ML20149H899

CPS Long Term Improvement Plan

ML20149H899
Person / Time
Site:	Clinton
Issue date:	06/30/1997
From:	ILLINOIS POWER CO.
To:
Shared Package
ML20149H046	List: ML20149H899 U-602781, Forwards CPS long-term Improvement Plan.Elements for Improvements in Areas of Sys,Programs & Organizations & Actions for Implementing Each of Improvement Elements Identified
References
PROC-970630, NUDOCS 9707250234
Download: ML20149H899 (63)

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- 2 Attachment to U-602781

' July 2, 1997 j

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i CLINTON POWER STATION LONG TERM IMPROVEMENT PLAN June 1997 9707250236 970702 DR ADOCK 050 4ji

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TABLE OF CONTENTS i.

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! Section Eggg 1.0 PURPOSE 1

2.0 DESCRIPTION

OF STRATEGIC RECOVERY l l PLAN (SRP) l l' 2.1 Purpose of SRP 1 2.2 Con.ponents of SRP 1 2.3 Results of Restart Readiness Reviews 2 2.4 . Long Term Improvement Plan and Performance 2 Measures 3.0 PROCESS OF DEVELOPMENT OF THE LONG 2 ,

TERM IMPROVEMENT PLAN (LTIP) 3.1 Turn-Around Team 3 3.2 Development ofLTIP Elements 4' 3.2.1 Reviews by the Turn- 4 Around Team 3.2.2 Input from Readiness Reviews 5 3.2.3 Identification ofElements 6 3.2.4 Format for Elements 7 ,

3.3 Line Management Development of 9  !

Implementing Plans for the Actions 3.4 Implementation of Actions by Line Management 9 3.5 Performance Measures 10 3.6 Changes to the Plan 10 l 3.7 Evaluation for AdditionalImprovements 10 3.8 Incorporation of Elements into Business Plan 13 4.0 LONG TERM IMPROVEMENT PLAN ELEMENTS 13 ,

4.1 LTIP Elements for Systems 14 l 4.1.1 Improvements Related to Design and 15 Licensing Basis  !

l 4.1.2 Improvements in Materiel Condition 18 l 4.1.3 Improvements in Work Planning and 21 j l.

l Control

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StGlifLrl East I 4.0 LONG TERM IMPROVEMENT PLAN ELEMENTS l (cont'd)

, 4.2 LTIP Elements for Programs 24 I 4.2.1 Reviews ofPrograms and Procedures 25 4.2.2 Improvements in Assessments and 27 Corrective Actions 4.2.3 Improvements in Other Programs 31 4.3 LTIP Elements for Organizations 35 l

.I 4.3.1 Improvements in Leadership and 36 j i Accountability 4.3.2 Improvements in Human Performance 39 I

APPENDIX I - Identification of How Significant Issues Have Been Addressed by SRP i 1

APPENDIX II - Disposition of Suggestions for Long Term Improvements Identified  !

Through Readiness Reviews l APPENDIX III - Long Term Site Program Reviews i

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June 1997 '_CLINTON POWER STATION (CPS) i LONG TERM IMPROVEMENT PLAN .l 1.0 PURPOSE Following an event at CPS on September 5,1996, the plant was shut down.

Illinois Power (IP) performed assessments of the event and implemented corrective actions. IP also established a Startup Readiness Action Plan (SRAP) to address the issues and root causes arising from the September 5 event. Based upon subsequent assessments by IP and inspections by the Nuclear Regulatory Commission (NRC), and additional event Juring the outage, IP determined that there was a need for a more deliberate and comprehensive approach to ensuring its readiness to restart and achieving long term improvements in performance.

Accordingly, IP developed a Strategic Recovery Plan (SRP), which incorporated .i the SRAP and included a provision to establish a Long Term Improvement Plan (LTIP) to provide sustained improvement in the performance of CPS.

The purpose of this document is to provide the Long Term Improvement Plan required by' the SRP. This LTIP builds upon the many improvements that have ,

already been made since the September 5 event. Section 2.0 of this Plan describes the SRP. Section 3.0 describes the process for development and implementation ofthe LTIP. Section 4.0 describes the elements of the LTIP.

2.0 DESCRIPTION

OF STRATEGIC RECOVERY PLAN (SRP) 2.1 Puroose of SRP The purpose of the SRP is to provide a deliberate and comprehensive approach to ensuring the readiness ofIP to restart CPS and to achieving long term improvements in performance. To ensure that the SRP receives appropriate management focus, IP established a dedicated Turn-Around Team headed by a newly created Assistant to the Vice President of CPS to coordinate implementation of the SRP.

2.2 Components of SRP The SRP provides for the establishment of three primary components:

1) restart readiness reviews; 2) a long term improvement plan; and

3) performance measures. In order to ensure the comprehensiveness of the SRP, each of these three components has elements applicable to the areas of systems, programs, and organizations.

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2.3 . Results of Restart Readiness Reviews

. IP has completed its readiness reviews for restart. Based upon these reviews, IP has determined that the systems, programs, and organizations will be ready for restart upon completion ofidentified actions. This determination is based, in part, upon some of the short-term improvements made as part of the Startup Readiness Action Plan. It is also based upon improvements and corrective actions implemented as a result of the findings of the readiness reviews associated with the SRP.

The results of the readiness reviews also identified a number ofitems to achieve long term improvement. These items are discussed in Section 3.2.

2.4 Long Term Improvement Plan and Performance Measures As discussed in more detail in Section 3.0, IP has developed the Long Term Improvement Plan to address significant issues identified by IP and the NRC in CPS systems, programs, and organizations and to achieve lasting improvements in performance in these areas. To ensure that the plan is implemented in an effective and timely manner, the plan specifies for each improvement action a deliverable product, a schedule, and a responsible manager / owner. Additionally, as discussed in more detailin Section 3.5, IP has developed performance measures to ensure that the readiness reviews and long term improvements are effective in achieving improvements in performance of systems, programs, and organizations.

3.0 PROCESS OF DEVELOPMENT OF THE LONG TERM IMPROVEMENT PLAN (LTIP)

The Long Term Improvement Plan was developed by the Turn-Around Team and line managers. The LTIP identifies elements for improvements in the areas of.

systems, programs, and organizations, and identifies actions for implementing each of the improvement elements. The line managers are responsible for developing implementing plans for each action, and providing deliverables to the CPS Vice  ;

President for his acceptance. Based upon these deliverables, its monitoring activities, and performance measures, the Turn-Around Team will determine whether further improvements are needed. This process is described in more detail in the following sections, and is depicted graphically on F3gure 1.

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Figure 1 LONG TERM IMPROVEMENT PLAN PROCESS 1 Owners Develop issuance of

> Implementing LTIP Plans d

Owners implement v Plans, Perform CPS VP Reviews CPS VP Reviews el -Assessments and Accepts and Accepts  :: <

& Provide implementing Deliverables Deliverables to Plans Team Team Evaluates Ne d for eam Monitom Pedonnance Further Improvement easums, MC Inspedons, and CPS Assessments v

Further

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4 No l Improvements > Done '

Needed?

Yes

, v Further lmprovements identified in Revised LTIP, Business Plan, or Department Plan, as appropriate l

3.1 Turn-Around Team I The Turn-Around Team has coordinated and supported line management in the development of the LTIP, will be coordinating and monitoring implementation of the LTIP, and will be monitoring the plant's performance measures and assessments to determine whether additional improvements are needed.

The Turn-Around Team is headed by the Assistant to the Vice President of CPS. The Team includes a multi-disciplinary group ofindividuals dedicated to development and coordination ofimplementation of the SRP.

The individuals comprising the Team may change over time. Regardless of the Team composition, the Team members shall remain objective.

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.j- .,7 The Team will exist until implementtion of the LTIP is completed, and/or

improved performance has been achieved (i.e., the goals for the elements either have been satisfied or substantial progress has been made in

, satisfying the goals). When improved performance has been established, the Turn-Around Team will be disbanded, and the Assistant to the Vice President will delegate any remaining responsibilities of the Turn-Around Team to a manager.-

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3.2 Development of LTIP Elements In keeping with a focus on materiel condition and human performance, the

} SRP (including the LTIP) covers the areas of systems, programs, and 4 organizations. Within each of thes,: areas, the Turn-Around Team identified various improvement elements. Each element identifies an aspect ,

of the systems, programs, or organizations to be improved. The elements were selected to address significant issues identified by IP, its independent contractors, or the NRC. These elements were identified based upon a .

review of available information and the experience of the Turn-Around

, Team and management, and input from the results of the readiness reviews.

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Each of these is discussed below.

1 3.2.1 Reviews by the Turn-Around Team L

. The Turn-Around Team performed a review ofinformation in  ;

significant IP and NRC inspections, assessments, and root cause determinations, including the following:

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• The Independent Assessment of Clinton Power Station's Nuclear Station Engineering Department (NSED) )

i conducted in November and December,1996. i 4

• The Common Cause and Root Cause Investigation resulting from the September 5,1996, forced shutdown.

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j e The Clinton Power Station Systematic Assessment Report completed in December 1996. This assessment was performed by a team composed of station, contract, and industry personnel with the purpose ofidentifying long-standing issues concerning operation of the Clinton Power l Station. This assessment was performed by selecting site j documentation, both internally and externally generated, and identifying past issues that did not meet generally accepted industry practices.

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. The CPS Cultural Index. The cultural index is a leading indicator of organizational safety performance.

. The preliminary CPS Site Wide Common Cause Analysis by .

l Performance Improvement International (PII) in May 1997. l

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e CPS Independent Corrective Action Process Assessment l (March 28,1997).

l e NRC Special Inspection, NRC Inspection Report i 50-461/96010, concerning the circumstances surroundmg l the September 5,1996, recirculation pump seal package f failure.

