ML061070061

Letter, Point Beach Revised Confirmatory Action Letter 3-04-001

ML061070061
Person / Time
Site:	Point Beach
Issue date:	04/14/2006
From:	Caldwell J NRC/RGN-III
To:	Koehl D Nuclear Management Co
References
CAL 3-04-001
Download: ML061070061 (47)

Text

April 14, 2006 CAL 3-04-001 Mr. Dennis L. Koehl Site Vice-President Point Beach Nuclear Plant Nuclear Management Company, LLC 6590 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

CONFIRMATORY ACTION LETTER CAL 3-04-001, REVISION 1

Dear Mr. Koehl:

The Point Beach Nuclear Plant was placed in the Multiple/Repetitive Degraded Cornerstone column (Column IV) of the Nuclear Regulatory Commissions (NRC) Action Matrix during the first quarter of 2003 as a result of a Red finding for Unit 1 and Unit 2 associated with the auxiliary feedwater and instrument air systems, and a Yellow finding for Unit 1 and a Red finding for Unit 2 associated with the potential failure of the auxiliary feedwater pumps due to recirculation line orifice plugging. As a result of these findings, the NRC performed an Inspection Procedure (IP) 95003 supplemental inspection in 2003. Following the issuance of the IP 95003 report on February 4, 2004, you developed actions to improve station performance to address the original Red and Yellow findings and other findings and performance issues identified in the IP 95003 inspection. Your improvement efforts were developed and incorporated in the Point Beach Excellence Plan. After reviewing the plan and meeting with Nuclear Management Company (NMC) officials on March 15, 2004, the NRC issued the subject Confirmatory Action Letter, CAL 3-04-001, to NMC on April 21, 2004, (ADAMS Accession Number ML041130447).

The Confirmatory Action Letter documented the steps of the Excellence Plan that NMC committed to complete and the intent of the NRC to conduct periodic inspections, in addition to the normal baseline program inspections, to assess the status and confirm the effectiveness of these steps. The NRC had categorized these steps in five Areas of Regulatory Concern:

Human Performance, Engineering Design Control, Engineering/Operations Interface, Emergency Preparedness, and Corrective Action Program. In our letter to you dated September 6, 2005, (ADAMS ML052500290), we stated that our inspections, to date, had indicated that the actions taken by NMC in the Engineering/Operations Interface and Emergency Preparedness Areas of Regulatory Concern were adequate and met the commitments in CAL 3-04-001. Furthermore, we stated that the actions taken in these two areas had established reasonable assurance of sustainability. Consequently, we conducted no further review of these two areas other than that which occurred during the normal baseline program inspections.

D. Koehl To assess the remaining three Areas of Regulatory Concern (Engineering Design Control, Human Performance, and Corrective Action Program), we used the results of the inspections listed in the enclosure to this letter. These results, and our findings and observations in previous inspections, indicate that actions taken by NMC in the Human Performance Area of Regulatory Concern were adequate and met the commitments in CAL 3-04-001, and were considered to be effective. Furthermore, the actions taken in this area have established reasonable assurance of sustainability. Consequently, we plan no further review of this area other than normal baseline program inspections. In the 2005 Annual Assessment Letter, dated March 2, 2006, (ADAMS ML060620046), we informed you of our decision to close the human performance substantive cross-cutting issue.

For the Corrective Action Program Area of Regulatory Concern, we also concluded that actions and observations taken by NMC had met the commitments in CAL 3-04-001, and were considered to be effective. The actions taken by NMC to meet the commitments have adequately addressed the findings and observations identified by the NRC of the Point Beach Corrective Action Program during the IP 95003 supplemental inspection conducted in 2003 following the identification of the Red inspection findings (Inspection Report 05000266/2003007; 05000301/2003007, ADAMS ML040360104). Additionally, you committed in a letter, dated February 10, 2006, to conduct assessments of the Corrective Action Program performance every 6 months for the next 2 years, with the assessments alternately being independent (outside of NMC) assessments and self-assessments. The first assessment will be an independent assessment and will be completed by September 1, 2006. While some weaknesses have been identified in causal evaluations and the implementation of corrective actions, based on your overall progress in this area, the results of a recent Problem Identification and Resolution (PI&R) inspection, and your commitment to conduct independent and self-assessments in the future, the Agency is satisfied with your understanding of the actions necessary for continued improvements and your scope of efforts in the Corrective Action Program Area of Regulatory Concern. Accordingly, we have concluded that the actions taken in this area have established reasonable assurance of sustainability. Therefore, we plan to monitor this area through baseline program inspections including an additional PI&R inspection and additional inspections focused on the effectiveness of your assessment activities (as provided for in the Reactor Oversight Process). In the 2005 Annual Assessment Letter, dated March 2, 2006, (ADAMS ML060620046), we informed you of our decision to close the problem identification and resolution substantive cross-cutting issue.

For the Engineering Design Control Area of Regulatory Concern, our inspections have established that many of the original commitments in the April 2004 CAL were met. However, further NRC review of the Engineering Design Control Area of Regulatory Concern is warranted in order to assure that your actions taken in this CAL area are effectively implemented and a reasonable assurance of sustainability can be demonstrated. Indications that further review is warranted include: extensions of the completion dates of the calculation reconstitution project (ADAMS ML060740680); our findings and observations from the inspections listed in the enclosure to this letter and from other inspections conducted; and specific engineering related questions raised in the latter half of 2004, in 2005, and in 2006. As a follow-up action to discussions of a self-assessment of the engineering program at the public meeting on

D. Koehl February 2, 2006, you made two commitments regarding the program in a letter to the NRC, dated February 10, 2006, (ADAMS ML060440285). Specifically, these commitments were:

(1) incorporation into the Point Beach Excellence Plan of long-term improvement actions which resulted from a recent engineering assessment, as discussed at the February 2, 2006, public meeting; and (2) assessments of the performance of engineering every 6 months for the next 2-year period, with the assessments alternately being independent (outside of NMC) assessments and self-assessments. The first assessment will be an independent assessment and will be completed by August 1, 2006.

Your efforts to meet these two commitments will be reviewed during baseline inspection activities, through additional inspections to evaluate the effectiveness of your assessments, and in an expanded-scope Component Design Bases team inspection, currently scheduled for August-September 2006. In addition, we will continue to review your progress in upgrading safety-related calculations throughout the aforementioned activities.

Finally, this letter revises the April 21, 2004, Confirmatory Action Letter to close four of the five Areas of Regulatory Concern. The Engineering Design Control Area, and this revised Confirmatory Action Letter, will remain open pending a satisfactory review by the NRC of, at least, the initial implementation of the engineering assessment commitments, continued progress in the calculation upgrade project, and effectiveness of previous improvement initiatives and corrective actions in engineering. Specifically, the NMC needs to demonstrate the ability to understand and recognize complex engineering questions/problems. These matters then need to be dispositioned in an accurate and comprehensive manner, taking into account all relevant design and licensing basis information and reaching a sound, justified conclusion without the need for extensive NRC involvement. As we determined in the Inspection Procedure 95003 inspection, engineering and design control weaknesses were found to be the root causes of the Red finding associated with the auxiliary feedwater and instrument air. As a result, it will be necessary for NMC to demonstrate sustained improvements in the Engineering Design Control Area prior to the NRC closing these two Red findings.

When the NRC has concluded that your actions in the Engineering Design Control Area have established reasonable assurance of sustainability, we will evaluate whether the Red findings will be closed and whether Point Beach will remain in Column IV of the NRCs Action Matrix.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:

(1) Notify me immediately if your understanding differs from that set forth above; (2) Notify me in writing, if for any reason, you cannot complete the actions within the specified schedule in your March 31, 2005, and February 10, 2006, letters, and advise me in writing of your modified schedule in advance of the change;

D. Koehl (3) Notify me in writing if you intend to change, deviate from, or not complete any of the actions documented in your letters, prior to the change or deviation; and (4) Notify me in writing of the status of your actions by July 31, 2006.

