NRC 2004-0019, Commitments in Response to 95003 Supplemental Inspection

Commitments in Response to 95003 Supplemental Inspection

ML040550516
Person / Time
Site:	Point Beach
Issue date:	02/13/2004
From:	Vanmiddlesworth G Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
95003, NRC 2004-0019
Download: ML040550516 (31)

Text

NM Committed to Nuclear Ex ce Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC February 13, 2004 NRC 2004-0019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Commitments In Response to 95003 Supplemental Inspection

Reference:

1) Letter from Nuclear Regulatory Commission to Nuclear Management Company, LLC dated February 4, 2004, transmitting Inspection Report 05000266/2003007; 05000301/2003007 EA-02-031, EA-03-057, EA-03-059, EA-03-181 Nuclear Management Company, LLC (NMC) has reviewed the 95003 Supplemental Inspection Report (Reference 1) and understands and acknowledges the inspection results. The Nuclear Regulatory Commission requested that NMC describe the actions to be taken to address the issues raised during the inspection, and provide the schedule for submission of the revised Point Beach Nuclear Plant (PBNP) Excellence Plan by February 13, 2004. This letter provides the requested information. NMC will forward an updated revision of the PBNP Excellence Plan to the NRC by February 27, 2004.

NMC has developed an Excellence Plan that provides the framework for overall improvement of station performance. NMC is committed to providing both station and fleet-wide resources to ensure the timely and quality implementation of the Excellence Plan and has established measures to monitor the effectiveness and sustainability of these enhancements. In addition, actions have been taken to strengthen the management team and elevate expectations for individual behaviors and accountability.

The commitments provided in Enclosure 1 were specifically developed by NMC to address performance issues identified in key improvement areas as a result of internal assessments and the information provided by the NRC in Reference 1. These improvement areas include human performance, nuclear oversight effectiveness, Engineering/Operations interface, operable but degraded/nonconforming condition backlog, emergency preparedness, corrective action, configuration management/design control, equipment reliability, and the auxiliary feedwater system. The commitment list 6590 Nuclear Road

• Two Rivers, Wisconsin 54241 Telephone: 920.755.2321

Document Control Desk Page 2 provided in Enclosure 1 reflects the specific Excellence Plan objectives and action plans that have been chosen to address these performance deficiencies and the critical action steps that must be accomplished. A completion date for each action plan is provided in Enclosure I and reflects the calendar year and quarter when the committed actions will be accomplished. The methods used to verify when each objective is met are also provided in Enclosure 1. These methods include the use of performance indicators, independent and self-assessments, effectiveness reviews, and documentation in the form of reports, procedures, and other records.

NMC recognizes that persistent management attention is necessary to complete the committed actions in a timely manner to achieve and sustain improved performance.

Summary of Commitments The NMC commitments associated with this response are provided in Enclosure 1.

Gary {Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure cc:

Regional Administrator, Region l1l, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector - Point Beach Nuclear Plant, USNRC

ENCLOSURE I Commitments In Response to 95003 Supplemental Inspection

HUMAN PERFORMANCE FOCUS AREA: Human Performance Action Plan: OR-01-001

Title:

Improve Human Performance and Work Practices Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed_

Human Performance OR-01-001.22 This Action Plan provides the infrastructure 1Q05 Site human performance infrastructure is established to to improve human performance at PBNP.

event clock is >36 days facilitate improved station This plan is complemented by Action Plans based on rolling 12-month performance OR-01-004 and OR-08-005, which are average intended to improve individual behaviors Components out of position and accountability. Action Plan OR-08-005 indicator is <24 events in was developed to provide additional focus 12-month rolling period to Human Performance issues in

<2 human performance Engineering.

LERs in 12-month rolling period Steps were taken to enhance infrastructure

• Effectiveness review that will for improving human performance at PBNP.

be performed upon These infrastructure enhancements have completion of included procedure revisions, formation of a Step OR-01-004.36 Human Performance Working Team, a new tool for performing job observations, and the assignment of human performance liaisons in each work group.

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Action Plan: OR-01-004

Title:

Individual Behavior Excellence l

Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p leted A PBNP 'Picture of Excellence" OR-01-004.1 Action steps to meet this plan objective 2Q04 Documented 'Picture of is developed to require OR-01-004.24 include communicating and reinforcing the Excellence" individual behaviors and

'Picture of Excellence" to improve Revised procedure NP accountability necessary to accountability and individual behaviors.