. NRC Operational Safety Team Inspection (OSTI), NRC l Inspection Report 50-461/96011, to evaluate Operations )

and Engineering support of CPS operation.  !

l e NRC Escalated Enforcement Actions related to NRC j Inspection Reports 50-461/96012 on Radiation Protection  :

(RP), 96014 on inoperable Emergency Diesel Generator  ;

(EDG),96015, and 97003 and Engineering Technical  !

Support (E&TS).

• NRC's Confirmatory Action Letter (CAL) dated January 9, 1997; NRC's Trending Letter dated January 27,1997; and NRC's Plant Performance Review (PPR) letter dated March 13,1997.

Appendix 1 identifies the significant issues discussed in these reports, and lists the corresponding elements in the LTIP. In some cases, the item has no corresponding element because it was adequately addressed in the SRAP or does not pertain to nuclear safety.

3.2.2 Input from Readiness Reviews As part of the restart readiness reviews, line management prepared Performance Improvement Activity Communication Forms to identify potential actions for inclusion in the Long Term j Improvement Plan. The subjects addressed by these forms are l l l identified on Appendix 2, together with an identification ofwhether )

1 the actions were included in the LTIP. '

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3.2.3 Identification of Elements Based upon the reviews of reports and the input from the restart readiness reviews, the Turn-Around Team identified elements for

improvement. The Team and line management screened these l elements utilizing the Timing Review Criteria in Appendix E of the

• SRP to identify those improvements that needed to be made prior.

to restart, and those elements were implemented as part of the restart readiness reviews. Elements which were screened out (i.e., ,

not required for restart) were designated for inclusion in the Long Term Improvement Plan These elements are summarized below and in Figure 2, and are discussed in detail in Section 4.0.

Systems

a. Improvements related to design and licensing basis.

b. Improvements in materiel condition.

c. Improvements in work planning and control.

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a. Reviews of programs and procedures. l l

b. Improvements in assessments and corrective actions.

c. Improvements in other programs.

Organizations

a. Improvements in leadership and accountability.

b. Improvements in human performance.

Appendix 1 shows how these elements were selected. In particular, Appendix 1 identifies 1) the significant issues raised in the reports reviewed by the Tum-Around Team,2) the relevant short term improvements implemented as part of the SRAP and readiness reviews, and 3) the applicable actions in the LTIP elements. As ,

Appendix 1 demonstrates, essentially all of the significant issues l l identified in the reports reviewed by the Team have corresponding i elements in the LTIP (and often have a corresponding action in the SRAP). Thus, IP is taking comprehensive action to achieve l improvements in performance for the significant issues identified in l these reports.

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i. 3.2.4 Format for Elements l

l For each of the elements, and based upon input from line l

management, the Turn-Around Team developed a description of the actions to be accomplished, and identified the managers / owners responsible for these actions. The descriptions of the elements is - {

provided in Section 4.0 below.- 1 In particular, each element of the LTIP consists of the following:

a. Issue that gave rise to the element

b. References related to the issue i

c. Status ofimprovements that have already been j implemented j

d. Purpose of additionalimprovements I

e. Goals for the improvement element .)

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f. Assessments to evaluate achievement of the goals

g. Actions to achieve improvement

h. Deliverables produced by the action

i. Manager or Owner responsible for the actions ,

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j. Schedules for producing the deliverables

In selecting actions for each element, the following criteria were used

1) the action should be a significant contributor to I accomplishment of the purpose of the element; 2) the action should l not be narrowly focused on one organization or group, but instead I should contribute to overall CPS improvement in performance  !

(even though the action may be confined within one organization),

L 3) the action should involve substantial expenditures of resources; i l and 4) the actions should represent a new activity and should not be i

part of a normal or ongoing activity at CPS. Additionally, the total ,

number of elements and actions was limited in order to ensure that ]

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Long-Term improvement Plan Elements I

Materiel Condition Human Performance i

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1. evemente in impsovements a Human Perkumance 3 Malenal Conesmo impsovements in improvements Reuted b Rownws of Programe LeadetenD and Desen and Licessmo Basis and Procedures accouniemiey ,

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Assessments and a Cofractive Accon l .. nts in Omer Pro 0: ems

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Improvements on I Woe Planning and Coat IV

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Event Free Performance 4

, m'enance Tase Pettemmace J runons Crew Momtorme Performance Measurements SALP Rotmos and Assessments Cun frei indes Conetwa Report nameflon Rete Redette Womer Perfosmance 4 Mem Control Room Dencaeacess rett Woe Amundo Team Evalusies Need for b n e M Further improvemonis 9ysism (teseness Meterial DenconciesCMWRs Temporery Moellcellone Maintenance Rule Systems la An a(1) Categmy

+ Total Senecent Open Consnent Control Forme Further improvements Total CPS Proceaste Cheneas Idenshed in Revned LTIP. Pescenteos of Human Poitormance and Techansi i' Suomess Plan, of Comment Connel Forne Deparansni Plan, as Conetum Reports Msocessed weh Pmcodute Vtonsuons appiopreis senacent Coneimo Reports a -----

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management focus and resources are p! aced on accomplishment of the most significant activities for achieving improved performance. Actions I

that were not sufficiently significant to warrant inclusion in the Long Term "f Improvement Plan may be implemented as part of department-level '

improvement plans, the normal corrective action process or subsequent- i improvement plans.  !

1 i- 3.3 Line Managems_nt Development ofImplementing Plans for the Actions J

. The description of the elements in Section 4.0 has been reviewed and approved by the responsible managers / owners. The responsible I

managers / owners will develop detailed plans for implementing their actions, and will submit these plans to the CPS Vice President for review and acceptance. In performing this review, the CPS Vice President may i L use the assistance of the Turn-Around Team. The detailed plans should include milestones, identify necessary resources, and provide for self-

assessments. As necessary, the Turn-Around Team will meet with the responsible managers / owners to discuss and review the rationale for the ,

plans and ask questions regarding the plans. j i

3.4 Implementation of Actions by Line Management

The responsible managers / owners will be responsible for ensuring implementation of the actions. Each responsible manager / owner shall conduct a self-assessment of his actions to verify their quality and

. effectiveness in achieving improved performance.

Following implementation, the responsible managers / owners will provide the deliverables identified in Section 4.0 to the CPS Vice President for his review and acceptance. In performing this review, the CPS Vice President may use the assistance of the Turn-Around Team. As necessary, the Turn-Around Team will meet with the responsible managers / owners to ask

questions regarding the deliverables. j In some cases, the deliverables are plans, procedures, or other documents which identify various activities to be performed. Each responsible  !

mar.ager/ owner shall perform self-assessments to verify the quality of these activities and their effectiveness. Additionally, the Turn-Around Team shall monitor these activities to ensure that they are completed. For continuous or periodic activities, the Turn-Around Team need only a

perfoim sufficient monitoring to assure that the activities have been

. initiated, i

The Turn-Around Team will track impl6 mentation and completion of each element. The Turn-Around Team will also maintain files of the deliverables Page 9

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. associated with each element. Finally, the Turn-Around Team will evaluate the Quality Assurance Department (QA) assessment ofimplementation of the LTIP (see Section 3.7), and assess the adequacy of the responses to QA's findings.

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If the Turn-Around Team is disbanded before completion of

implementation of the LTIP, the Team responsibilities described above will l be delegated to a manager or director designated by the Assistant to the .

Vice President.

3.5 Performance Measures As part of the readiness reviews, the Turn-Around Team facilitated, and l line management developed, performance measures for systems, programs, i and organizations. These performance measures are shown on Table 1 and j described in Appendix A of the SRP.

t- These performance measures are applicable to the Long Tenm 4

Improvement Plan as well as the readiness reviews. As shown on Table 1, a number of these performance measures include long term goals, some of which are more restrictive than the goals for the restart readiness reviews.

The Turn-Around Team will monitor these performance measures to compare performance against the established goals. The Turn-Around Team will also monitor the other performance measures to arrive at an 1 integrated assessment ofimprovement in the areas of systems, programs, and organizations. .;

3.6 Changes to the Plan Based upon further information or evaluation, line management may identify a need to change provisions in this Plan. If so, they should prepare ajustification for a change to the Plan and consult with the Turn-Around Team. Changes to the Plan, as warranted, will then be made by the Turn-Around Team.

3.7 Evaluation for AdditionalImprovements As discussed in Section 3.4, each responsible manager / owner will conduct self-assessments of the quality and effectiveness of his assigned actions.

Additionally, the Turn-Around Team will perfonn periodic evaluations of whether improvements in performance are being achieved, and will report ,

the results to the CPS Vice President. The QA Depanment will also conduct assessments of the quality ofimplementation of the Long Term Improvement Plan and its effectiveness in achieving improved performance.

Finally, as described in each element, an assessment will be performed for Page 10

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. .t the element to determine whether the goals of the element have been achieved.

If a particular goal for an element or a performance measure is not met (or if progress is not being made to meeting the goal), or if the integrated assessment discussed in Section 3.5 does not indicate sufficient improvement, the responsible managers / owners will determine the cause of i

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TABLE 1 Performance Measures E. %

Performance Measure Long Term Goal for Operation Goal Apphcable For Startup Areas

Event Free Performance P2b - 3;; TIE)4M Of - asas 2 21 days O, P, S Culture Index '14 N/A O, P

, Maintenance Task Performance 3.5 3 ' O, P Operations Crew Monitoring 4 3 O, P Main Control Room (MCR) Deficiencies 2< 84 days '< 45 P, S i System Readiness Materiel Deficiencies '< 182 days -  % P, S ,

Tc-.gariof Modifications <8 <8 P, S -

12 Operator Work-Arounds <10 0 P, S 5

Long Term Tagouts e " *

• 4TBDy ~ $2 0 P, S Total Significant Open Comment Control Forms (CCFs) < 125 0 O, P Total CPS Pi&M-c Changes N/A N/A _ _O, P Percentage of Human Performance and Technical CCFs N/A N/A J, P ,

Condition Reports (Associated With Pr&M-, Violations) N/A N/A O, P ..