Issuance of the revised Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of NMC, nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in the revised Confirmatory Action Letter may result in enforcement action.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and any responses you provide will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James L. Caldwell Regional Administrator Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosures:

1. Listing of Inspections to Review CAL Commitments

2. Letter from NMC to NRC, dated March 22, 2004

3. Letter from NMC to NRC, dated March 31, 2005

4. Letter from NMC to NRC, dated February 10, 2006 DISTRIBUTION:

See next page

D. Koehl (3) Notify me in writing if you intend to change, deviate from, or not complete any of the actions documented in your letters, prior to the change or deviation; and (4) Notify me in writing of the status of actions by July 31, 2006.

Issuance of the revised Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of NMC, nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in the revised Confirmatory Action Letter may result in enforcement action.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and any responses you provide will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James L. Caldwell Regional Administrator Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosures:

1. Listing of Inspections to Review CAL Commitments

2. Letter from NMC to NRC, dated March 22, 2004

3. Letter from NMC to NRC, dated March 31, 2005

4. Letter from NMC to NRC, dated February 10, 2006 DISTRIBUTION:

See next page DOCUMENT NAME:G:\POIN\Post CAL - Followup\CAL_MARCH_06_REV2.wpd G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive

• See previous concurrence To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME MKunowski*:sls PLouden* MSatorius CPederson DATE 04/06/2006 04/06/2006 04/07/2006 04/07/2006 OFFICE RIII-EICS NRR RIII RIII NAME KOBrien JDyer via email JCaldwell DATE 04/11/2006 04/14/2006 04/14/2006 OFFICIAL RECORD COPY

D. Koehl cc w/encl: F. Kuester, President and Chief Executive Officer, We Generation D. Cooper, Senior Vice President, Group Operations J. McCarthy, Site Director of Operations D. Weaver, Nuclear Asset Manager Plant Manager Regulatory Affairs Manager Training Manager Site Assessment Manager Site Engineering Director Emergency Planning Manager J. Rogoff, Vice President, Counsel & Secretary K. Duveneck, Town Chairman Town of Two Creeks Chairperson Public Service Commission of Wisconsin J. Kitsembel, Electric Division Public Service Commission of Wisconsin State Liaison Officer

D. Koehl ADAMS Distribution:

JLD CFL EMH1 LXR1 RidsNrrDirsIrib GEG KGO CAA1 RGK C. Pederson, DRS (hard copy - IRs only)

DRPIII DRSIII PLB1 JRK1 ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)

Inspections Completed to Review CAL Commitments Special engineering team inspection, conducted July 25 to August 24, 2005. Inspection Report (IR) 05000266/2005011; 05000301/2005011. Areas of Regulatory Concern reviewed: Engineering Design Control, Engineering/Operations Interface, and Corrective Action Program. ADAMS Accession Number ML052690183.

Expanded-scope Problem Identification and Resolution team inspection, conducted September 12 to October 6, 2005. IR 05000266/2005012; 05000301/2005012. Area of Regulatory Concern reviewed: Corrective Action Program. ADAMS Accession Number ML053200120.

Combined baseline team inspection of Evaluation of Changes, Tests, or Experiments and Permanent Plant Modifications, conducted December 12 to 16, 2005. IR 05000266/2005018; 05000301/2005018. Areas reviewed:

Engineering and Corrective Action Program. ADAMS Accession Number ML060240610.

3rd Quarter 2005 resident inspector integrated inspection, conducted July 1 to September 30, 2005. IR 05000266/2005010; 05000301/2005010. Areas reviewed: Engineering and Corrective Action Program. ADAMS Accession Number ML053000237.

4th Quarter 2005 resident inspector integrated inspection, conducted October 1 to December 31, 2005. IR 05000266/2005013; 05000301/2005013. Areas reviewed:

Engineering and Corrective Action Program. ADAMS Accession Number ML060410620.

Enclosure 1

Committed to Nuclear Excellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC March 22, 2004 NRC 2004-0030 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 NuclearRegulatory Commission to Nuclear Management Company, LLC dated Februaty 4, 2004, transmittingInspection Report 05000266/2003007; 0500030112003007 EA-02-031, EA-03-057, EA-03-059, EA-03-181

2) Letter from NuclearManagement Company, LLC (NMC) dated February13, 2004, Submitting NMC Commitments in Response to 95003 Supplemental Inspection On March 15, 2004, a public meeting was held at the Nuclear Regulatory Commission (NRC)

Region IlIl offices in Lisle, IL. The purpose of this meeting was to formally review the contents of the NMC submittal to the NRC dated February 13, 2004 (Reference 2) that transmitted NMC commitments in Response to the 95003 supplemental inspection (Reference 1).

It was concluded that additional clarification of some of the commitments is necessary to remove ambiguity and to ensure that the commitments are clearly understood. Accordingly, the updated commitment listing contained in the enclosure to this letter is provided. The attached updated commitment list supersedes in total the commitment list provided in our February 13, 2004, letter.

Summary of Commitments The updated NMC commitments are provided in Enclosure 1.

Gary D. Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure cc: Regional Administrator, Region IlIl, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector - Point Beach Nuclear Plant, USNRC 6590 Nuclear Road

• Two Rivers, Wisconsin 54241 1P: L; C j Telephone: 920.755.2321 Enclosure 2

bcc: G. D. Van Middlesworth J. W. Connolly (3) D. E. Cooper M. E. Holzmann F. D. Kuester(P460)

J. H. McCarthy L. A. Schofield (OSRC) P. Russell J. G. Schweitzer R. C. Milner D. F. Johnson D. A. Weaver (P346) E. J. Weinkam III File Enclosure 2

ENCLOSURE I Updated Commitments In Response to 95003 Supplemental Inspection 27 Pages Follow Enclosure 2

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

Title:

Improve Human Performance and Work Practices Objective to Pl Summary & Status of Complete Methods to Verify Objective Met Completed Action Steps Date Human Performance infrastructure OR-01-001.22 This Action Plan provides the infrastructure to 1Q05

• Site human performance event is established to facilitate improved improve human performance at PBNP. This clock isŽ>36 days based on station performance plan is complemented by Action Plans rolling 12-month average OR-01-004 and OR-08-005, which are intended * <2 human performance LERs in to improve individual behaviors and 12-month rolling period accountability. Action Plan OR-08-005 was

• Effectiveness review specified developed to provide additional focus to Human in Step OR-01-001.22 Performance issues in Engineering.

Steps were taken to enhance the infrastructure for improving human performance at PBNP.

These infrastructure enhancements have included procedure revisions, formation of a Human Performance Improvement Team, implementation of the PACE program, that provides a structured method for tracking job observations, and the assignment of Human Performance Improvement Team members in each work group. The PBNP site observation program and the electronic database used to administer the program are implemented by procedure NP 13.6.1 Action Plan: OR-01-004

Title:

Individual Behavior Excellence l Objective Atio Summary &Status of Cate Methods to Verify Objective Met C o m ple te d _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

A PBNP 'Picture of Excellence' is OR-01-004.1 Action steps to meet this plan objective include 2Q04

• Documented 'Picture of developed to require individual OR-01 -004.24 communicating and reinforcing the 'Picture of Excellence' behaviors and accountability Excellence' to improve accountability and

• Revised procedure NP 1.1.10 necessary to sustain performance individual behaviors. Action steps to meet this consistent with 'Picture of improvement plan objective are to validate the 'Picture of Excellence' Excellence' and revise the PBNP Human Performance Program to include requirements consistent with the 'Picture of Excellence."