1.1.IO consistent with sustain performance Action steps to meet this plan objective are

'Picture of Excellence" improvement to validate the "Picture of Excellence" and revise the PBNP Human Performance Program to include requirements consistent with the 'Picture of Excellence."

Action Plan: OR-01-004

Title:

Individual Behavior Excellence Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed The PBNP "Picture of OR-01-004.3 Site Management will use the steps 2Q04 Completed briefing sheets Excellence" is communicated to OR-01-004.4 associated with this objective to introduce PBNP employees and the OR-01-004.6 the 'Picture of Excellence" principles to workforce is briefed on the OR-01-004.8 PBNP employees.

application of and expectations OR-01-004.9 for the program OR-01-004.10 OR-01-004.11 2 of 28

Infrastructure and tools required to execute and reinforce the "Picture of Excellence" are established OR-01-004.2 OR-01-004.5 OR-01-004.7 OR-01-004.10 OR-01-004.12 OR-01-004.13 OR-01-004.14 OR-01-004.15 OR-01-004.16 OR-01-004.17 OR-01-004.26 OR-01-004.28 OR-01-004.34 OR-01-004.35 Site Management will use the steps associated with this objective to communicate the infrastructure and tools required to ensure that the "Picture of Excellence" is established. The steps taken include the development of a database to monitor program effectiveness, incorporation of ACEMAN into daily plan of the day management meeting, implementation of a daily meeting (D-1 5) between plant supervisors and individual contributors to discuss and grade human performance. This will be the initial communication of the 'Picture of Excellence." Additional actions to improve the implementation of ACEMAN at PBNP include developing a daily communications publication and an ACEMAN observation DroCIram.

3Q04 D-15 meetings implemented and monitored using a communications survey ACEMAN job observation card implemented ACEMAN rating system employed at POD and Production meetings NOS assessment of ACEMAN implementation (Step OR-01-004.28) 3 of 28

Action Plan: OR-01-004

Title:

Individual Behavior Excellence Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C om pleted Tools to monitor effectiveness OR-01-004.18 Site management will use the steps 4Q04 Manager job observations of and recognize 'Picture of OR-01-004.19 associated with this objective to monitor the conducted to assess Excellence" program successes OR-01-004.20 effectiveness of the actions to implement ACEMAN implementation are established OR-01-004.22 the "Picture of Excellence" program.

and effectiveness OR-01-004.27 (1 observation per manager OR-01-004.33 per month)

OR-01-004.36 ACEMAN indicators reviewed at monthly Management Review Meetings Effectiveness review of ACEMAN program (Step OR-01-004.36)

ACEMAN is effectively used to OR-01-004.36 PBNP will conduct an effectiveness review 1Q05 Site human performance improve performance of station of the completed actions taken in this focus event clock is >36 days personnel area (Human Performance). This review based on a rolling 12-month will include a review of the identified average.

performance indicators to determine Components out of position whether the focus area objectives have indicator is <24 events in been met and whether improvements in this 12-month rolling period.

focus area are sustainable.

<2 human performance LERs in 12-month rolling period.

Effectiveness review of ACEMAN program (Step OR-01-004.36) 4 of 28

FOCUS AREA: Engineering Or anizational Effectiveness Action Plan: OR-08-005

Title:

Improve Human Performance in Engineering Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C om pleted_

Communicate expectations and OR-08-005.13 Actions taken to improve human 3Q04 Training attendance records provide human performance performance in the Engineering group tools to improve Engineering include: (1) An engineering Human performance Performance Improvement Team has been formed to improve human performance, (2) Engineering personnel have been trained on human performance topics, (3)

Management has established a process for identifying, evaluating, and communicating human performance events to Engineering personnel, (4) An engineering-specific observation and coaching program has also been implemented.

Additional human performance training for engineers is being conducted.

Achieve an improving trend in OR-08-005.14 Steps have been included in this action 1Q05 Improving trend in the the Engineering Event Clock OR-08-005.19 plan to further strengthen the effective use Engineering event clock performance indicator of human performance improvement tools performance indicator with a in Engineering.

goal of >10 days per rolling 12-month period Effectiveness review (Step OR-08-005.19) 5 of 28

r.

I-

NUCLEAR OVERSIGHT EFFECTIVENESS FOCUS AREA: Oversight & As essment Action Plan: OR-02-001

Title:

Nuclear Oversight Assessment Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Com pleted Improve NOS staffing OR This action plan is intended to improve 3Q04 Rotation policy implemented effectiveness by implementing a 001.2.A.1 the effectiveness of the Nuclear Oversight Assessors assigned to rotation policy, assigning OR-02-001.2.B (QA) organization in identifying problems functional areas assessors to maintain functional OR-02-001.2.C and escalating significant issues.