CR Initiation Rate N/A N/A O Significant CRs '< 180 da3s 'O O, P -

SelfIdentification Rate N/A N/A O, P i Radiation Worker Performance '< 10% < 10% - O, P .[

Maintenance Rule Systems in an a(1) Category N/A N/A S 1 - As indicated from the Site Wide Culture Index 2 - Average Age ofMCR Deficiencies 3 - 45 is the summation of 20 [ outage] and 25 [non-outage] MCR deficiencies t i

4 - No outstanding MWRs identified as Startup Related 5 - Number without a completed safety evaluation f 6 - Average Age of CRs ir M in days >

7 - No remaining CRs identified as Startup Significant prior to unit startup  ;

8 - A measure of minor Radiological Problems / Field Obsen ations in perant (%) ,

9 - Average age of Non Outage Corrective MWRs .

10 "O" = Operations; "P" = Programs; "S" = Systems 11 - No outstanding procedure revisions required for startup 12 - No Workarounds that affect safe operation ,

.f ITEMS 'HIGHLIGiffED' REQUIRE FURTHER INPUT!

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the lag in performance improvement. Based upon the cause, the Turn- . '

Around Team will coordinate development of an action plan for approval by the CPS Vice President to achieve the desired improvement.

Additionally, the Turn-Around Team will be available to receive feedback l from plant personnel and will monitor NRC inspection reports and QA and other CPS assessments to identify any significant weakness that indicate the -

need for additional improvements, and will recommend a plan of action to the CPS Vice President.

The periodic evaluations by the Turn-Around Team shall continue until the desired improvements identified in the LTIP are achieved.

1 3.8 Incorooration of Elements Into Business Plan CPS issues a Business Plan on an regular basis. Elements of the LTIP which are not completed at the time of the 1998 update will be incorporated into the Business Plan.

I Additionally, any additional recommendations for improvement identified by the Turn-Around Team and accepted by the CPS Vice President will be l 2 incorporated into the Business Plan. These recommendations will be in addition to any provided by line managers and QA.' At that time, the LTIP will be closed, and additional improvements will be controlled through the Business Plan.

I 4.0 - LONG TERM IMPROVEMENT PLAN ELEMENTS

As described above, the Long Term Improvement Plan provides a comprehensive

,- plan for achieving long term improvements in the areas of systems, programs, and

. organizations. The following sections provide a description of each of the LTIP f elements for systems, prograna, and organizations.

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C. ,I 4.1.1 Improvements Related to Design and Licensing Basis l Lgus: NRC has identi6ed signi6 cant discrepancies between the as-built plant and procedures and the Updated Safety Analysis Report (USAR) at some plants, and has provided a two-year enforcement discretion for licensees to identify

- and correct such discrepancies. ' Additionally, some discrepancies have been identified at CPS. As a result, IP has decided to place priority on conducting reviews to determine whether additional discrepancies may exist.

Additionally, weaknesses have been identified at CPS in safety evaluations under 10 CFR 50.59 for changes in the USAR, and in operability evaluations to ensure that degraded and nonconforming components are able to perform their i design and licensing basis safety functions. CPS has already provided training to improve 50.59 safety evaluations, and j has upgraded its operability program to address identified weakness. Additionally, IP has decided to improve its 50.59  :

process and to conduct reviews ofits operability determinations under its upgraded program to verify the effectiveness ]

of the upgrades. ,

References NRC's 50.54(f) letter dated October 9,1996; IP's Response to 50.54(f) letter dated February 12,- 1997; NRC's Trending Letter dated January 27,1997 to IP; NRC's Plant Performance Review (PPR) Letter dated March 13, .[

1997; NRC Inspection Report 50-461/96014 on EDGs; NRC Special Inspection Report 50-461/96010 and NRC OSTI  ;

Inspection Report 50-461/96011; NRC E&TS Inspection Report 50-461/97003; NRC's 6/9/97 letter Proposing

$450,000 Civil Penalty; NRC Inspection Report 50-461/96015 Current Status: As discussed in IP's response to NRC's 50.54(f) letter, IP has already taken extensive actions to ensure that the plant and procedures conform with the design and licensing basis. Additionally, as discussed above, IP has .i upgraded its operability determination procedure and provided training on 10 CFR 50.59. ,

Purpose of Additional Improvements: To provide additional assurance that the plant and procedures conform with the design and licensing basis, thereby providing a sound foundation for future operability determinations, 50.59 safety evaluations, and other configuration controls; to ensure that the improvements to the operability determination procedure have been effective; and to improve the 50.59 process.

Goals- There are no identified discrepancies between the as-built plant and procedures and the Updated Safety Analysis t Report (USAR) that affect operability.

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4.1.1 Improvements Related to Design and Licensing Basis (Cont'd)

Assessment: The Turn-Around Team will review the results of the actions listed below, and will review other rehwant assessments (e.g., LERs, NRC Inspection Reports, Condition Reports) to evaluate whether any USAR discrepancies have been determined to impact operability. Ifyes, the Turn-Around Team will assess the need for further actions.

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4.1.1 Improvements Related to Design and Licensing Basis (Cont'd)

No. Action Deliverable Dae Responsible Date Manager /0wner ,

1 Perform a vertical-slice inspection of a Report ofresults ofvertical-slice Develop a Manager, NSED and Vertical system to assess compliance of the inspection, including an evaluation of plan and Director ofLicensing

• Slice system configuration and procedures any need to perform additional schedule by l

i Inspection with the design and licensing basis. inspections based upon identified 7/31/97 I deficiencies or any adverse trends from this and previous vertical-slice inspections.

2 Assess the accuracy of the Updated Report of the results of the assessment,- 8/31/97 Manager ofNuclear Station USAR Safety Analysis Report (USAR) and including a plan to address identified Engineering Department >

Review Technical Specifications and develop a weaknesses and expand scopeif (NSED) and Director of  ;

plan to address weaknesses identified warranted. Licensing i by this assessment including assessment

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scope expansion ifwarranted. The i

. assessment will review documents such  ;

as; vertical slice inspection report, CRs, self and independent assessment reports and NRC inspection reports.

3 Complete the 50.59 Improvement List ofindividuals who were trained on 9/1/97 Director ofLicensing 50.59 Action Plan. 50.59; lesson plan for 50.59 training;  ;

revisions to procedure 1005.06; response to NSED 50.59 assessment;  ;

and report ofroot cause evaluation of-50.59 problems and plan for additional  !

corrective actions. ,

4 Conduct an assessment ofthe Report ofresults of assessment of 12/31/97 Supervisor, ISEG i Operability operability determinations and operability determinations and Determi- operability evaluations made under the operability evaluations, including any. ,

nations new procedure to ensure conformance recommendations forimprovement ,

with NRC Generic Letter 91-18. ,

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4.1.2 Improvements in Materiel Condition Issue: IP and NRC have identified some long-standmg CPS equipment problems. IP has also identified some degraded components at CPS. Good materiel condition is essential to ensuring safe and reliable operation and to reducing burdens -

on operators. Therefore, IP has decided to take action to improve the materiel condition at CPS by correcting the . ,

degraded components, and monitoring and trending system health, and prioriting work to help ensure that equipment problems are promptly identified and corrected. .

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References:

CPS Readiness Reviews; CPS Common Cause and Root Cause Investigation; NRC Special Inspection.

Report 50-461/96010 and OSTI Inspection Report 50-461/96011; NRC E&TS Inspection Report 50-461/97003; NRC i Trending Letter dated 1/27/97; NRC's PPR Letter dated March 13,1997; NRC's 6/9/97 letter Proposing $450,000 Civil i Penalty  ;

i Current Status: IP has performed startup readmess reviews to venfy the adequacy ofplant systems'to support safe .

operation; has substantially reduced the backlogs ofmain control room deficiencies, operator workarounds, and long- -

term tagouts; and has made improvements in breakers, the Auxilip Power system (degraded voltage protection), j reactor recirculation pump seals, feedwater check valves, and mam control room indicator lights. IP has also established j quarterly reviews by the CPS Vice President, Plant Manager, and Manager ofNSED to assess long term materiel deficiencies and ensure corrective actions are pursued aggressively and operational needs are met. j

Purnose of Additional Imorovements: To make further improvements in materiel condition and system availability; and ,

to enhance IP's capability to monitor and trend system performance in order to identify degradation in system performance and conditions warranting corrective action; and to prioritize work to ensure that adverse conditions are  ;

promptly corrected.

Goals: Backlogs ofwork items are less than specified goals; adverse materiel conditions are identified and corrected ,

l before they cause significant events; and structures, systems, and components satisfy their reliability and availability objectives under the Main +enance Rule.

Page 18

4.1.2 Improvements in Materiel Condition (Cont'd)

Assessments: The Turn-Around Team will determine whether the status of materiel condition performance measures satisfy established goals. If the goals are not satisfied, the Turn-Around Team will assess the need for further actions.

Additionally, the Turn-Around Team will review various assessment reports (e.g., LERs, NRC Inspection Reports, Condition Reports) to evaluate whether materiel conditions are causing plant events, and whether structures, systems, and components are not satisfying their reliability and availability objectives as established under the Maintenance Rule If so, the Turn-Around Team will assess the need for further actions.

Page 19

.~ ~ ~ _-. .. - . . . . - ...-. - - . - - . - .-. . . - - . .-- . .- - - .. . . ~ . . . . - -

4.1.2 Improvements in Materiel Condition (Cont'd) ,

No. Action Deliverable Due Responsible ,

Date Manager / Owner 1 Redefine system engineer Revision to Procedure A.18 for system 9/30/97 Director, Plant Engineering '

- System responsibilities to focus on monitoring engineers to focus on monitoring and Engineers and analysis of system health. analysis'of system health.