Page 1 of 27 Enclosure 2

Action Plan: OR-01-004

Title:

Individual Behavior Excellence l Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date MethodstoVerifyObjective Met

______ ____

____ ___ ___ ___ C om pleted _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

The PBNP 'Picture of Excellence" OR-0l -004.3 Site Management will use the steps associated 2Q04 . Completed attendance sheets is communicated to PBNP OR-01-004.4 with this objective to introduce the 'Picture of at workforce briefings employees and the workforce is OR-01-004.6 Excellence' principles to PBNP employees.

briefed on the application of and OR-01 -004.8 expectations for the program OR-01 -004.9 OR-01-004.10 OR-01-004.11 Infrastructure and tools required to OR-01-004.2 Site Management will use the steps associated 3Q04

• D-15 meetings implemented execute and reinforce the 'Picture OR-01-004.5 with this objective to communicate the and monitored using a of Excellence' are established OR-01-004.7 infrastructure and tools required to ensure that communications survey OR-01-004.10 the 'Picture of Excellence" is established. The

• ACEMAN job observation card OR-01 -004.12 steps taken include the development of a implemented OR-01 -004.13 database to monitor human performance,

• ACEMAN rating system OR-01-004.14 incorporation of ACEMAN into daily plan of the employed at POD and OR-01-004.15 day management meeting, implementation of a Production meetings OR-01-004.16 daily meeting (D-15) between plant supervisors . NOS assessment of ACEMAN OR-01 -004.17 and individual contributors to communicate implementation OR-01 -004.26 about a variety of issues, including human (Step OR-01-004.28)

OR-01 -004.28 performance. This will be the initial OR-01-004.34 communication of the 'Picture of Excellence."

OR-01 -004.35 Additional actions to improve the implementation of ACEMAN at PBNP include developing a daily communications publication and an ACEMAN observation program.

Page 2 of 27 Enclosure 2

Action Plan: OR-01-004

Title:

Individual Behavior Excellence l ObjeAction Plan SumAction Steps Complete Methods to Verify Objective Met Completed Tools to monitor effectiveness of OR-01 -004.18 Site management will use the steps associated 1Q05

• Manager job observations and recognize 'Picture of OR-01-004.19 with this objective to monitor the effectiveness conducted to assess ACEMAN Excellence' program successes OR-01 -004.20 of the actions to implement the 'Picture of implementation and are established OR-01-004.22 Excellence' program. effectiveness (>30 manager OR-01 -004.27 observations of the ACEMAN OR-01-004.33 program 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 of 1Q05

• Site human performance event improve performance of station the completed actions taken in this focus area clock is >36 days based on a personnel (Human Performance). This review will include rolling 12-month average a review of the identified performance indicators * <2 human performance LERs in to determine whether the focus area objectives 12-month rolling period have been met and whether improvements in

• Effectiveness review of this focus area are sustainable. ACEMAN program (Step OR-01-004.36)

Page 3 of 27 Enclosure 2

FOCUS AREA: Engineering Organizational Effectiveness Action Plan: OR-08-005

Title:

Improve Human Performance In Engineering Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed Communicate expectations and OR-08-005.13 Actions taken to improve human performance in 3Q04

• Training attendance records provide human performance tools OR-08-005.17 the Engineering group include: (1) An to improve Engineering engineering Human Performance Improvement performance 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. Step OR-08-005.17 solicits post-training feedback to determine whether the training has been effectively communicated.

Achieve an improving trend in the OR-08-005.14 Steps have been included in this action plan to 1Q05

• Improving trend in the Engineering Event Clock OR-08-005.19 further strengthen the effective use of human Engineering event clock performance indicator performance improvement tools in Engineering. performance indicator with a goal of >10 days per rolling 12-month period

. Effectiveness review (Step OR-08-005.19)

Page 4 of 27 Enclosure 2

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

Title:

Nuclear Oversight Assessment Action Plan Summary & Status of Complete Objective Steps to be Action Steps Date Methods to Verify Objective Met Completed _

Improve NOS staffing effectiveness OR-02-001.2.A.1 This action plan is intended to improve the 3Q04

• Rotation policy implemented by implementing a rotation policy, OR-02-001.2.B effectiveness of the Nuclear Oversight (QA)

• Assessors assigned to assigning assessors to maintain OR-02-001.2.C organization in identifying problems and functional areas functional area cognizance, and escalating significant issues. . Qualification matrix tool completing the personnel completed qualification matrix tool Action steps to achieve this objective are to assign assessors to functional areas, iniplement a rotation policy and implement a training plan to address staff developmental needs.

The rotation policy has been developed and issued. Training and developmental needs have been identified.

The functional area assignments remain 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.

NOS is effective in communicating OR-02-401.4 Development of the intrusiveness 2Q04

• Intnusive methodology significant issues to Site methodology procedure is in progress. The procedure issued Management intrusiveness methodology procedure uses the problem development process as a format for developing and determining issue significance. _ -

NOS is effective in assuring OR-02-001.7.C The method for statusing and reporting NOS 1Q04

• Methodology implemented management response QA findings QA findings has been developed. The NOS staff and station management have been briefed on this process.

Page 5 of 27 Enclosure 2

Action Plan: OR-02-001

Title:

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

performance. Three exit meetings have been

• Process developed conducted. NMC continues to refine the

• Incorporate scoring in process using the fleet standard for the NOS NOS quarterly exit portion of the exit meeting. meetings NOS is effective in identifying OR-02-001.7.E This action step ensures that the actions 4Q04 . Planned independent major weaknesses within the taken by NOS to improve performance have assessment PBNP organization, ensuring been effective. (Step OR-02-001.7.E) identifies problems are resolved, and no programmatic repeat ensuring timely implementation of An assessment (PBSA-03-03) of NOS findings from the June 2003 corrective actions to address conducted in June 2003 identified two assessment (PBSA-03-03) findings programmatic findings. These findings

• Improving trend in age of QA included: (1) Nuclear Oversight and line findings, such that no more organizations have not established the than 3 QA findings are greater

.effective disciplined partnership' implied by than 180 days old and this goal the PBNP Picture of Excellence, and (2) is sustained for >6 months Nuclear Oversight-identified issues do not consistently communicate underlying problems (causes and contributors) and their associated risks. A planned follow-up assessment (Step OR-02-001.7.E) will assess if these findings have been effectively corrected.

In addition, as part of the Step OR-02-001.7E effectiveness review, an assessment will be made of Nuclear Oversight's effectiveness in identifying major weaknesses within the PBNP organization, ensuring timely implementation of corrective actions and effectiveness in ensuring problems are resolved.

Page 6 of 27 Enclosure 2

ENGINEERING I OPERATIONS INTERFACE FOCUS AREA: Enaineerina Oraanizational Effectiveness Action Plan: OR-08-007

Title:

Utilize the Quality Review Team Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Verify Objective Met

__ _ _ __ _ _ _ _ _ _ _ _ Com pleted Action__ ____Steps_ ____Date__

Improve the quality of Engineering OR-08-007.4 PBNP site management directed the formation 1Q05

• QRT-directed rework averaged products of a Quality Review Team (QRT) in 4Q02. The over 6-month period <15%

team selects a sample of engineering products

• Effectiveness Review and grades the quality of work. Feedback is (Step OR-08-007.4) 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 l Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed Improve quality of Engineering OR-08-015.6 In addition to the Quality Review Team, an 1Q05

• Effectiveness Review products OR-08-015.7 Engineering Safety and Design Review Group (Step OR-08-015.7)

(ESDRG) has been established to improve the quality of engineering products. The ESDRG conducts in-line independent review of engineering products.

Page 7 of 27 Enclosure 2

FOCUS AREA: Training Organiza ional Effectiveness Action Plan: TR-18-002

Title:

ESP Training Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed A qualified Engineering workforce TR-18-002.11 Actions have been taken to revise the 1Q05

• Effectiveness review supports station priorities and Engineering Support Personnel (ESP) training (Step TR-1 8-002.11) schedules 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.