Qualification matrix tool area cognizance, and completed completing the personnel Action steps to achieve this objective are qualification matrix tool to assign assessors to functional areas, implement a rotation policy and implement a training plan to address staff developmental needs.

The rotation policy has been developed and is pending issuance. Training and developmental needs have been identified.

Formal issuance of the rotation policy and the functional area assignments remains to be performed. The personnel qualification matrix will be used as a guide to assign personnel to assessment activities. A preliminary list of individual functional area assignments has been developed.

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1

NOS is effective in OR-02-001.4 Development of the intrusiveness 2Q04 Intrusive methodology communicating significance methodology procedure is in progress.

procedure issued issues to Site Management The intrusiveness methodology procedure Incorporate scoring in NOS uses the problem development process quarterly exits as a format for developing and determining issue significance.

Issuance of the procedure will complete this required action.

NOS is effective in assuring OR-02-001.7.C The method for statusing and reporting 1Q04 Methodology implemented management response QA NOS QA findings has been developed.

findings The NOS staff and station management l_

have been briefed on this process.

Implement integrated OR-02-001.6 A change management plan was 3Q04 Process implemented as assessment of performance developed to implement an integrated exhibited by:

assessment of performance. Three exit Process developed meetings have been conducted. NMC People trained continues to refine the process using the fleet standard for the NOS portion of the exit meeting.

NOS is effective in identifying OR-02-001.7.E This action step ensures that the actions 4Q04 Independent assessment of major weaknesses within the taken by NOS to improve performance NOS effectiveness PBNP organization, ensuring have been effective.

(Step OR-02-001.7.E) problems are resolved, and Planned independent ensuring timely implementation assessment of corrective actions to address (Step OR-02-001.7.E) findings identifies no programmatic repeat findings from the June 2003 assessment (PBSA-03-03)

Improving trend in age of QA findings, such that no more than 3 QA findings are greater than 180 days old 7 of 28

ENGINEERING / OPERATIONS INTERFACE FOCUS AREA: Engineering Organizational Effectiveness Action Plan Number:

Title:

Utilize the Quality Review Team OR-08-007 Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Improve the quality of OR-08-007.4 PBNP site management directed the 1Q05 Quality Review Team Engineering products formation of a Quality Review Team (QRT) directed rework <15%

in 4Q02. The team selects a sample of Effectiveness Review engineering products and grades the quality (Step OR-08-007.4) of work. Feedback is provided via the CAP to the responsible engineer for products that require rework.

Action Plan: OR-08-015

Title:

Establish an Engineering Safety & Design Review Group Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Improve quality of Engineering OR-08-015.6 In addition to the Quality Review Team, an 1 Q05 Effectiveness Review products OR-08-015.7 Engineering Safety and Design Review (Step OR-08-015.7)

Group (ESDRG) has been established to improve the quality of engineering products.

The ESDRG conducts in-line independent review of engineering products.

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FOCUS AREA: Training Organizational Effectiveness Action Plan: TR-18-002

Title:

ESP Training Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p le te d A qualified Engineering TR-18-002.11 Actions have been taken to revise the 1Q05 Effectiveness review workforce supports stations Engineering Support Personnel (ESP)

(Step TR-18-002.1 1) priorities and schedules training program. These actions include: 1) a job analysis for the ESP population to identify the core qualifications required for each position has been completed; 2) a workdown curve for each engineer to complete all required qualifications has been developed; 3) new Training Advisory and Curriculum Review Committees have been established; 4) site policy on training attendance has been established and training attendance expectations reinforced.

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FOCUS AREA: Engineering Or anizational Effectiveness Action Plan: OR-08-017

Title:

Operations and Engineering Interface Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date met C om pleted_

Improve the interface between OR-08-017.1 This new plan focuses on improvement 2Q05 Operational Decision Making Operations and Engineering to OR-08-017.2 activities that reside in other Excellence Model is implemented ensure that the station priorities OR-08-017.4 Plan Action Plans, including implementation Self assessment of are reflective of actions OR-08-017.5 of the Design Review Board, Operable But effectiveness of Plant Health necessary for achievement of OR-08-017.6 Degraded/Non-conforming Backlog Committee (Step equipment excellence Reduction Plan, the Operator Burden OR-08-017.2)

Reduction Plan. The Operational Decision Self-assessment of Making Model has been incorporated into effectiveness of Design this plan.