2 Increase staffmg devoted to monitoring, a. Authorization for positions. a. Complete Manager, NSED r Trending trending, and supporting hardware b. Assignment ofstaff. b. 9/30/97 and performance improvement. c. Plan and schedule for equipment c.TBD  !

Analysis root cause analysis training.  ;

3 Develep a plan forintegrating or Plan for integrating or coordinating the 12/31/97 Plant Manager i i Prioritizati coordinating the various work control work antrol groups. I on groups (e.g., MCMT, work review .

board, etc.) to provide a process for [

prioritizing work led by Operations.  ;

This plan should account for previous experience at CPS.

4 a. Implement the system improvements a. Report describing improvements and a.TBD a. Manager,. NSED ,

System identifiedin the Nuclear Program conclusion b. 45 days b. Director, Plant' i Improve- Business Plan, including the b. Engineering plan to resolve after Engineering i ments improvements for breakers, condition ofrecirculation pump restart degraded voltage, AR/PR seals. ,

radiation monitors, and feedwater c. Plant and equipment condition c. '12/31/97 c. Plant Manager I

check valves. limits.

b. Develop an engineering plan to . Condenser in-leakage resolve the materiel condition of the . Condenservacuum I recirculation pump seals and RE/RF . ~ main power transformer 'f system. gassing.

c. Develop additional plant or . Suppression Poollevel/EOP i equipment condition limits based on entry conditions CPS and industry operating . Rotating component vibration l experience to ensure conservatism.

Page 20 l

t 4.1.3 Improvements in Work Planning and Control Issue: IP and NRC have identified weaknesses in work control and prioritization, including work planning for outages, work planning during operation, and engineering work control. These types ofweaknesses can contribute to untimely . 1 performance of needed work and corrective actions, can create a potential for a safety concern due to unanticipated 3 conditions and conflicting work activities, and can lead to inefficiencies and lowered proioctivity. Therefore, IP has .['

decided to upgrade its work control processes to help ensure that work is appropriately prioritized and planned, and is' accomplished on schedule.

References:

CPS Common Cause and Root Cause Investigation; PII Preliminary Site Wide Common Cause Analysis; Independent Assessment of NSED; CPS Systematic Assessment Report; NRC OSTI Inspection Report 50-461/96011; ,

NRC E&TS Inspection Report 50-461/97003.

i Current Status: IP has established a Work Control Team to provide a focal point for planning and controlling work. ,

This team has identified work plans for activities beginning after the plant has resumed full power operation. .

Purpose of Additional Improvements: To achieve improvements in work planning and control to reduce the potential for errors and improve plant materiel condition and to help ensure that activities are performed on schedule and in accordance with established priorities.

Goals- . Work activities are prioritized based upon their importance to safety. EWRs, MWRs, surveillances, and modifications are perfonned on schedule. No plant events are caused by any conflicts in work activities.

• Assessment: The QA Department will conduct an assessment ofwhether work activities are being prioritized based ,

upon their significance to safety. Based upca the results of this assessment, the Turn-Around Team will evaluate the -

need for further actions. The Turn-Around Team will determine whether the scheduled goals for EWRs, MWRs, . [

surveillances, and modifications are satisfied. Ifnot, the Team will assess the need for further action. The Turn-Around  !

Team will also review various assessments (e.g., LERs, NRC Inspection Reports, and QA assessments) to determine whether any plant events are attributable to conflicting work. . If so, the Team will assess the need for further action.

Page 21 i

i 4.1.3 Improvements in Work Planning and Control (Cont'd)

No. Action Deliverable Due Responsible Date ' Manager / Owner  !

1 Improve work planning and scheduling a. A root cause analysis report on the a. 9/30/97 Director, Planning and ,

Plant Work to minimize the potential for conflicting planning and scheduling concerns Scheduling Control work, including a root cause analysis of identified by PII.  !

the planning and scheduling concerns b. Plan forimproving work planning b.12/31/97 t

identified in the PII Preliminary and scheduling. ,

Common Cause Analysis, performance c. Performance measures for work c. 9/30/97 measures, and an improved project control.

management system for scheduling d. Improved project management d. 8/30/98  ;

activities. system.

2 Improve engineering work control and a. Work prioritization method. a. 8/13/97 Manager, NSED ,

Engineer- prioritization of engineering tasks, b. Revised work control process. b. 8/15/97 ing Work including: c. Documented process for c. 9/15/97 Control a. revising responsibilities and management oversight.  ;

processes for work initiation.  !

b. prioritization, scheduling, assignment, accountability,  :

management and timely completion, i

and

c. providing a management oversight function.

Page 22  ;

_ _ _ . . _ _ . _ . _ _ .__.__.______..._____._____..____.___.___.___m___ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ .____________._____.____.________________._.______.__=_______.__.____.m. . _ _ _ _ _m____ ____,_.._m_ _.

4.1.3 Improvements in Work Planning and Control (Cont'd)

No. Action Deliverable Due Responsible -

Date Manager / Owner

, 3 Develop methods to improve planning Documented methods to improve 60 day prior Director, Planning and Outage for outages, including identification and planning for outages. to P O8. Scheduling Planning scheduling of support activities, (Currently methods to freeze the outage scope, 2/28/98) better tools to assess outage readiness, and a schedule tool to perform analyses

, of the outage schedule.

Page 23

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4.2.1 Reviews of Programs and Procedures Issue- IP and NRC have identified examples ofinadequate procedures. Additionally, inadequate procedures contributed  !

l to the September 5 event. Complete and accurate procedures are essential to ensuring that tasks are performed properly .

and in accordance with management expectations. As a result, IP has decided to initiate a systematic effort to review and improve its procedures and programs.  ;

l

References:

CPS Systematic Assessment Report; CPS Common Cause and Root Cause Investigation; Cultural Index; i NRC's January 9,1997 Confirmatory Action Letter (CAL); NRC's Trending Letter dated January 27,1997 to IP; NRC Special Inspection Report 50-461/96010 and OSTI Inspection Report 50-461/96011; NRC RP Inspection Report 50-461/96012; NRC Inspection Report 50-461/96015; NRC's 6/9/97 letter Proposing $450,000 Civil Penalty ,

Current Status: IP has reviewed numerous operating procedures and a sample of surveillance procedures. Additionally,  !

t IP has conducted startup readiness reviews for the more important programs Finally, IP has streamlined its procedure change process and has made numerous changes to improve procedures and reduce procedure change backlogs.

Purnose of Additional Imorovements: To provide additional assurance that programs and procedures comply with applicable requirements, are understandable and clear, and can be implemented as written.

Goals: Procedures conform with the USAR, are understandable and clear, and can be implemented as written.

Assessment: The Turn-Around Team will review the results of the ' actions taken below, and will review other relevant assessments (e.g., LERs, NRC Inspection Reports, Condition Reports) to evaluate whether procedures conform with the USAR, are understandable and clear, and can be implemented as written. If not, the Turn-Around Team will assess the need for further actions.

Page 25

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i 4.2.1 Reviews of Programs and Pmcedures (Cont'd)

No. Action Deliverable Due Responsible '

Date Manager / Owner 1 Complete the review ofsurveillance List ofsurveillance procedures a. 3/31/98 a. DirectorofLicensing Surveil- procedures (a) for fidelity with the reviewed, revisions to surveillance lances USAR, technical specifications, (b) pre- procedures, and report of results which b. 3/31/98 b. Director ofLicensing s conditioning, and (c) to identify and includes an evaluation of discrepancies i correct inadequacies that prevent for generic implications. c. 3/31/98 - c. Assistant Plant successful completion of surveillance Manager, Operations j activities. "

2 Using the Program Element Review a. Revisions to procedures / program See program Program Ownersidentified Program Guidance in the SRP, review programs b. Report ofresults ofreview, review - in Appendix 3  !

Reviews in Appendix 3 that were not reviewed identifying what was reviewed, schedulein ,

as part of the SRP readiness reviews, to any weaknesses, and planned Appendix 3  !

identify any program weaknesses. i.nprovements.  ;

3 Evaluate plant procedures against the Report which evaluates CPS 1/31/98 Director, Plant Support Procedure best plants in the industry for effective procedures against procedures ofbest Services Bench- procedures. plants, with recommendations for i marking improvement..  ;

4 Establish goals for the backlog of Backlogs ofprocedure changes and 12/31/97 Director, Plant Support  !

Procedure procedure changes and Comment CCFs are less than established goals.- Services Changes Control Forms (CCFs), and reduce the j backlog to within established goals.

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4.2.2 Improvements in Assessments and Corrective Actions t

Issue: IP and NRC have identified some weaknesses in CPS assessments. Additionally, IP and NRC have identified examples ofinsufficient corrective actions, including assessment of event significance, trending, root cause analysis, and timeliness of corrective actions. The ability to identify and correct problems and weakneaec in a timely manner is critical to ensuring safe, reliable, and economical performance, and to improving performance Therefore, IP has decided to upgrade its assessment and corrective action program to ensure that problems are promptly identified and corrected, and that recurring problems are precluded.

References:

Cultural Index; CPS Systematic Assessment Report; CPS Common Cause and Root Cause Investigation-Independent Assessment ofNSED; CPS Independent Corrective Action Processes Aueament; NRC's PPR Letter i dated March 13,1997; NRC Inspection Report 50-461/96014; NRC's Proposed $450,000 Civil Penalty; NRC E&TS t Inspection Report 50-461/97003; NRC Special Inspection Report 50-461/96010 and OSTI Inspection Report 50-461/96011.