Page 8 of 27 Enclosure 2

FOCUS AREA: Engineering Orga izational Effectiveness Action Plan: OR-08-017

Title:

Operatio s and Engineering Interface Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed 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 Plan Model is implemented ensure that the station priorities OR-08-017.4 Action Plans, including implementation of the . Self assessment of are reflective of actions necessary OR-08-017.5 Design Engineering Review Board, and effectiveness of Plant Health for achievement of equipment OR-08-017.6 Operable But Degraded/Non-conforming Committee (Step OR-08-017.2) excellence Backlog Reduction Plan. The Operational . Self-assessment of Decision Making Model has been incorporated effectiveness of Design into this plan. Engineering Review Board (Step OR-08-017.4)

The Plant Health Committee (PHC) will be the

• Operable but degraded/

driving force for the successful execution of this nonconforming condition Action Plan by engagement of Operations and backlog reduced to <20 Engineering personnel using the operational . Seven of the existing 13 decision making model to review system health Maintenance Rule (a)(1) reports, engineering programs, proposed systems will be transitioned to modifications and to recommend corrective (a)(2) status by the end of 2Q05 actions to equipment-related issues.

• Corrective work order Responsibilities for the PHC are defined in NMC maintenance backlog <25 fleet procedure PF-E-PHC-01. The PHC is the maintenance backlog <275 site focal point for equipment reliability

• Operations procedure feedback decisions. The PHC is responsible to review backlog <450 feedbacks system and program health reports, assess Maintenance procedure current site conditions, and respond to corrective feedback backlog emergent issues. <225 (Continued on next page) <225 Page 9 of 27 Enclosure 2

Action Plan: OR-08-017

Title:

Operatio s and Engineering Interface n (continued)

Action Pian Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed .

(Continued from previous page) The current schedule is to transition seven of the 13 existing Maintenance Rule (a)(1) systems to (a)(2) status by 2Q05. This schedule, however, may be subject to change if new system issues occur or are identified on any of the seven systems that would require a revision to the system (a)(1) action plan. If this occurs, the respective (a)(1) action plans will be changed accordingly. The following is the current projected dates when the seven systems will transition to (a)(2) status:

Condensate and Feed - 2Q04; Nuclear Instrumentation - 2Q04; Reactor Protection -

4Q04; Cable Spreading Room Heating, Ventilation & Air Conditioning - 4Q04; Metering, Relaying and Regulation - 2Q04; Crossover Steam Dump 4Q04; Vital Instrument Bus (120 V) - 3Q04.

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

Title:

Reduce Operable But Degraded / Nonconforming Backlog OR-08-01 6 Action Plan Objective Steps to be Summary & Status of Complete Methods to Verify Objective Met

_______________ Completed Action Steps Date Reduce the backlog to meet the OR-08-016.3 The Plant Health Committee will be a driving 3Q04

• Operable but degraded/

NMC goal OR-08-016.4 force to reduce the backlog of operable but nonconforming condition OR-08-016.5 degraded and operable but nonconforming backlog .S20 conditions at PBNP. The staff is executing a workdown curve that will 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.

Page 10 of 27 Enclosure 2

EMERGENCY PREPAREDNESS FOCUS AREA: Emergency Prepa edness (EP)

Action Plan: OP-09-001

Title:

Improve EP Infrastructure (Processes, Programs)

Objective Plan Action Steps Complete Methods to Verify Objective Met Completed Enhance knowledge of EP staff OP-09-001.12 This action plan is intended to improve overall 1Q05

• Qualification cards for EP staff OP-09-001.15 ownership and effectiveness of maintaining the members completed in Emergency Preparedness program. accordance with defined schedule An EP Advisory Committee (EPAC) has been

• Effectiveness review established that includes representatives of the (Step OP-09-001.15) site leadership team. The EPAC is chartered to provide site leadership oversight to support EP activities. The EPAC currently consists of the managers from Radiation Protection, Operations, Maintenance, Chemistry, EP, Engineering, and Human Resources.

The vision and mission for Emergency Preparedness Program have been 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 Preparedness OP-09-001.11 Staff roles and responsibilities have been 1Q05 . >80% of EP tasks (callups) staff roles and responsibilities OP-09-001.15 delineated. To date, EP-related call-ups have performed by Emergency been assigned to an individual having primary Planning staff members have a responsibility for activity performance. primary and backup person Qualification of backup activity performers is in assigned progress. . Effectiveness review (Step OP-09-001.15)

Page 11 of 27 Enclosure 2

Action Plan: OP-09.001

Title:

Improve EP Infrastructure (Processes, Programs) (continued)

Action Plan Summary & Status of Complete MethodstoVerify Objective Met Objective Steps to be Action Steps Dt ehd oVrf betv e Completed Dt Corrective Action Program (CAP) OP-09-001.15 EP staff personnel have received training in 1Q05 . Quarterly CAP Trend Report in Emergency Preparedness is CAP expectations and implementation. A CAP tracks effectiveness of CAP in implemented in accordance with liaison has been assigned to support EP. A Emergency Preparedness and station procedures and standards number of CAP documents such as evaluations demonstrates >95% on-time and corrective actions have been re-reviewed corrective actions completed; for adequacy. and >60% self-identification for CAPs.

. Effectiveness review (Step OP-09-001.15)

Action Plan: OP-09-003

Title:

Revise Emergency Plan Implementing procedures Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met C om pleted __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _

Revised Emergency Plan and OP-09-003.13 This action plan completes a review of the 3Q04

• Effectiveness Review supporting procedures are aligned Emergency Plan to assure compliance with (Step OP-09-003.13) 10 CFR 50 Appendix E and NUREG-0654. A team of plant personnel performed a review of the Emergency Plan and supporting procedures and revised to assure alignment. These procedures have been revised and issued.

ERO is trained on Emergency Plan OP-09-003.13 Training on the revised Emergency Plan and 3Q04 . Effectiveness Review and procedure revisions implementing procedure revisions has been (Step OP-09-003.13) completed. The revised procedures have been issued.

Page 12 of 27 Enclosure 2

Action Plan: OP-09-004

Title:

Upgrade Emergency Action Levels (EALs)

Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Datet Completed Develop an EAL scheme that is OP-09-004.7 This action plan will upgrade PBNP EALs to the 2Q05

• Revised EALs submitted to consistent with NEI 99-01 and OP-09-004.8 NEI 99-01 scheme and submit the upgraded NRC submit to the NRC OP-09-004.9 EALs to the NRC. . Implementation of revised EALs OP-09-004.10 within 90 days of the date NRC OP-09-004.11 Once drafted, the EALs must be reviewed and approval is obtained OP-09-004.12 approved by the Plant Onsite Review OP-09-004.13 Committee as well as State and Local governmental agencies. Following these approvals, the EALs will be submitted for review and approval by the NRC. Following site approval and submittal to the NRC, training will be conducted on upgraded EALs. The site will be prepared to implement the upgraded EALs within 90 days of NRC approval. _

Action Plan: OP-09-005

Title:

Control/lMaintenance of EP Required Equipment l Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed EP equipment and facilities are OP-09-005.4 This action plan improves configuration control 2Q05

• Procedures and processes are documented and controlled OP-09-005.5 of EP equipment including equipment located at in place to control EP OP-09-005.6 the emergency response facilities. equipment and facilities OP-09-005.7

• Effectiveness review OP-09-005.8 A matrix has been developed to document (Step OP-09-005.12)

OP-09-005.9 equipment needed to support emergency OP-09-005.10 response. EP equipment is being assessed to OP-09-005.11 assess its reliability and maintainability.