Engineering Review Board Operable but The Plant Health Committee will be the degraded/nonconforming driving force for the successful execution of backlog reduced to <20 this Action Plan by engagement of Operations total operator Operations and Engineering personnel burden reduced to <36 using the operational decision making Corrective work order model to review system health reports, maintenance backlog <25 engineering programs, proposed Elective work order modifications, and work orders and to maintenance backlog <275 recommend corrective actions to Operations procedure equipment-related issues.

feedback backlog <450 feedbacks Maintenance procedure critical feedback backlog

<225 10 of 28

OPERABLE BUT DEGRADEDINONCOMFORMING BACKLOG FOCUS AREA: Engineering Organization Effectiveness Action Plan Number:

Title:

Reduce Operable But Degraded / Nonconforming Backlog OR-08-016 Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o rnp leted Reduce the backlog to meet the OR-08-016.3 The Plant Health Committee will be the 3Q04 Operable but NMC goal OR-08-016.4 driving force to reduce the backlog of degraded/nonconforming OR-08-016.5 operable but degraded and operable but issue tracking process nonconforming conditions at PBNP. The validates open issues are staff is executing a workdown curve that will reduced to <20 reduce the backlog to 20 or less by 3Q04.

This action plan will also reduce the number of operable but degraded/but nonconforming conditions which are older than one fuel cycle, in accordance with the NMC fleet procedure.

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EMERGENCY PREPAREDNESS FOCUS AREA: Emergency Pre aredness (EP)

Action Plan: OP-09-001

Title:

Improve EP Infrastructure (Processes, Programs)

Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p le te d Enhance knowledge of EP staff OP-09-001.12 This action plan is intended to improve 1Q05 Qualification cards for EP OP-09-001.15 overall ownership and effectiveness of staff members completed in maintaining the Emergency Preparedness accordance with defined program.

schedule

>80% of EP callups have a An EP Advisory Committee (EPAC) has primary and backup person been established that includes assigned representatives of the site leadership team.

Effectiveness review The vision and mission for EP have been (Step OP-09-001.15) developed and have been communicated to site personnel. A structured approach to ERO staffing of key positions has been implemented. An ERO training advisory committee has been established. An EP staff training program has been developed.

Training and qualification of EP staff members is in progress in accordance with the pre-defined schedule.

Define Emergency OP-09-001.11 Staff roles and responsibilities have been 4Q04

>80% of EP callups have a Preparedness staff roles and OP-09-001.15 delineated. To date, EP-related call-ups primary and backup person responsibilities have been assigned to an individual having assigned primary responsibility for activity Effectiveness review performance. Qualification of backup (OP-09-001.15) activity performers is in progress.

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Corrective Action Program OP-09-001.15 EP staff personnel have received training in 4Q04 Quarterly CAP Trend Report (CAP) in Emergency CAP expectations and implementation. A tracks effectiveness of CAP Preparedness is implemented CAP liaison has been assigned to support in Emergency Preparedness in accordance with station EP. A number of CAP documents such as and concludes CAP trends in procedures and standards evaluations and corrective actions have EP are favorable been re-reviewed for adequacy.

Effectiveness review

___O P -0 9 -0 0 1.1 5 )

Action Plan: OP-09-004

Title:

Upgrade Emergency Action Levels (EALs) l Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Com pleted Develop an EAL scheme that is OP-09-004.7 This action plan will upgrade PBNP EALs to 2Q04 Revised EALs submitted to consistent with NEI 99-01 and OP-09-004.8 the NEI 99-01 scheme and submit the NRC submit to the NRC OP-09-004.9 upgraded EALs to the NRC.

OP-09-004.10 OP-09-004.11 Once drafted, the EALs must be reviewed and approved by the Plant Onsite Review Committee as well as State and Local governmental agencies. Following these approvals, the EALs will be submitted for review and approval by the NRC.

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Action Plan: OP-09-005

Title:

Control/Maintenance of EP Required Equipment Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed EP equipment and facilities are OP-09-005.4 This action plan improves configuration 2Q05 Procedures and processes documented and controlled OP-09-005.5 control of EP equipment including are in place to control EP OP-09-005.6 equipment located at the emergency equipment and facilities OP-09-005.7 response facilities.

Effectiveness review OP-09-005.8 (Step OP-09-005.12)

OP-09-005.9 A matrix has been developed to document OP-09-005.10 equipment needed to support emergency OP-09-005.11 response. EP equipment is being assessed OP-09-005.12 to assess its reliability and maintainability.