Current Status: IP has made several improvements in its QA Department, including adding experience in various i

' disciplines and performing more performance-based surveillances. Additionally, IP has issued a procedure requiring departments to perform periodic self-assessments. Finally, IP has made a number ofimprovements in its corrective  !

action program, including lowering the threshold for preparation of Condition Reports and establishing an Independent t Analysis Group to perform root cause analyses.

Purmse ofAdditionalImprovements: To improve IP's ability to identify and correct conditions adverse to quality.

Goals: CPS assessments are effective in identifying problems and weaknesses. The aging of Condition Reports, and the amount of recurring conditions and repetitive failures, satisfy established goals. Resolutior:s are timely and effective in correcting adverse conditions and precluding recurrence. [

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4.2.2 Improvements in Assessments and Corrective Actions (Cont'd)

Assessment: The Assistant to the Vice President will contract for a third party assessment by INPO or others of the effectiveness ofIP's assessments. Based upon these results, the Turn-Around Team will assess the need for further actions. The Turn-Around Team will determine whether the actions listed below have beer. completed. The Team will also determine whether the aging of Condition Reports, and the amount of recurring conditions and repetitive failures, satisfy established goals. Finally, the Team will review various assessments (e.g., LERs, NRC Inspection Reports, and QA assessments) to determine whether any adverse conditions are recurring, whether corrective actions are effective, ,

and whether any corrective actions have been untimely. Based upon these results, the Turn-Around Team will assess the need for further actions.

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Page 28

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4.2.2 Improvements in Assessments and Corrective Actions (Cont'd) j I

No. Action Deliverable Due Responsible '

Date Manager /0wner I a. Develop and implement a plan to a. A plan to improve QA audits and a.12/31/97 Manager, QA }

QA Assess- improve audits and assessments by assessments. b.12/31/97 i ments the Quality Assurance Department b. Action plan forimproving *

(QA), including adding personnel, quality control.

training for personnel, a rotation plan, and QA assessments of  !

management oversight activities.

b. Develop and implement an action plan to improve Quality ,

Control with a focus on hardware  ;

and material conditions by plant ,

area.

2 a. Develop and implement a program a. A self-assessment plan for each a. 9/31/97 a. Each Department Self-Assess- of department self-assessments in department, including identification b.10/31/97 Manager -

ments accordance with CNP 3.08, which ofregularly scheduled self- b. Manager, QA includes consideration ofoperating assessments and criteria for i experience. iddating special self-assessments

b. Develop a plan for routine audits in response to internal or external t of such programs. events.

b. A plan for routine audits of 1 I

departmental self-assessment programs.  ;

3 Perform an iadependent diagnostic Report of strengths and weaknesses, 9/30/97 Assistant to Vice President t Independ- safety assessment to accurately including root causes for CPSs i

ent determine the reason for CPSs performance decline.

Assessment performance decline. i Page 29

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4.2.2 Improvements in Assessments and Corrective Actions (Cont'd)

No. Action ' Deliverable Due Responsible Date Manager / Owner l 4 Improve the process for performing a. Revised procedures on event 9/30/97 Director, Plant Support Event critiques, including training for critiques. Services

' Critiques ~ personnel and critique chairmen b. List of personnel receiving traimng on event critiques. l' 5 Improve root cause analyses by Plan for addressing the PII finding on 12/31/97 Assistant to Vice President Root Cause addressing the PII assessment and root cause analyses, and a list ofroot Analyses establishing root cause analysts to lead cause analysts.

investigation teams for significant CRs. l 6 Provide training to department a. List ofpersonnel receiving apparent 12/31/97 Assistant to Vice President Apparent personnel in identifying apparent causes cause training.

Cause ofless significant events that do not b. Apparent cause training lesson Training warrant a formal root cause analysis. plan. ,

7 Develop an action plan that defines the Plan for Performance Monitoring and 12/31/97 Assistant to Vice President Trending purpose and goals of the CPS Trendmg.  ;

and Performance Monitoring and Trending -l Analysis Program, which incorporates PII elements, and includes provisions for j

- communicating trend to plant personnel.

8 Establish a mechanism to provide Plan for providing information to plant 12/31/97 Assistant to Vice President Communi- information to plant personnel - personnel.

cation regarding identified specific problems and their resolution. 3 9 Establish a site organization which A revised organization plan. 7/31/97 Assistant to Vice President i Organi- combines existing groups devoted to zation assessments, corrective actbns, and improvements.

i Page 30 t,

l 4.2.3 Improvements in Other Programs ,

Issue: IP and NRC have identified certain weakne-< in other programs The most significant of these weakneaa=

pertain to post-modification and surveillance testing; design and design control; control of vendor manuals; rnantion protection; plant operations; and the operating em:ence program.

References CPS Readiness Reviews; NRC's January 9,1997 CAL; NRC's Trending Letter dated January 27,1997 to i IP; NRC's PPR Letter dated March 13,1997; NRC E&TS Inspection Report 50-461/97003; NRC Inspection Report

50-461/96010 and OSTI Inspection Report 50-461/96011; NRC RP Inspection Report 50-461/96012; NRC Inspection ,

Report 50-461/96015; NRC's 6/9/97 letter Proposing $450,000 Cisil Penalty 1 i l l Current Status: Operations and Maintenance have issued booklets identifying management expectations for cf. rations and maintenance.

Purpose of Additional Imorovements: To correct the specific weaknesses in the programs identified above. .

t Goals: The weaknesses in the programs identified above have been corrected.

. Assessment: The Turn-Around Team will assess whethe- the actions identified below have been completed. The QA Department will perform assessments of the effectiveness of these actions. Based upon the results ofits own assessments and the QA assessments, the Turn-Around Team will assess the need for any further actions.

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Page 31 e-- w

4.2.3 Improvements in Other Programs (Cont'd) [

t No. Action Deliverable Due Responsible Date Manager / Owner 1 Maintenance should identify Maintenance will identify deliverables TBD Assistant Plant Manager, Testing improvements in post-modification and Maintenance surveillance testing; these actions are  ;

needed to address IR 97003]

2 Improve design process. a. Improvement Plan based on results 9/30/97 Manager, NSED Design a. Perform a common cause analysis ofcommon cause analysis.

Control of all condition reports generated on b. Decumentation identifying the ,

i modification and design control procedure changes and confirming proce::ses in the last IS months. issuance of the revised procedure.

b. Revise CPS No. 1003.01 to improve t its user-friendliness and incorporate specific CR corrective actions. >

3 Improve vendor manuals and the Confirmation that CPS's vendor 12/31/98 Manager, NSED -

Vendor vendor manual update process. technical documents in vendor manuals Manuals a. Incorporate 900 change documents, and the controlled drawing file are up i

b. Re-establish the vendor contact to date and verified to be the correct -

program, version for equipment configuration at

c. Evaluate control drawings (in DSS) CPS (except for ongoing USA effort).

versus those in VM and,

d. Receive and process over half of the  :

new VMs from the USA contract with PRC.

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4.2.3 Improvemenb in Other Programs (Cont'd)

No. Action Deliverable Due Responsible Date Manater/ Owner 4 a. Implement the Radworker a. Closure report documenting a 8/30/97 Director, Plant Radiation  !

Radiation g Assessment Plan. implementation of the Assessment and Chemistry  ;

Protection b. Develop and implement a higher Plan. b. 3/31/98 Director, Maintenance and level Radworker training course as b. Training records documenting Technical Tra'.ning .

follow up on training to initial implementation of the training Radworker qualifications c. Confirmation that Radworker c. 7/18/97

c. Increase accountability for good performance is being satisfactorily  ;

Radworker performance. investigated by the line organization  :

d. Develop clear and concise set of and individuals with unsatisfactory Radworker procedures by performance are held accountable i i implementing a comprehensive set and understand the radiological ofdistinct and separate Radworker expectation i procedures. d. Confirmation that the Radworker d. TBD i procedures have been satisfactorily i implemented.

5 Improve the conduct of Operations, n.TBD a.TPD a. Assistant Plant i Operations including: b. Evaluation report of safety tagging b. 4/1/98 Manager, Operations l process, lesson plans and attendance b. Assistant Plant  ;

a. [ Operations should identify actions list for training on process, and Manager, Operations to improve the rigor ofplant goals and monitodng system for operations (includinglogs and safety taggmg process. 6 pre-job briefings) to address  !

3/13/97 NRC PPR Letter; NRC's i

)

1/27/97 Trending Letter;NRC's 1/9/97 CAL;IR 96010 and 96011.]

b. Improve the safety tagging program,  ;

including evaluation of the process, ,

training on the revised process, and  ;

development ofgoals and a l monitoring system.  :

6 Page 33 i P

.m_ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . . _ _ . . _ _ _ . _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ _ - _ _ . + - ___ _ _____ _ __._ __________ _ _____ _ _ m_,

i 4.2.3 Improvements in Other Programs (Cont'd) 6 a. Improve the availability and a. Database ofIndustry Feedback a.1/31/98 a. Director ofLicensing -  !

Operating response to industry experience. Program information, and plan for b.1/30/98 b. Plant Manager Experience b. Improve quality of daily managers upgrading responses to industry c. 3/31/98 c. ISEG meetings and planned evolutions and experience. d.12/31/97 d. Corrective Action pre-job briefings to include pertinent b. Guidelines for considering industry Program Coordinator -

industry information and station information and station events in events. daily managers meeting and planned

c. Review operating experience closure evolutions and pre-job evolutions.

packages for adequacy. c. Guidelines for ISEG reviews.

d. Revise the corrective action process d. Revision to corrective action to include provisions for considering procedure to include provisions for industry experience for correcting considering industry experience.

significant conditions adverse to ,

quality t

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Page 34 i

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l-4.3.1 Improvements in Leadership and Accountability l Lsse: IP and NRC have identified instances in which management expectations were not clearly defined and ccmmunicated, management did not oversee the activities ofits staff, and management expectations were not met.