OP-09-005.12 Equipment call-ups and alarm response procedures will be updated Page 13 of 27 Enclosure 2

CORRECTIVE ACTION PROGRAM FOCUS AREA: Corrective Action Program Action Plan: OP-1 0-001

Title:

Improve CAP Action Request Screening and Prioritization Action Plan Summary &Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed Senior plant management owns OP-1 0-001.14 Management has taken steps to improve the 4004

• Assessments indicate no CAP screening CAP screening process to provide focus and significant CAP prioritization improve management oversight of the program. errors. Goal is to have:

Benchmarking of the CAP screening

• No level ZA" events improvements has been performed. CAP misclassified screening team members have been briefed on

• 290% of EBB level events their roles and responsibilities. An external properly categorized assessment of the CAP screening process will be performed to ensure effectiveness of the screening process.

Action Plan: OP-1 0-004

Title:

CAP Resolution Effectively Addresses Problems Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met Completed Dt A Technical Review Panel is OP-1 0-004.12 A Technical Review Panel was established to 3Q04

• TRP is established by charter established (and in place until the perform a multi-disciplined review selected . Meeting notes documenting Site VP and Plant Management corrective actions to ensure that the corrective periodic TRP meetings agree the need no longer exists) to actions taken effectively resolve the condition . Effectiveness Review review selected corrective actions identified. PBNP management has included a (Step OP-1 0.004.12) to ensure the actions taken step in this action plan to validate the effectively resolve the issue effectiveness of the Technical Review Board.

Issue owners are assigned to OP-1 0-004.12 In order to ensure that there is individual 3Q04

• Issue Manager Procedure significant issues OP-1 0-004.15 accountability for corrective actions for station (NP 1.1.11) issued issues, a method to assign an 'issue Owner'* NOS assessment of procedure has been developed. PBNP management has compliance and effectiveness included a step in this action plan to validate the of issue manager program effectiveness of this enhancement to the CAP

• Effectiveness Review Program. (Step OP-10-004.12)

Page 14 of 27 Enclosure 2

Action Plan: OP-1 0-004

Title:

CAP Resolution Effectively Addresses Problems (continued)

Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met

____

___ ___ ___ ___ ___ ___ C o m pleted _ _ _ _ _ _ _ _ _ _ _ _ _ _

Station personnel are aware of OP-1 0-004.12 PBNP management has taken actions to ensure 3Q04

• Employee briefings completed their roles and responsibilities in that station personnel are aware of their roles . New employee training program the Corrective Action Program and responsibilities as they pertain to the revised (CAP) Corrective Action Program. PBNP management a Employee Surveys has included a step in this action plan to

• Effectiveness Review validate the effectiveness of this enhancement (Step OP-10.004.12) to the CAP Program.

Managers monitor and improve the OP-1 0-004.14 PBNP will take steps to expand the CARB 1Q05

• CARB membership expanded health of the CAP Program at a OP-1 0-004.16 membership include representation from all . Department level indicators station and an individual major site work departments in order to improve show improving trends department level management oversight of the CAP. The station . Ratio of effectiveness reviews will create department level indicators for the to A & B level CAPs key attributes of a healthy corrective action

• Effectiveness review program. The departmental level indicators (Step OP-10004.14) include such items as: self-identification rate, evaluation age, evaluation quality, corrective action age, and backlogs. Effectiveness reviews will be utilized to monitor the effectiveness of actions. l Corrective Action Program OP-1 0-004.12 Measures have been established to review 1Q05 . CAP throughput (number of improvements have led to timely OP-1 0-004.14 corrective actions to ensure the corrective open CAPs) <2500 CAPs corrective actions that resolve actions are effective in resolving problems. . Average ACE Quality grade is problems >85 sustained over a 3-month period

• Average RCE Quality grade is

>85 sustained over a 3-month period

• Corrective Action Implementation Effectiveness indicator >80

• Effectiveness Review (Step OP-10-004.14)

Page 15 of 27 Enclosure 2

Action Plan: OP-1 0-005

Title:

Improve CAP Trending and Use of Trending Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed CAP Trend Reports reflect Station OP-1 0-005.12 A method was developed to trend code CAPs in 1Q05 . Declining trends are identified Performance and identify adverse OP-1 0-005.13 a timely manner. Quarterly trend reports were in quarterly CAP Trend Reports trends issued throughout 2003. The station will perform and actions initiated to correct an effectiveness review of the use of CAP Trend performance Reports to correct emerging issues. An

• Effectiveness review effectiveness review will be performed to ensure (Step OP-10-005.13) that periodic reports are issued and reviewed by plant management, and that declining performance trends are identified and actions are taken to correct performance.

Page 16 of 27 Enclosure 2

Action Plan: OP-10-006

Title:

Effective Root Cause Evaluations Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met Completed __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Reduce recurrent problems OP-1 0-006.14 PBNP has developed a standard for grading 1Q05 . Average RCE Quality Grade is through improved root cause OP-1 0-006.15 Root Cause Evaluations (RCE) and a checklist >85 sustained over a 3-month quality for Corrective Action Review Board to review period RCEs. A performance indicator was . Effectiveness Review established to monitor RCE quality. A (Step OP-10-006.15) 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-1 0-006.12 PBNP has provided refresher briefing and 1Q05 . Certification records of those become root cause evaluators and OP-1 0-006.14 developed a Root Cause Evaluator (RCE) selected team leaders OP-1 0-006.15 certification standard. Additionally, a process to . Documented self- assessment certify Root Cause Evaluation Team Leaders of use of multi-disciplinary was developed. A continuing /refresher training teams (Step OP-1 0-006.12) course for Root Cause Evaluators will be

• Effectiveness Review established to ensure that RCE quality remains (Step OP-10-006.15) high. An additional closeout effectiveness review by independent assessors will be performed to ensure that the actions taken to improve RCE have been effective.

Page 17 of 27 Enclosure 2

Action Plan: OP-10-010

Title:

Operating Experience (OE) Improvement Plan Action Plan Summary & Status of Complete MehdtoVryObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met

____ ____

____ ____ ____ ___ C om pleted _ _ _ _ _

Expectations are clearly OP-10-010.1 Expectations are formally delineated in 3Q04

• 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

• Effectiveness Review whether the actions taken have been (Step OP-10-010.19) effective.

OE is contained within a single OP-10-010.15 This action is complete. The OE program 3Q04

• Single OE database created database OP-10-010.19 resides in a single database, T-Track. . Effectiveness review (Step OP-10-0i0.19)

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

Procedures for acquiring and OP-1 0-010.4 Procedures OEG-007 and NP 5.3.11 have 3Q04

• Procedures approved and processing OE are issued OP-10-010.19 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 1Q05 . OE evaluation quality being improve the quality of work OP-10-010.22 circumstances in which OE disseminated at tracked OP-1 0-010.23 daily production and planning meetings had . Average age of open OE not been implemented in the field. A second evaluation is <30 days action deals with providing a means such that sustained over a 3-month OE can be easily accessed and filtered for period.

use by maintenance personnel during pre-job

• Average age of open corrective briefs. A third item conducts an effectiveness actions associated with OE review of implementation of the OE program <120 days sustained over a 3-within the Maintenance Department as well as month period assessing the overall effectiveness of the

• Effectiveness Review Action Plan. (Step OP-10-010.23)

Page 18 of 27 Enclosure 2

Action Plan: OP-10-011

Title:

Improve Effectiveness of Self Assessment Action Plan Summary & Status of Complete MeodtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met Com pleted _ _ _ ___ ;__

_ _ _ _ _ _ _ _ _ _ _ _ _

Benchmarking is conducted in OP-1 0-01 1.4.0 This Action Plan is intended to strengthen 4Q04 . Procedure issued which formal, systematic methods certain elements of the continuous provides a formal structure for against industry performance OP-1 0-011.9 improvement process to drive the overall benchmarking activities station improvement process.