Equipment call-ups and alarm response procedures will be updated CORRECTIVE ACTION PROGRAM FOCUS AREA: Corrective Action Program Action Plan: OP-10-001

Title:

Improve CAP Action Request Screening Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Senior plant management owns OP-10-001.14 Management has taken steps to improve 2Q04 Assessments indicate no CAP screening the CAP screening process to provide focus significant CAP prioritization and improve management oversight of the errors. Goal is to have:

program. Benchmarking of the CAP o

No level "A" events screening improvements has been misclassified performed. CAP screening team members o

>90% of "B" level events have been briefed on their roles and properly categorized responsibilities. An external assessment of the CAP screening process will be performed to ensure effectiveness of the screening process.

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Action Plan: OP-10-004

Title:

CAP Resolution Effectively Addresses Problems l Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p leted A Technical Review Panel is OP-1 0-004.12 A Technical Review Board was established 2Q04 TRP is established by established (and in place until to perform a multi-disciplined review charter the Site VP and Plant selected corrective actions to ensure that Meeting notes documenting Management agree the need no the corrective actions taken effectively periodic TRP meetings longer exists) to review selected resolve the condition identified. PBNP corrective actions to ensure the management has included a step in this actions taken effectively resolve action plan to validate the effectiveness of the issue the Technical Review Board.

Issue owners are assigned to OP-1 0-004.12 In order to ensure that there is individual 2Q04 Issue Manager Procedure significant issues accountability for corrective actions for (NP 1.1.11) issued station issues, a method to assign an "Issue

& NOS assessment of Owner" has been developed. PBNP procedure compliance and management has included a step in this effectiveness of issue action plan to validate the effectiveness of manager program this enhancement to the CAP Program.

Station personnel are aware of OP-1 0-004.12 PBNP management has taken actions to 2Q04 Employee briefings their roles and responsibilities in ensure that station personnel are aware of completed the Corrective Action Program their roles and responsibilities as they New employee training (CAP) pertain to the Corrective Action Program.

program revised PBNP management has included a step in Employee Surveys this action plan to validate the effectiveness of this enhancement to the CAP Proqram.

Managers monitor and improve OP-10-004.14 PBNP will take steps to expand the CARB 4Q04 CARB membership the health of the CAP Program membership in order to improve expanded at a station and an individual management oversight of the CAP. The

• Department level indicators department level station will create department level for the key attributes of a indicators for the key attributes of a healthy healthy corrective action corrective action program. Effectiveness program show improving reviews will be utilized to monitor the trends effectiveness of actions.

Ratio of effectiveness reviews to A & B levelCAPs 15 of 28

Corrective Action Program OP-10-004.12 Measures have been established to review 1 Q05 CAP throughput (number of improvements have led to OP-10-004.14 corrective actions to ensure the corrective open CAPs) < 1900 CAPs timely corrective actions that actions are effective in resolving problems.

• Average ACE Quality grade resolve problems is >80

• Average RCE Quality grade is >80 Action Plan: OP-10-005

Title:

Improve Trending and Use of Trending Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p leted CAP Trend Reports reflect OP A method was developed to trend code 1Q05 Quarterly Trend Reports Station Performance and 005.12 CAPs in a timely manner. Quarterly trend issued and reviewed by identify potential adverse trends OP reports were issued throughout 2003. The CARB 005.13 station will perform an effectiveness review Declining trends are of the use of CAP Trend Reports to correct identified and actions emerging issues. An effectiveness review initiated to correct will be performed to ensure that periodic performance reports are issued and reviewed by plant management and that declining performance trends are identified and actions are taken to correct performance.

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Action Plan: OP-10-006

Title:

Effective Root Cause Evaluations Objective Ste Plan Summary & Status of Complete Methods to Verify Objective Completed Action Steps Date Met Reduce recurrent problems OP-1 0-006.14 PBNP has developed a standard for 4Q04 Root Cause Evaluation through improved root cause OP-1 0-006.15 grading Root Cause Evaluations (RCE) and Quality PI average is >80 quality a checklist for Corrective Action Review Board to review RCEs. A performance indicator was established to monitor RCE quality. A continuing /refresher training course for Root Cause Evaluators will be established to ensure that RCE quality remains high. An additional close out effectiveness review by independent assessors will be performed to ensure that the actions taken to improve RCE quality have been effective.