Tl:ese factors contributed to the September 5 event. Safe, reliable, and efficient operation is dependent on effective l

management and supervision by all CPS departments. As a result, IP is taking action to enhance the communication of its expectations, to oversee the activities ofits staff to ensure that personnel understand management expectations, and to ensure that personnel are held accountable for satisfying those expectations.

References:

CPS Systematic Assessment Report; CPS Common Cause and Root Cause Investigation; CPS Readiness Reviews; NRC's January 9,1997 CAL; NRC's Trending Letter dated January 27,1997 to IP; NRC's PPR Letter dated March 13,1997; NRC E&TS Inspection Report 50-461/97003; PII Preliminary Site-Wide Common Cause Analysis; Independent Assessment ofNSED; NRC Special Inspection Report 50-461/96010; NRC OSTI Inspection Report 50-461/96011; NRC's 6/9/97 letter Proposing $450,000 Civil Penalty Current Status: IP has communicated its expectations for procedure compliance and conservative decision making to CPS personnel. Additionally, IP has established an In-Plant Crew Monitoring program for control room operations, and has established a program for monitoring nuintenance work. Finally, PII has provided training to supervisors on effective supervision.

Purnose of Additional Improvements: To improve identification and communication of management expectations to supervisors and workers; to improve management overview of plant activities; and to ensure that personnel are held -

accountable for satisfying management expectations.-

Goals: Management expectations are established, management and supervisors regularly observe actisities by their staff, personnel satisfy management expectations, and personnel are held accountable if they do not satisfy management expectations.

Page 36

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4.3.1 Improvements in Leadership and Accountability (Cont'd)

Assessment: The Turn-Around Team will assess whether the actions identified below are being taken. The Assistant to the Vice President will contract for a third-party assessment by INPO or others to determine whether management expectations are established, understood, and satisfied by personnel; whether management is providing effective overview of the activities of their staff; and whether personnel are being held accountable for satisfying management's '

expectations. Based upon these results, the Turn-Around Team will assess the need for further actions.

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4.3.1 Improvements in Leadership and Acc,unimo:'% (Cont'd)

No. Action Deliverable Due Responsible Date Manager / Owner ~

1 Implement training to improve a. Lesson plan.- for t aining. 10/30/97 Marger, Nuclesr Training  !

Manage- management and supervisory skills. b. Attendance Ic $ for training. & Support  !

ment Skills {

2 Establish expectations and goals for Revision 0 ofexpectations and goals 12/31/97 CPS Vice President Manage- each individual, group, and department. for each individual, group, and ment These shall be reviewed and revised as department. ,

Expecta- appropriate on an annual basis.

tions ~

3 Develop and implement a program for Guidelines for managers and 12/31/97 CPS Vice President +

Manage- managers and supervisors for observing supervisors on monitoring work, ment work, training, and other activities of training, and other activities of their Observa- their staff. (See also Action 4.3.2.3) staff to determine whether personnel tions are satisfying expectations, missions, and goals. ,

i 4 On a continuing basis, conduct Initial checklists for each manager, 12/31/97 CPS Vice President Perform- performance reviews which assess director, and supervisor position which ance performance against expectations and provide a mechanism for evaluating -

Reviews goals. his/her staff against expectations and -

goals.

5 [ Assistant to the Vice President should TBD TBD, CPS Vice President Teamwork develop a plan to respond to Cultural  !

Index concern regardinglateral integration and teamwork.] i Page 38

.- ~. . . -. ~ . - . - . . - . - - . - - - - . - . . -- -- -. --- -- - - -- - - ~. . -

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t 4.3.2 Improvements in Hannan Performance Issue: IP and NRC have identified instances of procedure noncompliance and non-conservative decisions. Additionally, procedure noncompliances and non-conservative decisions contributed to the September 5 event. ' Industry expe ience has shown that consistent compliance with procedures and conservative decision making is essential to ensuring safe and  ;

reliable operation and achieving improvements in performance. As a result, IP is taking action to improve procedure compliance and conservative decision making at CPS.

References:

CPS Common Cause and Root Cause Investigation; NRC's 3/13/97 PPR Letter; NRC's January 9,1997 I CAL; NRC's Trending Letter dated January 27,1997 to IP; PII Preliminary Site Wide Common Cause Analysis; Independent Assessment of NSED; NRC Special Inspection Report 50-461/96010 and OSTI Inspection Report 50- .

461/96011; NRC RP Inspection Report 50-461/96012; NRC Inspection Report 50-461/96015; CPS Systematic l l

. Assessment Report; NRC's 6/9/97 letter Proposing $450,000 Civil Penalty l

r Current Status: IP has communicated and provided training on its expectations on procedure compliance and l conservative decision making to CPS personnel. IP has also revised its procedures and issued new procedures on  :

procedure use and compliance to require strict procedure compliance.

Purpose _of Additional Imorovements: To achieve continued improvement in human performance, including compliance l with procedures and conservative decision m=mg i Goals: Personnel routinely comply with procedures and make conservative safety decisions, as demonstrated by f performance measures and assessments.

Assessment: The Turn-Around Team will review the performance measures related to human performance, and the results ofvarious assessments (e.g., NRC Inspections, QA assessments). The Assistant to the Vice President will ,

contract for a third-party assessment by INPO or others to assess human performance and procedures. Based upon the l results of these assessments, the Turn-Around Team will assess the need for further actions. ,

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. _ . . _ . . _ _ _ _ _ . __._ __ _ ..m __ _ _ m _____ _._____.____ . _ ._ _ _ _ _._ _ ____ _ . _ _ ___ . __ _ _ _ _ __ _ _ _ _ . _ _

4.3.2 Improvements in Human Performance (Cont'd) .

No. Action Deliverable ' Due Responsible Date - Manager / Owner 1 Complete training for a) supervisors a and b Traininglesson plans on human a. 9/1/97 Steering Committee i Human and b) workers on human error error reduction, and attendance lists for b.TBD Error reduction. the training classes.

Reduction i Training 2 Conduct training and seminars for Lesson plans for training and seminars TBD Manager, Nuclear Training Procedure employees on procedure performance on procedure performance and and Support Perform- and conservative decision making. conservative decision making, and ance & attendance lists for the classes.

Conser- -

vatism 3 a. Develop and implement an a. An organization and programmatic a.12/31/97 a. Director, Independent Monitoring organization and programmatic measurement plan. b.12/31/97 Analysis Group i performance measurement program. b. A plan for evaluating and correcting c.TBD b. Director, Independent

b. For existing human performance declining trendsin performance Analysis Group ,

related performance measures, measures. c. Director, Independence develop and implement a program c. A plan for behavior-based Analysis Group for evaluating and correcting performance monitoring.

declining trends and performance which does not satisfy goals.

c. Develop and implement a behavior-based performance monitonng program.

Page 40

' ,. APPENDIX 1 IDENTIFICATION OF IlOW SIGNIFICANT ISSUES IIAVE BEEN ADDRESSED BY SRP Issue Addressed by SRAP Addressed by LTIP Independent Assessment of Clinton Power Station's Nuclear Station Engineering Department Ganuary 10.1997) I

1. Inadequate work control SRAP III.10 LTIP Q 4.1.3.2 and prioritization. I

2. Management goals and SRAP III LTIP 4.3.1.2  ;

expectations are not clearly defined and communicated.

3. Non-conservative decision SRAP II LTIP 4.3.2 making.

4. Insufficientindividualand N/A LTIP Q 4.3.1.4 team accountability.

5. Skills, training, and tools N/A LTIP Q 4.3.2 not supportive of conserva-tive processes.

6. Insufficient inanagement SRAP III LTIP 4.3.1 follow-through and inde-pendent oversight.

CPS Preliminary Site Wide Common Cause Analyses by Performance Improvement International (PII)

(May 1997)

1. Less than adequate work SRAP III.10 LTIP { 4.1.3 planning and scheduling.

2. Ineffectiveimplementation SRAP { III LTIP 4.3.1 ofmanagement expectations.

3. Potential procedural non- SRAP I LTIP 4.3.2 compliances.

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. Issue Addressed by SRAP Addressed by LTIP CPS Independent Corrective Action Processes Assessment by FPI (March 28.1997)

The greatest areas of opportunity for improving the corrective action system relate

+o:

1. Root cause investigation N/A LTIP 4.2.2.4 process

2. Problem monitoring and N/A LTIP Q 3.5 and 4.2.2.6 tiending

3. Communication of N/A LTIP 4.2.2.7 information to personnel

4. Segmented ownership of Independent Analysis N/A corrective action program. Group CPS CulturalIndex Results by PII (Feb.1997

]

The top concerns of station personneiinvolve:

a. Investigating causes, SRAP I.5 LTIP Q 4.2.2 taking corrective actions, j and preventing recurrence.  !

b. Teamwork N/A LTIP 4.3.1.5

c. Processes and procedures SRAP Q I LTIP Q 4.2.1 CPS Systematic Assessment

]Leport (December 1996)

1. Industrial Safety Practices N/A N/A

2. Planning and Scheduling SRAP j III.10 LTIP 4.1.3 ofActivities

3. Procedures Not Followed SRAPQI LTIP Q 4.2.1 and 4.3.2 orInadequate ,

4 Management Oversight SRAP III LTIP 4.3.1.3

& Involvement

5. PersonnelPerformance SRAP I and II LTIP 4.3.2

6. Corrective Action Program N/A LTIP G 4.2.2 Page 2

. Issue Addressed by SRAP Addressed by LTIP Common Cause and Root Cause Investigation of the Recirculation Pump Seal Leakage Event of September 5-6.1996 '

l. The problem areas identi-fled for this event included:

a. Non-conservative plant SRAP { II LTIP Q Q 4.3.1 and 4.3.2 operation b.' Procedure inadequacy SRAPQI LTIP 4.2.1

c. Inadequate management SRAP III LTIP { 4.3.1.3 oversight.

d. Inadequate planning SRAP III.10 LTIP { 4.1.3 and evaluation of infrequently performed .

evaluations.

e. Long-standing equip- SRAP IV.7 LTIP 4.1.2 ment problems.

f. Untimely recognition of SRAP { III.8 LTIP 4.2.2, 4.3.1, and the signi6cance of the 4.3.2 events.