• Benchmarking schedule adherence is >80%

A formal benchmarking procedure has been . Effectiveness Review developed. Additionally, a performance (Step OP-10-011.9) 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-1 0-01 1.3.0 Actions taken to date have included self- 4Q04 . An average of >325 program is analyzed and OP-1 0-01 1.9 assessments to identify the specific elements management observations per disseminated to detect adverse warranting additional attention, month (both training and field trends implementation of a common database for observations) are conducted administering the job observation process, over a sustained 3-month development and issuance of the job period observation program procedure that . Quarterly analysis of job formalizes the process and defines standards, observation data is prepared expectations, trending, and reporting and issued observations. Effectiveness Review (Step OP-10-011.9)

The PBNP site observation program is delineated in procedure NP 13.6.1. NP 13.6.1 requires job observations to be performed by managers and supervisors. The total number of managers and supervisors required by procedure to conduct the job observations is approximately 115.

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

Page 19 of 27 Enclosure 2

Action Plan: OP-10-011

Title:

Improve Effectiveness of Self Assessment (continued) l Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Methods to Verify Objective Met Completed ActionStepsDate Quality, focused self-assessments OP-1 0-011.5.A Actions taken to date have included revising 4Q04

• Focused selfassessment are routinely conducted OP-1 0-011.5.B the administrative procedure and process schedule adherence is >90%

OP-1 0-011.5.D used to conduct self-assessments. The NMC sustained for 2 quarters OP-1 0-011.5.F fleet process for performing focused self- . Focused selfassessment OP-1 0-011.7 assessments has also been adopted. report quality is graded >95%

OP-1 0-011.8 sustained for 2 quarters OP-1 0-011.9 Actions remaining to be completed include

• Effectiveness Review implementation of a site-wide integrated (Step OP-10-011.9) assessment reporting process, establishing a process whereby performance indicators relevant to each plant department are routinely reviewed by the departmental staff and the conduct of an effectiveness review.

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 Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed Self-Assessment of the PBNP CAP A step was included in this action plan to 3Q04 Corrective actions completed for program (SA-CAP-2003-01) OP-10-013.16 determine the effectiveness of the changes findings from SA-CAP-2003-01 comments/observations have been made to the CAP program as a result of the resolved July 2003 selfassessment.

Page 20 of 27 Enclosure 2

CONFIGURATION MANAGEMENT I DESIGN CONTROL FOCUS AREA: Configuration Ma agement Action Plan: OP-14-001

Title:

Improve the Configuration Management Program Objective Action Plan Steps Summary & Status of Complete Methods to Verify Objective Met to be Completed Action Steps Date Reduce the backlog of OP-1 4-001.11 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 days closeout greater than 90 days backlog reduction workdown curve will be since acceptance is reduced to since acceptance developed and used as a means for station <20 management to monitor progress to assure the closeout goal is met.

Configuration Management OP-14-001.12 The scope of work and list of procedures 2Q05

• A minimum of 40 procedures Program guidelines and OP-1 4-001.15 requiring revision have been identified. will be revised and issued by procedures to improve OP-1 4-001.16.A Resources necessary to revise and develop 2Q05 (approximately two-thirds configuration management are procedures have been identified. of total project scope) issued

• Performance indicators, New or revised Configuration Management standards or health reports Program guidelines and procedures will be developed in issued per schedule. Step OP-14-001.15 implemented Approximately 60 procedures will require

• Progress Review revision. All actions in OP-14-001 will be (Step 14-001.16.A) completed by 2Q05 with the exception of Steps 16 and 17. Step 16, which is the work to revise applicable procedures, is scheduled to be approximately two-thirds complete by 2Q05. Step 17 is the final effectiveness review. A progress status review (Step OP-14-001.16.A) will be conducted in 2Q05 to assure satisfactory progress. This progress review will validate that a minimum of 40 procedures have been revised and issued.

Page 21 of 27 Enclosure 2

Action Plan: OP-14-003

Title:

Validate De sign Basis for High Risk Systems ObJective CtiopPlte Summary & Status of Complete Methods to Verify Objective Met ObjctiepSepstoed Action Steps Date Design Basis Documents (DBDs) OP-1 4-003.3 This plan will update and validate the three 2Q05

• Interim progress review (Step for the fdlowing high risk OP-14-003.4 most risk significant DBIs by 2Q05 and the OP-1 4-003.6.A) significant systems are updated OP-1 4-003.5 seven selected systems over an approximate

• AFW DBD validation and and validated: Auxiliary Feedwater, OP-1 4-003.6.A 2.5 year period. update completed by 3004 Service Water, Fire Protection,

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

A project plan will be created and resourced appropriately such that the AFW DBD validation and update will be completed by 3Q04. The Service Water and Fire Protection System DBD validation and updates will be completed by 2Q05.

Page 22 of 27 Enclosure 2

Action Plan: OP-14-005

Title:

Validate and Integrate Calculations and Setpoints l Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date Methods to Verify Objective Met

____

___ ___ ____ ___ ___ ___ C om pleted _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Calculations are upgraded to OP-14-005.2.D A project plan has been developed and scope 2Q05

• Calculations revised, validated provide a clear basis for safety- OP-1 4-005.2.E of work determined. The scope of calculations and issued related setpoints and to create a OP-1 4-005.3 requiring upgrade will be defined and the EOP

• Cross-reference database cross-reference for setpoints, OP-1 4-005.4 setpoint bases requiring revision will be developed calculations and procedures OP-14-005.5 identified. A review of safety-related

• Progress Review OP-1 4-005.6 calculations is being performed, including (Step OP-14-005.9)

OP-1 4-005.7 validation of assumptions. The project plan OP-1 4-005.8 includes requirements to assure the technical OP-1 4-005.9 bases for safety-related setpoints and OP-14-005.10 calculations are documented.

The primary objective of this plan is to upgrade the subject calculations. The calculation upgrades are to be completed by 2Q05. All of the steps in this plan will be completed by 2Q05 except Step OP-14-005.2.F and Step OP-14-005.11. Step OP-14-005.2.F will implement revised EOP setpoints in emergency operating procedures and this work will be completed by 4Q05. A final effectiveness review, Step OP-14-005.1i, will be completed in 2006.

Step OP-1 4-005.9 is a progress review that will ensure successful completion of work scheduled by 2Q05. By 2005, the calculations will be revised, validated and issued. Also, by 2Q05 a cross-reference database will be developed.

Page 23 of 27 Enclosure 2

Action Plan: OP-14-007

Title:

Updated Vendor Technical Information Program (VTIP)

Action Plan Summary & Status of Complete Methodsto Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt

__ _ __ __ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ C om p leted__ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Strengthen the VTIP program and OP-1 4-007.4 VTIP program management is strengthened 2Q05

• Procedures revised and issued address issues identified in a self- OP-1 4-007.5 by 1) assigning program ownership to the

• Corrective actions from self-assessment OP-1 4-007.8 Configuration Management group; 2) revising assessment PBSA-ENG-02-01 procedures used to administer VTIP; and 3) are resolved completing corrective actions identified in self-assessment PBSA-ENG-02-01.

AUXILIARY FEEDWATER SYSTEM FOCUS AREA: Equipment Rellabi ity (AFW)

Action Plan: EQ-15-001

Title:

Auxiliary Feedwater (AFW) Appendix R Firewall Project Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed Complete modifications required to EQ-1 5-001.8 Modifications are being installed and will be 2Q04

• Modification installed and resolve Auxiliary Feedwater Pump EQ-1 5-001.9 completed by end of 2Q04. These closed out Room Appendix R issues EQ-1 5-001.10 modifications include the construction of a EQ-1 5-001.11 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-1 5-001.14 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 pump room.

Page 24 of 27 Enclosure 2

Action Plan: EQ-1 5-015

Title:

Auxiliary Feedwater Electrical Modifications Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed AFW component power supplies EQ-1 5-015.5 A design basis evaluation of the AFW system 3Q04 . Modifications MR 03-005 and meet design basis requirements identified that power supplies to some 03-007 closed out components did not meet design basis requirements. The purpose of this action plan is to implement electrical modifications to address these issues.