Individuals receive instruction to OP-10-006.12 PBNP has provided refresher briefing and 4Q04 Certification records of those become root cause evaluators OP-1 0-006.14 developed a Root Cause Evaluator (RCE) selected and team leaders OP-10-006.15 certification standard. Additionally, a Documented snapshot self-process to certify Root Cause Evaluation assessment of use of multi-Team Leaders was developed. A disciplinary teams continuing /refresher training course for (Step OP-10-006.12)

Root Cause Evaluators will be established to ensure that RCE quality remains high.

An additional close out effectiveness review by independent assessors will be performed to ensure that the actions taken to improve RCE have been effective.

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Action Plan: OP-10-010

Title:

Operatinc Experience (E) Improvement Plan Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Com pleted Expectations are clearly OP-10-010.1 Expectations are formally delineated in 2Q04 Procedures reviewed and communicated OP-10-010.19 procedures OEG-007 and NP 5.3.11.

issued (OEG-007 and NP 5.3.11)

A review will be conducted to determine whether the actions taken have been effective.

OE is contained within a single OP-10-010.15 This action is complete. The OE program 2Q04 Single OE database created database OP-10-010.19 resides in a single database, T-Track.

Effectiveness review (Step OP-10-010.19)

A review will be conducted to determine whether the actions taken have been effective.

Procedures for acquiring and OP-10-010.4 Procedures OEG-007 and NP 5.3.11 2Q04 Procedures approved and processing OE are issued OP-10-010.19 have been approved and issued.

issued (OEG-007 and NP 5.3.11)

A review will be conducted to determine Effectiveness review whether the actions taken have been (Step OP-10-010.19) effective.

OE data is effectively used to OP-10-010.21 A CAP that was initiated to address 1 Q05 OE effectiveness report improve the quality of work OP-10-010.22 circumstances in which OE disseminated indicator is <1 OP-10-010.23 at daily production and planning meetings OE evaluation quality being had not been implemented in the field. A tracked second action deals with providing a Average age of open OE means such that OE can be easily evaluation is <60 days.

accessed and filtered for use by Average age of open maintenance personnel during pre-job corrective actions associated briefs. A third item conducts an with OE <150 days effectiveness review of implementation of the OE program within the Maintenance Department as well as assessing the overall effectiveness of the Action Plan.

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Action Plan: OP-10-011

Title:

Improve Effectiveness of Self Assessment Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Action StepsDateMet Benchmarking is conducted in OP-1 0-011.4.C This Action Plan is intended to strengthen 4Q04 Procedure issued which formal, systematic methods OP-10-011.4.1 certain elements of the continuous provides a formal structure against industry performance OP-10-011.9 improvement process to drive the overall for benchmarking activities station improvement process.

Benchmarking schedule adherence is >80%

A formal benchmarking procedure has been developed. Additionally, a performance indicator to monitor benchmarking effectiveness has been developed.

A review of the revised benchmarking procedure and process will be performed to ensure its effectiveness.

Data from the job observation OP-10-011.3.0 Actions taken to date have included self-4Q04 Fleet goal of >150 program is analyzed and OP-1 0-011.9 assessments to identify the specific management observations disseminated to detect and elements warranting additional attention, conducted per month prevent adverse trends implementation of a common database Quarterly analysis of job for administering the job observation observation data is prepared process, development and issuance of and issued the job observation program procedure that formalizes the process and defines standards, expectations, trending, and reporting observations.

A review of the site leadership observation program will be performed to ensure its effectiveness.

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Quality, focused self-assessments are routinely conducted OP-10-011.5.A OP-10-011.5.B OP-10-011.5.D OP-10-011.5.F OP-1 0-011.7 OP-10-011.8 OP-10-011.9 Actions taken to date have included revising the administrative procedure and process used to conduct self-assessments. The NMC fleet process for performing focused self-assessments has also been adopted.

Actions remaining to be completed include implementation of a site-wide integrated assessment reporting process, establishing a process whereby performance indicators relevant to each plant department are routinely reviewed by the departmental staffs and the conduct of an effectiveness review.

