins D. Haskins Ostrowski Wilson PI Reference D-PPP-04 (Management Commitment Area Only)

F-PPP-01 (Semi-Annual)

F-PDE-02 D-SPO-06 D-RPO-08 M-11.1 M-I 1.2 M-I 1.3 Mo%oring Source MPR MPR MPR MPR MPR OIP OIP OIP Page 31 of 33 Revision 10

Davis-Besse Nuclear Power Station Goal Owner PI Reference c 5 during the Operating Cycle Hovland M-12 0 related to equipment and design deficiencies after restart from major outages Operational Improvement Plan Cycle 14 Monitoring Source OIP M-12 Attribute Number of Temporary Modifications Page 32 of 33 Revision 10

Davis-Besse Nuclear Power Station Goal Completion of Primary Elements:

Line organization response to Davis-Besse Deferral of 5 1 Primary Element monthly Oversight-initiated Condition Reports is within 90% - 110% of the average time required for the line organization to respond to all Condition Reports.

reviewed by NQA are accepted or rejected within 14 days after the investigation was complete 100% of Corrective Actions verified or rejected 100% of Condition Report Investigations Operational Improvement Plan Cycle 14 Owner PI Monitoring Reference Source Hruby 0-01 OIP Hruby DB-02 OIP Hruby DB-03 OIP Hruby DB-04 OIP Item

< 25 working days from the end of the quarter 0-01 0-02 0-03

~

0-04 0-05 0-06

~

Hruby DB-05 OIP Attribute 100% utilization of the scheduled INPO Assist Visits for 2004 Field Activity Assessments Responsiveness to QA Identified Issues Donnellon Semi-OIP Annual Assessment Condition Report NQA Review Timeliness Corrective Action NQA Verification Timeliness Timeliness of NQA Audit Report Issuance Use of Industry Peer support Page 33 of 33 Revision 10