Modifications to correct these deficiencies were installed in 2003. These included modifications MR 03-005, MR 03-006 and MR 03-007.

Closeout of MR 03-006 is complete. The two remaining modifications will be closed out by 3Q04.

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

Title:

AFW Root Cause Evaluation (RCE) Corrective Actions Action Plan Summary & Status of Complete Methods to Verify Objective Met Objective Steps to be Action Steps Date MehdtoVrfObcivMt Completed .

The Auxiliary Feedwater Root OR-05-008.1 PBNP has completed three Root Cause 2Q05 . Corrective actions from Cause Evaluation corrective OR-05-008.2 Evaluations related to these issues and RCE 01-069 Revision 1, actions are complete and correct OR-05-008.3 corrective actions are being addressed by the RCE 191 Revision 1, and the root causes and contributing OR-05-008.4 PBNP management team through the CAP RCE 202 are determined to be causes identified in the RCEs OR-05-008.5 program. Corrective actions included plant complete and have effectively modifications and organizational addressed root causes and effectiveness improvements. Necessary contributing causes per modifications for the AFW have been Effectiveness Review installed and design control processes have scheduled pursuant to been strengthened. Step OR-05-008.5 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.

Page 25 of 27 Enclosure 2

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

Title:

Bolted Fault Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date to Verify Objective Met

_ _ _ __ __ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ C o m p leted__ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Calculations to support fault EQ-1 5-011.5 These planned analyses and modifications 4Q04

• Approved calculations protection reflect design basis will improve the protection of in-plant electrical assumptions 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 in EQ-1 5-011.3 Modifications required to configure the plant in 2Q05

• Interim progress review accordance with project schedule EQ-1 5-011.12 accordance with the design calculations are in (Step EQ-15-011.16) following EQ-1 5-011.16 progress. A project schedule has been U2R27 determines work established and will continue through 2007. scheduled by 2Q05 is completed.

By the end of 2Q05, Steps EQ-1 5-011.1, 3, 4, 5, 8, 12, 15, and 16 will be completed. Steps EQ-1 5-011.2, 6 and 7 will be partially completed. Work on these steps will include:

(1) Procurement and receipt of motor control center (MCC) buckets; (2) procurement and receipt of MCC bracing; (3) completion of design analysis engineering; (4) determination of scope of power panel/MCC individual breaker replacement; (5) procurement of transformer tap change material, (6) change packages are approved for 4 of 8 MCCs; (7) bracing installed on 1 MCC; and (8) buckets are replaced in 2 MCCs..

To assure satisfactory project progress, an interim progress review (Step EQ-1 5-011.16) will validate that the actions scheduled for completion by 2Q05 have been successfully performed.

Page 26 of 27 Enclosure 2

Action Plan: EQ-1 5-012

Title:

Manhole and Cable Vault Flooding Objective to be Action Steps Complete Methods to Verify Objective Met

____

___ ___ ____ ___ ___ ___ C o m pleted _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Implement a solution to keep the EQ-1 5-012.8 A modification is in the implementation phase 3Q04

• Modification for dewatering cables in Maintenance Rule scope EQ-1 5-012.9 to install dewatering equipment in Manholes equipment for Manholes I and manholes from becoming submerged I and 2. Callups will be established to 2 installed and accepted inspect and pump Maintenance Rule scope

• Maintenance call-ups in place manholes to preclude long-term to inspect and pump manholes, submergence of cables. as determined necessary, for remaining manholes containing The modification to install the dewatering Maintenance Rule scope cables equipment in Manholes I and 2 is scheduled

• Effectiveness review of installed for installation and acceptance by 2Q04. modification (Step EQ-15-012.9)

Action Plan: EQ-15-016

Title:

Determine Condition of Underground Cables Which Have Been Submerged Action Plan Summary & Status of Complete MehdtoVrfObcivMt Objective Steps to be Action Steps Date to Verify Objective Met Completed The condition of the underground EQ-1 5-016.4 Condition monitoring has been performed on 1Q05

• Effectiveness assessment 480 V, 4160 V and 13.8 kV cables EQ-15-016.6 the subject cables. The cables have been (Step EQ-15-016.6) that are safety-related or provide found to be in good condition.

• Cable condition assessment offsite power is understood and reports completed monitored Call-ups will be established to routinely

• Call-ups are in place for future monitor condition of the cables to ensure their cable condition monitoring reliability. Callups will require periodic energized partial discharge testing of 4160 V and 13.8 kV cables subject to submergence.

Page 27 of 27 Enclosure 2

Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC March 31, 2005 NRC 2005-0039 42 USC 2332 Regional Administrator Region 111 U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle. IL 60532-4352 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 CAL 3-04-001 Update on Confirmatorv Action Letter Commitments and Performance Measures

References:

(1) Nuclear Management Company, LLC Letter dated March 22,2004, "Commitments in Response to 95003 Supplemental Inspection" (2) NRC Letter dated April 21, 2004, transmitting CAL 3-04-001, "Confirmatory Action Letter" (3) NMC Letter dated November 23, 2004, "Update on Confirmatory Action Letter Commitments and Performance Measures" On March 22,2004, Nuclear Management Company, LLC (NMC) submitted proposed commitments to the U. S. Nuclear Regulatory Commission (NRC) via Reference (1). On April 21, 2004, the NRC issued CAL 3-04-001, as described by Reference (2).

Reference (2) contains provisions that the Regional Administrator, Region 111, be notified in writing if there are any changes or deviations from the actions documented in the NMC commitment letter, or if NMC cannot complete the actions within the specified schedule in advance of the change. Reference (3) provided an update on Confirmatory Action Letter (CAL) commitments and associated performance measures. This letter advises NRC of additional changes to CAL commitments and performance measures that are contained in Reference (2) and provides information as committed to in Reference (3).

There were two issues summarized as commitments in Reference (3) that required further action by NMC. These issues were:

Calculation Validation and Reconstitution Project Bolted Fault Calculations The status of the above issues is discussed in the enclosure to this letter and has resulted in revised commitments. Additionally, there are updates on CAL commitments and 6610 Nuclear Road

• Two Rivers, Wisconsin 54241 Telephone 920.755.2321 Enclosure 3

Regional Administrator, Region I l l Page 2 associated performance measures that have been the subject of discussions between representatives of NRC Region 111 and NMC on several occasions during this calendar quarter, including March 2, March 14, March 15, March 24, and March 30, 2005.

Summaw of NewlRevised Commitments

1. EQ-15-011: NMC will complete the Bolted Fault Calculations in 3Q05 in accordance with revised Action Step EQ-15-011.5.

2. OP-14-005: The deliverable for Action Step OP-14-005.2.D has been revised to reflect progress of completed calculations as of June 15, 2005. The deliverable for Action Step OP-14-005.2.E has been revised to provide a copy of the project plan describing approval requirements for the Emergency Operating Procedure (EOP) setpoint calculations.

Commitment Excellence Plans EQ-15-011 and OP-14-005 have been updated to reflect these revised commitments. Revision Six (6) of the Commitment Excellence Plan is being transmitted to the NRC Document Control Desk separate from this submittal. The individual corrective actions that direct performance of these activities have been updated to reflect the revised commitments and the individual commitments that are documented in the plant's commitment management system have been revised.

Please contact me at PBNP if there are questions regarding the information provided in this letter or its enclosure.

Dennis L. Koehl Site Vice-president, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure cc: Document Control Desk NRR Project Manager, Point Beach Nuclear Plant Enclosure 3

ENCLOSURE UPDATE TO POINT BEACH NUCLEAR PLANT CONFIRMATORY ACTION LETTER COMMITMENTS This enclosure provides a status update on Point Beach Nuclear Plant (PBNP)

Confirmatory Action Letter (CAL), CAL 3-04-001, commitments. The information provided is sequentially arranged into the relevant focus areas contained in the CAL. This letter only addresses issues where the commitment or performance measures differ from those described in Reference (2).