4Q04 Focused self-assessment schedule adherence is >

90%

Focused self-assessment report quality is graded >

80%

Action Plan: OP-10-013

Title:

Resolution of 2003 CAP Self-Assessment Areas for Improvement Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p leted Self-Assessment of the PBNP OP-10-013.12 A step was included in this action plan to 2Q04 Corrective actions completed for CAP program OP-10-013.16 determine the effectiveness of the changes findings from SA-CAP-2003-01 (SA-CAP-2003-01) made to the CAP program as a result of the comments/observations have July 2003 self-assessment.

been resolved 20 of 28

CONFIGURATION MANAGEMENT I DESIGN CONTROL FOCUS AREA: Conficuration Manaaement Action Plan: OP-14-001

Title:

Improve the Configuration Management Program Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C o m p leted Reduce the backlog of OP-14-001.11 A backlog of work remains to close out 2Q05 Backlog of modifications that modifications that have been in OP-14-001.11.A previously installed modifications. A have been in closeout >90 closeout greater than 90 days backlog reduction workdown curve will days since acceptance is since acceptance be developed and used as a means for reduced to <20 station management to monitor progress to assure the fleet closeout goal is met.

Configuration Management OP-14-001.12 The scope of work and list of 2Q05 Configuration Management Program guidelines and OP-14-001.15 procedures requiring revision have Interim Program guidelines and procedures to improve OP-14-001.16.A been identified. Resources necessary Progress Procedures issued per configuration management are to revise and develop procedures have Milestone schedule issued been identified.

Performance indicators, standards or health reports New or revised Configuration developed in Management Program guidelines and Step OP-14-001.15 procedures will be issued per schedule.

implemented Interim effectiveness review, including review of Configuration Management CAP trend data (Step OP-14-001.12) 21 of 28

Action Plan: OP-14-003

Title:

Validate Design Basis for High Risk Systems Action Plan Summary & Status of Complete Methods to Verify Objective Steps to be Action Steps Date Objective Met C om pleted_

Design Basis Documents OP-14-003.3 This plan will update and validate the 2Q05 Interim progress review (DBDs) for the following high OP-14-003.4 three most risk significant DBDs by 2Q05 Interim (Step OP-14-003.6.A) risk significant systems are OP-14-003.5 and the seven selected systems over an Progress DBD validation and update updated and validated: Auxiliary OP-14-003.6.A approximate 2.5 year period.

Milestone completed for Auxiliary Feedwater, Service Water, Fire Feedwater, Service Water, Protection, Emergency Diesel Owners have been assigned to the and Fire Protection by the Generators, Component selected DBDs. A schedule will be end of 2Q05 Cooling, 480 V, and 13.8 kV developed for the remaining four DBDs identified in the Action Plan.

A project plan will be created and resourced appropriately such that the AFW, Service Water and the Fire Protection System DBD validation and updates will be completed by 2Q05.

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Action Plan: OP-14-005

Title:

Validate and Integrate Calculations and Setpoints Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Calculations are upgraded to OP-14-005.2.D A project plan has been developed and 2Q05 Calculations revised, provide a clear basis for safety-OP-14-005.2.E scope of work determined. The scope of validated and issued related setpoints and to create OP-14-005.3 calculations requiring upgrade has been Cross-reference database a cross-reference for setpoints, OP-14-005.4 defined and the EOP setpoint bases developed calculations and procedures OP-14-005.5 requiring revision have been identified. A OP-14-005.6 documented technical basis is created for OP-14-005.7 safety-related calculations, including OP-14-005.8 validation of assumptions. The project OP-14-005.9 plan includes requirements to assure the OP-14-005.10 technical bases for safety-related setpoints and calculations are documented.

The primary objective of this plan is to upgrade the subject calculations. The calculation upgrades are to be completed by 2Q05. Revision of the affected EOP procedures will follow later in 2005.

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Action Plan: OP-14-007 Titie: Updated Vendor Technical Information Program (VTI) l1 Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Strengthen the VTIP program OP-14-007.4 VTIP program management is 2Q05 Procedures revised and and address issues identified in OP-14-007.5 strengthened by 1) assigning program issued a self-assessment OP-14-007.8 ownership to the Configuration Corrective actions from self-Management group; 2) revising assessment procedures used to administer VTIP; and PBSA-ENG-02-01 are

3) completing corrective actions identified resolved in self-assessment PBSA-ENG-02-01.

AUXILIARY FEEDWATER SYSTEM FOCUS AREA: Equipment Reliability (AFW)

Action Plan: EQ-15-001

Title:

Auxiliary Feedwater (AFW) Appendix R Firewall Pro ect Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Complete modifications required EQ-15-001.8 Modifications are being installed and will 2Q04 Modification installed and to resolve Auxiliary Feedwater EQ-1 5-001.9 be completed by end of 2Q04. These closed out Pump Room Appendix R issues EQ-15-001.10 modifications include the construction of a EQ-15-001.11 3-hour fire rated barrier and fire wrap of EQ-15-001.12 certain Appendix R credited electrical EQ-1 5-001.13 conduits. These modifications provide EQ-15-001.14 assurance that at last one train of safe shutdown equipment remains free of fire damage following a fire in either the north or south half of the AFW room.