2. The root cause of these problems are:

a. Management expecta- SRAP I, II, and III LTIP Q 4.3.1.2 tions not always clear and unambiguous,

b. Management oversight SRAP III LTIP 4.3.1.3 and and conservative deci- 4.3.2 sion making.

c. Internal and external N/A LTIP 4.2.2 evaluations not used to identify commonalities or declining trends.

Page 3 m

. Issue Addressed by SRAP Addressed by LTIP NRC Special Inspection Report 50-461/96010 and -

NRC Operational Safety Team Inspection Report 50-461/96011

1. The 9/5/96 event revealed significant deficiencies including:

a. Proceduraladequacy SRAP I LTIP 4.2.1

b. Procedure adherence SRAP I LTIP Q 4.3.2 -

problems

c. Lack of rigor in con- SRAP { I.2 LTIP 4.2.3.5 ducting plant operations

d. Weak engineering N/A LTIP 4.1.1.4 and support to. operations 4.1.3

e. Lapses in safety focus SRAP II LTIP 4.3.1, 4.3.2

f. Failure to correct known SRAP IV.7 LTIP Q 4.1.2 material conditions

g. Self-assessment did not SRAP Q I.5 LTIP 4.2.2.2 fully address procedure compliance issues I

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,' Issue Addressed by SRAP Addressed by LTIP NRC SpecialInspection Report 50-461/96010 and NRC Operational Safety Team Inspection Report 50-461/96011 (Cont'd)

2. The OSTIidentified prob-lems involving:-

a. Procedure adequacy SRAP { I LTIP 4.2.1

b. Procedure adherence SRAP I LTIP 4.3.2

c. Preconditioning for a SRAP I.11 LTIP 4.2.1.1 diesel generator sur-veillance .-

i

d. A lack of management SRAP Q III LTIP 4.3.1.3 oversight of control f room i l e. Weak engineering N/A LTIP 4. ' . l .4 and support to operations 4.1.3.2

f. Weak safety focus by SRAP Q II LTIP 4.3.2 engineering l

g. Poor operability SRAP IV.9 LTIP { 4.1.1.4  !

evaluation program i

! h. Failure to perform SRAP I.17 LTIP Q 4.1.1.3 )

50.59 safety evaluations and weak safety evaluations

i. Inadequate corrective N/A LTIP { 4.2.2

! actions

j. Operations did not have SRAP { II LTIP 4.3.1 and 4.3.2 safety as its highest

, priority l= k. Conduct of operations SRAP Q I.2 LTIP { 4.2.3.5 lacked rigor and formality

1. Procedure change SRAP I.9 LTIP 4.2.1.4 backlog

m. Operations department SRAP { III.8 LTIP Performance missed identifying Measure on CRs problems due to a high threshold

n. living with long SRAP Q IV.7 LTIP 4.1.2

! standing material conditions

o. Weak surveillance SRAP I.11-14 LTIP % 4.2.1.1 i- procedures

p. Tests performed using SRAP IV.10 N/A action plans rather than

!~

procedures Page 5

Issue Addressed by SRAP Addressed by LTIP Confirmatory Action Letter dated 1/9/97 from A. Bill Beach (NRC) to Wilfred Connell i

1. . The 9/5/96 event revealed significant deficiencies in:

a. Procedural adequacy SRAP I LTIP 4.2.1 and 4.3.2 and adherence

b. Rigor in conducting SRAP I and II LTIP 4.2.3.5 plant operations

c. Engineering support to N/A LTIP 4.1.1.4 and Operations 4.1.3.2

d. Lapses in safety focus SRAP II LTIP 4.3.1 and 4.3.2

2. The area not addressed is SRP Performance LTIP 3.5

the criteria IP will use to Measures

evaluate the plans i effectiveness 4

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. Issue Addressed by SRAP Addressed by LTIP Letter dated 1/27/97 from Hugh L. Thompson (NRC) to Larry D. Haab (IP)

1. Examples of non- SRAP Q II LTIP s 4.3.1 and 4.3.2 conservative safety focus.

2. Examples ofpoor SRAP Q I LTIP { 4.2.1 and 4.3.2  !

procedural adherence and I adequacy.

3. Examples ofweak engi- N/A LTIP Q 4.1.1.4 and neering and maintenance 4.1.3.

support to operations.

4. Examples of a lack of SRAP I & II LTIP { 4.2.3.5 1 I

discipline and rigor during conduct of operations.

5. Some operational evalua. SRAP IV.9 LTIP 4.1.1.4 tions for degraded equip-ment were not rigorously performed.

6. Examples ofbypassing SRAP IV.10 N/A normal procedure develop-ment processes by using '

Action Plans to direct equipment manipulations.

7. Several control room and SRAP IV.12 Performance Measure on equipment materiel MCR Deficiencies; condition deficiencies LTIP 4.1.2.3 were allowed to exist for extended time periods.

8. Three individuals were SRAP I-contaminated when they LTIP 4.2.3.4 and perfc,rmed an activity 4.3.2 without appropriate procedure guidance.

Page 7

, - a' Issue Addressed by SRAP Addressed by LTIP Letter dated 3/13/97 from A. Bill Beach (NRC) to Larry D. Haab (IP) i

1. Significant performance SRAP { I and II LTIP Q 4.2.3.5 weaknesses in operations.

2. Significant performance N/A LTIP 4.1.1.4, 4.1.3.2, weaknesses in engineering. and 4.2.3.2

3. Significant performance N/A LTIP 4.2.3.4 i weaknesses in radiation protection.

4

4. Significant procedural SRAP { I and II LTIP 4.3.1 and 4.3.2 adherence deficiencies and -

lapses in safety focus  :

during the 9/5/96 event.

5. Significant deficiencies in SRAP IV.9 LTIP 4.1.1.4 l

! operational evaluations.  ;

6. Significant deficiencies in SRAP { I.17 LTIP Q 4.1.1.3 50.59 evaluations.

7. Significant deficiencies in SRAP { I and II LTIP { 4.2.3.5 and i procedural adherence and 4.3.2 1 conduct ofoperations.

4 8. Significant deficiencies in SRAP IV.12 Performance Measure on

.' control room materiel MCR Deficiencies condition.

9. Slow response to SRAP III.7 LTIP Q 4.2.2 and 4.3.1 thoroughly assess operator crew during 9/5/96 event, and insufficient initial j ,

assessment.

NRC Inspection Report 50-461/96012 on Radiation Protection (RP) and Chemistry i 1. Procedure adherence and adequacy problems. SRAP Q I LTIP { 4.2.1 and 4.3.2

2. Lack of conservative decision making. SRAP II LTIP 4.3.2

3. Lack of sensitivity towards RP controls and alarms. N/A LTIP 4.2.3.4

4. Worker acceptance of RP problems, and an inability N/A LTIP 4.2.3.4 to identify emerging problem trends.

Page 8

.. .o Issue Addressed by SRAP Addressed by LTIP NRC SpecialInspection Report 50-461/96014 on Inoperable EDG

1. Methods for assuring that N/A LTIP Q 4.1.1

' design basis information is correctly translated into procedures.

2. Lack of documentation and N/A- LTIP 4.2.2 tiniely corrective action for a discrepancy between as-found and as-left setpoint.

NRC Inspection Report 50-461/96015 1.' Continuing problems with SRAP I LTIP { 4.2.1 and 4.3.2 procedure adherence and adequacy.

2. Continuing problems with SRAP II LTIP { 4.3.2 conservative decision making.-

3. CPS's upper tier adminis- New Procedure 1005.15 LTIP 4.3.2 trative program on proce-dure adherence authorizes deviations from procedures.

4. Failure to perform safety SRAP Q I.17 LTIP 4.1.1.3 evaluations for USAR  ;

changes. LTIP Q 4.2.3.4 5.' Failure to perform required N/A radiological surveys.

Page 9

1

. .c i I Issue Addressed by SRAP Addressed by LTIP 1 NRC Engineering & Technical Support (E&TS) Inspection  !

Report .

I 50-461/97003 ., j

1. Inadequate engineering and Letter WC-220-97 dated LTIP 4.1.2.4 maintenance practices for 5/30/97 electrical breakers. l

2. Weak 10CFR50.59 Safety SRAP I.17 LTIP 4.1.1.3 Evaluation Program.

3. Weaknesses in modifica- N/A LTIP 4.2.3.2 tion and design control process.

4. Weaknesses in post- N/A LTIP 4.2.3.1 modification and surveil-lance testing program.

5. Weaknesses in trending of N/A LTIP 4.1.2.2 equipment and system performance.

6. Weaknesses in tracking N/A LTIP Q 4.2.3.6 industry information.

7. Weaknesses in prioritizing SRAP III.10 LTIP 4.1.3.2 l work and work control.

8. Weaknesses in self- N/A LTIP Q 4.2.2.1 and j assessments and audits. 4.2.2.2

9. Weaknesses in operability SRAP IV.9 LTIP 4.1.1.4 evaluations.

10. Weaknesses in oversight N/A LTIP 4.3.1.3 ofengineering.

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4 Page 10

." Issue Addressed by SRAP Addressed by LTIP NRC Letter dated June 9, 1997, Imposing Proposed

$450.000 Civil Penalty L Violations demonstrate:

l a.' a lack of conservative SRAP { II LTIP Q 4.3.2 l decision-making l b. pervasive procedural SRAP { I LTIP 4.3.2 l adherence problems  !

c. inappropriate SRAP I LTIP Q 4.2.1 i procedures l d. lack of rigor in conduct- SRAP I.2 LTIP 4.2.3.5 ing routine plant I operations. j L e. weaknesses in the SRAP{ I and II LTIP { 4.2.3.5 j conduct of operations  :

f. weaknesses in engineer- N/A LTIP 4.1.1.4 and ing support to 4.1.3.2 operations i

2. CPS management failed to SRAP II LTIP Q Q 4.3.1 and 4.3.2 put proper focus on safe, conservative facility operations.

3. Controls were not used SRAP I.5, III.8 and LTIP { 4.1.2 and 4.2.2 effectively to ensure early IV.7 detection and timely resolution of adverse conditions.

4. Significant deficiencies in SRAP I.17 and IV.9 LTIP Q 4.1.1.3 and safety evaluations and 4.1.1.4 operability determinations.

5. CPS had difficulties in New Procedure 1005.15 LTIP 4.3.2 implementing effective corrective action for procedure compliance problems.

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• i # Issue Addressed by SRAP Addressed by LTIP NRC June 23,1997

^

Systematic Assessment of-Licensee Performance (SALP) l for CPS

? l

1. Pervasive procedural SRAP Q I LTIP 4.3.2.2 l adherence problems

2. Deficiencies in operations SRAP I LTIP { 4.2.1.1 and surveillance procedures problems I l 3. Deficiencies in 50.59 safety SRAP I.17 and IV.9 LTIP j 4.1.1.3 and l evaluations and operability 4.1.1.4 l l evaluations l 4. Long-standing hardware SRAP IV.7 LTIP 4.1.2 i deficiencies I

5. Management under- SRAP Q III LTIP Q Q 4.2.2 and 4.3.I' standing, oversight, and j attention on corrective actions l 6. Management fostered an SRAP II LTIP Q 4.3.1 and 4.3.2 environment to minimize outage.

7. Numerous personnel errors SRAP I LTIP 4.3.2.1

8. Problems with work SRAP III.10 LTIP 4.1.3 package quality and work control

9. Timely resolution of SRAP IV LTIP 4.1.2 material condition concerns was lacking in some instances

10. Weakness in root cause N/A LTIP 4.2.2.4 invesigation

11. Weaknesses in design N/A LTIP 4.2.3.2 control l

12. Some inadequate designs N/A LTIP { 4.2.3.2 and design errors

13. Problems with worker N/A LTIP 4.2.3.4 sensisivity toward radiological controls and ala.nns.

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Page 12

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APPENDIX 2

DISPOSITION OF SUGGESTIONS FOR LONG TERM IMPROVEMENTS l IDENTIFIED THROUGH READINESS REVIEWS Suggestion R_devant LTIP Section '

Comply with Generic Letter 83-28 4.2.3.3 regarding frequency of solicitation of vendor technicalinformation.

l Assign a team of engineers to field support 4.1.2.1 to free systems engineers to manage problems / trends on their systems.

Review and revise overtime policy for non- N/A exempt personnel during outages.

Use the latest technology to identify flow N/A accelerated corrosion.

ISEG will perform a self-assessment. 4.2.2.2 Visit at least one other ISEG to improve the N/A  !

ISEG process.

Don't include the ECCS/SM dump valves N/A as an alternate shutdown cooling system in the RF-07 schedule; use it as a last resort.

Revise the ISEG procedures to address N/A NAD's assessment ofISEG.

Develop an effective approach to 4.3.1 accountability.

Assess the current communication tools at 4.3.1 CPS for effectiveness. Establish an environment where employees feel free to provide feedback to management.

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l Suggestion Relevant LTIP Section

l. .

Assess ourselves better. 4.2.2 ,

l Increase management time spent in the field 4.3.1 l coaching, reinforcing expectations, and clearing obstacles l

l Improve reliability of the annunciator N/A system.

Determine the responsibilities of the N/A MCMT in the areas of work control,' outage scoping, and modification prioritization.

Evaluate and decide if the MCMT should N/A be described in the CPS USAR.

Improve the safety tagging program, 4.2.3.5-including evaluation of the process, training on the revised process, and development of goals and a monitoring system.

Note 1: Suggestions not included in the LTIP may be included in departmental level improvement plans.

I Page 2

APPENDIX 3 LONG TERM SITE PROGRAM REVIEWS Proeram Name Owner Duc Date Control of Working Hours Director, Plant - 8/15/97 Support Services l

Emergency Operating Procedures Director, Plant 08/30/97 and Preparation Support Services Contractor Management Assistant Plant 12/31/97 Manager, Maintenance Temporary Modifications Assistant Plant 09/01/97 Manager, Operations Operability Determination Assistant Plant 09/15/97 Manager, Operations CPS Licensee Event Reports (LER) Director of 09/30/97 Licensing Conduct and Documenting of Critiques Director, Plant 09/30/97 l Support Services i Plant Records Preparation Transmittal Director, Received l and Retention Administration  !

Control of Chemicals Director, Plant 10/30/97 Radiation &

Chemistry Housekeeping Director, Plant 08/30/97 Support Services l System Cleanliness Assistant Plant 12/31/97 Manager, Maintenance

I ij Pronram Name Owner Due Date i

i ' Foreign Material Exclusion Areas (FMEA) Assistant Plant 12/31/97 Manager, l Maintenance Dry Active Waste Director, Plant 08/30/97 Radiation and l l Chemistry - I i

Leakage Reduction and Monitoring Program Assistant Plant 11/01/97 l Manager, Operations Human Performance Enhancement System . Assistant to the 09/01/97 Vice President l l Site Communication Director, Operations 03/09/98 i

Training and l Emergency Response I Radiation Environmental Monitoring Director, Plant 07/30/97 Radiation &  :

Chemistry Respiratory Protection Program Director, Plant Received Radiation &

Chemistry MWR Preparation and Routing of Assistant Plant 12/31/97

Maintenance Work Documents Manager, Maintenance l

CPS Security Program Director, Plant Received Support Services j Security Access Control (Personnel / Vehicle) Director, Plant Received Support Services Safeguards Control Program Director, Plant Received

! Support Services I

Plant Labeling Assistant Plant 09/01/97 Manager, Operations 4

r

is . .,

t-l

i. Program _Narae Owner Due Date '

l Changes to CPS Operating License /rech. Spec. Director of 09/30/97 .

Bases Licensing l

l l Revising the USAR and the ORM Director of 11/26/97 L Licensing i

Conduct of System Lineup Assistant Plant 08/01/97 i

Manager, Operations

. . Conduct ofCPS Testing (including Director, Plant 10/01/97 j Ventilation Test Program) Engineering l

Coordination Plans Director, Engineer- 11/30/97 mg Projects )

l Air Operated Valve Program Assistant Plant 12/31/97 Manager, Maintenance

Welding Program Assistant Plant 12/31/97 )

I '

Manager, L Maintenance i

l ODCM Program- Director, Plant 10/03/97 ,

j Radiation &

i Chemirtry 4

Plant System Lay-up Program Director, Plant 11/07/97 Radiation &

Chemistry Plant Water Chemistry Control Director, Plant 09/12/97 Radiation &

l Chemistry l ASME Repair and Replacement Director, Plant 10/01/97 l Engineering i

EQ Director, Engineer- 11/30/97  :

ing Projects SQ Director, Engineer- 11/30/97 ing Projects

%  :. *e

.s i

i i Program Name Owner Due Date Fatigue Monitoring Director, Plant 09/01/97 ,

Engineering Major Component Overhaul Program Director, Plant ,

09/26/97 Engineering MOVs Periodic Verification Director, Plant .09/15/97 Engineering NDE Program Director, Plant 09/15/97 Engineering NSED Work Control Program Director, Resource 09/15/97 Management PRA Director, Engineer- 12/31/97 ing Projects External Dosimetry Program ,

Director, Plant Received Radiation &

Chemistry l

Check Valves Director, Plant 10/01/97 '

)

Engineering  !

l i

Sonware Control Leader, Engineering 10/30/97 l Assurance

!- Predictive Maintenance Director, Plant 09/01/97 Engineering i Process Control Program Director, Plant 08/30/97 Radiation &

Chemistry Post Accident Sampling Program Director, Plant 09/12/97 l Radiation &

l Chemistry '

i Special Nuclear Material Program Director, Engineer. 10/15/97 ing Projects

l s ., .,

(- Pronram Name Owner DueDatt Radioactive Waste Storage and Inventory ' Director, Plant 09/30/97 l -

Radiation &

l Chemistry l

Engineering and Technical Support Training Director, Mainte- 09/30/97 nance and Technical Training General Employee Training Program Director, Received l Maintenance and l Technical Training i Maintenance Training Program Director, Mainte- Received i

nance and Technical Training Emergency Response Program Director, Operations 10/31/97 i Training and j Emergency Response I I

Licensing Bases Program Director of 07/31/97 l

Licensing Design Bases Program Director, Engineer- 03/31/98 )

ing Projects  !

Quality Control Program Manager, QA 10/31/97 l

10 CFR Part 21 Program Director of 08/30/97 Licensing l Quality Assurance Program Description Manager, QA 12/31/97 ELMS / SLICE Director, Engi- 12/15/97 neering Projects l Penetrations Director, Engi-' Received neering Projects i

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s. .. . 7 f

. U-602781 Page 3  ;

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SUBJECT:

Clinton Power Station Long-Term U-602781 Improvement Plan I A.120 l 1

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bec: J. G. Cook, V-275 P. D. Yocum, T-31 A

! G. L. Baker, V-923 1

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1

)

l M. A. Reandeau. V-920 Author (s) l l Technical Validators

1. W. S. Iliff. V-928 l

1 2.

• Associated Corrective Action Document N/A l