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Action Plan: EQ-15-015

Title:

Auxiliary Feedwater Electrical Modifications l

Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Cornpleted AFW component power supplies EQ-15-015.5 A design basis evaluation of the AFW 1 Q05 Modifications installed, tested meet design basis requirements system identified that power supplies to and closed out (modification (plant modifications have been some components did not meet design closeout requires completion of completed; remaining work basis requirements. The purpose of this the dc calculation revision from requires the dc system action plan is to implement electrical action Plan OP-14-005) calculations to be updated modifications to address these issues.

before modification closeout)

Modifications to correct these deficiencies were installed in 2003.

Closeout of some of the modification packages is in progress pending completion of an upgrade to dc calculations being done via action plan OP-14-005. Remaining modification closeouts will occur in 1 Q05.

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FOCUS AREA: Manaement Effectiveness Action Plan: OR-05-008

Title:

AFW Root Cause Evaluation (RCE) Corrective Actions Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed The Auxiliary Feedwater Root OR-05-008.1 PBNP has completed three Root Cause 2Q05 Corrective action Cause Evaluation corrective OR-05-008.2 Evaluations related to these issues and recommendations from actions are complete and OR-05-008.3 corrective actions are being addressed RCE 01-069 Revision 1, correct the root causes and OR-05-008.4 by the PBNP management team through RCE 191 Revision 1, and contributing causes identified in OR-05-008.5 the CAP program. Corrective actions RCE 202 are determined to the RCEs included plant modifications and be complete and have organizational effectiveness effectively addressed root improvements. Necessary modifications causes and contributing for the AFW have been installed and causes design control processes have been strengthened.

An interim effectiveness review of these corrective actions will be conducted in 3Q04 and a final effectiveness assessment will be conducted in 2Q05 to assure the corrective actions taken are effective.

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EQUIPMENT RELIABILITY FOCUS AREA: EauiDment Reliability Action Plan: EQ-15-011

Title:

Bolted Fault Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed Action StpsDaee Calculations to support fault EQ-1 5-011.5 These planned analyses and 4Q04 Approved calculations protection reflect design basis modifications will improve the protection assumptions of in-plant electrical distribution systems in the event of a catastrophic electrical fault.

A large portion of the analysis work has been completed. Modifications to the 480 V electrical distribution system are in

___progress.

Bolted fault project is completed EQ-15-011.3 Modifications required to configure the 2Q05 Interim progress review in accordance with project EQ-1 5-011.12 plant in accordance with the design Interim (Step EQ-1 5-011.16) schedule EQ-1 5-011.16 calculations are in progress. A project Progress following U2R27 schedule has been established and will Milestone Project on track through continue through 2007.

2Q05 in accordance with established schedule or To assure satisfactory project progress, recovery plan is in place an interim progress review will be conducted following U2R27.

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Action Plan: EQ-15-012

Title:

Manhole and Cable Vault Flooding Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met C om pleted Implement a solution to keep the EQ-1 5-012.8 A modification is in the implementation 3Q04 Modification for dewatering cables in Maintenance Rule EQ-1 5-012.9 phase to install dewatering equipment in equipment for Manholes 1 scope manholes from becoming EQ-1 5-012.10 Manholes 1 and 2. Callups will be and 2 installed and accepted submerged established to inspect and pump Maintenance call-ups in Maintenance Rule scope manholes to place to inspect and pump preclude long-term submergence of manholes, as determined cables.

necessary, for remaining manholes containing The modification to install the dewatering Maintenance Rule scope equipment in Manholes 1 and 2 is cables scheduled for completion in 2Q04.

Effectiveness review of installed modification (Step EQ-1 5-012.9)

Action Plan: EQ-15-016

Title:

Determine Condition of Underground Cables Which Have Been Submerged Action Plan Summary & Status of Complete Methods to Verify Objective Objective Steps to be Action Steps Date Met Completed The condition of the underground EQ-1 5-016.4 Condition monitoring has been performed 1Q05 Effectiveness assessment 480 V, 4160 V and 13.8 kV EQ-1 5-016.6 on the subject cables and have been (Step EQ-15-016.6) cables that are safety-related or found to be in good condition.

Cable condition assessment provide offsite power is reports completed understood and monitored Call-ups will be established to routinely Call-ups are in place for monitor conditions of the cables to ensure future cable condition their reliability.

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