Human Performance -Action Plan OR-01-004 Step OR-01-004.35, "Publish department excellence plans," is a CAL commitment that was scheduled for completion during 3Q04. Plant activities associated with this commitment were completed during 3Q04. The commitment consists of three sub-steps as follows:

OR-01-004.35A, "Determine the best method for implementing department excellence plans (actual plans, matrices, or other)." This action was completed during 3Q04.

OR-O1-004.35B, "Create Department Excellence Plans." This action was completed during 3Q04.

OR-O1-004.35C, "Publish Department Excellence Plans." This action was completed during 3Q04.

As noted above, the activities associated with this CAL commitment have been completed.

However, a review of the results of this activity revealed that the continued development and implementation of individual department excellence plans were inconsistent with improving site alignment. The department excellence plans created a risk of departmental misalignment that could detract from the overall Picture of Excellence, as the departmental excellence plans were external to the Site Excellence Plan. The alignment of departments to a common understanding of station priorities and the Excellence Plan is a key enabler, which is aligned to support these priorities.

Shortly after this CAL commitment was completed, an NMC fleet initiative was undertaken to establish a common process and methodology for creating and monitoring individual site Excellence Plans. Each NMC site has developed, or is in the process of developing, an Excellence Plan. The Excellence Plan at each site is to be maintained as a "living document" via ongoing and routine reviews by the Plant Excellence Review Group (PERG). The PERG provides a forum to validate that the site is working on the right issues, with appropriate priorities and resource allocations, and that the organization is aligned. The Site Excellence Plan establishes a path toward achieving excellence in which individual departmental roles are identified.

Page 1 of 5 Enclosure 3

Enclosure Update to Point Beach Nuclear Plant Confirmatory Action Letter Commitments Enqineerina Oraanizational Effectiveness - Action Plan OR-08-17 One of the methods to verify that the objectives of Action Plan OR-08-017, Operations and Engineering Interface, have been met is that the Operations procedure feedback backlog is less than 450 feedbacks. This performance measure is currently challenged and may not be met. When this performance measure was initially proposed, Operations procedure feedbacks were counted in aggregate and there was no prioritization or classification scheme. Since that time, all feedbacks have been evaluated, classified and prioritized. In addition, requested Operations procedure changes are now individually entered as procedure change requests (PCRs) into the corrective action program. The data, however, could be affected if one procedure change affects many procedures. For example, a caution note might need to be incorporated into each units specific procedures and the caution could affect multiple pieces of equipment, and thus, many procedures.

Additionally, when this performance measure was developed, the potential scope of procedures that may require revision was not realized as the overall scope of the calculation project (OP-14-005) was not fully known. That information is now becoming available as the calculation project progresses. NMC believes this effort will likely generate a significant number of procedure changes.

As of March 28, 2005, there were 587 outstanding Operations procedure feedbacks. Ten of the feedbacks were corrective in nature, while 533 of the feedbacks were elective and there were 44 project-related feedbacks.

Emersencv Preparedness - Action Plan OP-09-004 OP-09-004 was developed to ensure an effective upgrade of the current PBNP emergency action levels (EALs) to the Nuclear Energy Institute (NEI) 99-01 scheme. The original submittal of these revised EALs occurred in accordance with the original schedule. The EALs were submitted on June 25, 2004. In response to a public meeting held on this issue between representatives of NMC and NRC on September 2,2004, revised EALs were submitted to the NRC on October 15, 2004.

Based upon discussions last week with the NRC PBNP Project Manager, it was learned that NRC approval of the revised EALs would occur no earlier than late May 2005. NMC remains committed to implementing these revised EALs within 90 days of the date NRC approval is obtained.

Corrective Action -Action Plan OP-10-004 One of the methods used to verify that the objectives of Action Plan OP-10-004, CAP Resolutions Effectively Addresses Problems, have been met is that the Corrective Action Implementation Effectiveness performance indicator would be greater than 80%.

Performance in 2Q04 was 70%; in 3Q04, it was 82%, and in 4Q04, it was 100%.

However, during 1Q05 performance dropped to 40% because three of the five Page 2 of 5 Enclosure 3

Enclosure Update to Point Beach Nuclear Plant Confirmatory Action Letter Commitments effectiveness reviews presented to the Corrective Action Review Board (CARB) were determined to be ineffective. This matter was discussed at the March 24, 2005, CARB meeting. Direction has been given to Managers and Supervisors to provide more oversight during the performance of corrective actions to prevent recurrence and effectiveness reviews. In addition, CAP063034 was initiated on March 24, 2005, by the Site Director to document, evaluate and take additional corrective actions, as necessary.

Confiauration Manaaement - Action Plan OP-14-005 The NMC letter dated November 23, 2004, (Reference (3), stated a revised completion date for the calculation upgrade project (OP-14-005) would be provided in 1Q05. Detailed schedules have been developed to reflect calculation interdependencies that affect the current CAL due date of 2Q05. The detailed schedule is available for review at PBNP.

There are four significant milestones associated with completion of the calculation upgrade project. These milestones are currently scheduled as follows:

Completion of Electrical Calculations 1Q06 Completion of Mechanical Calculations 2Q06 Completion of Instrumentation & Control (lac) Calculations 3Q06 Perform Final Effectiveness Review 2Q07 In addition to the above, interim milestone completion dates for completed calculations have been established. Action Plan OP-14-005 has been revised accordingly.

The prioritization of calculations to be reviewed was completed in an integrated manner.

This methodology included ties to interdependent calculations as necessary to logically complete calculations in an efficient manner and established specific priorities in each discipline. Specifically, EOP setpoint change calculations were established as highest I&C priority along with mechanical calculations that were tied to these I&C EOP setpoint changes. Additionally, auxiliary feedwater system calculations receive a high priority because of this systems safety significance. Finally, electrical calculations are prioritized in accordance with the bolted fault project needs and to address an open QA significant issue in the Appendix R area.

The development of the calculation program schedule did not lend itself to the establishment of a probabilistic risk assessment. However, the completion of related CAL steps to administratively restrict the use of calculations while under revision, along with controls to ensure that future calculation revisions retain interdependent links to other calculations, provides NMC with assurance that the established project timelines and milestones are appropriately risk informed.

Action Step OP-14-005.2.D was originally intended to define completion of the project at the end of 2Q05. In response to communications between NRC and NMC, the deliverable for this step has been revised to require a copy of the signature page from each calculation Page 3 of 5 Enclosure 3

Enclosure Update to Point Beach Nuclear Plant Confirmatory Action Letter Commitments that is approved by June 15, 2005, showing the approval signatures. The project schedule indicates that approximately 10% of calculations to be revised will be complete and ready for NRC review by June 30,2005.

CAP 060919 was generated on December 6,2004, to document the fact that the 2Q05 CAL date of Step OP-14-005.2.D may not be met.

Accordingly, these changes necessitate a change to CAL Commitment Action Step OP-14-005.2.D to no longer require completion of the calculation project in 2Q05.

Likewise, CAL Commitment Action Step OP-14-005.2.E was originally intended to define completion of the final review and acceptance of the revised EOP setpoint calculations.

The deliverable for this step has been revised to require a copy of the project plan describing requirements for Operations or EOP Procedure Coordinator approval of the EOP setpoint calculations. The due date for this commitment remains at 2Q05.

In addition to the above, a discussion was held with a representative of NRC Region Ill on March 15, 2005, regarding CAL Commitment Step OP-14-005.10, "Incorporate relational database into station information system." At the time Action Plan OP-14-005 was created, it was envisioned that the relational database being utilized for the calculation review phase would be utilized in the production phase with subsequent incorporation into the station's electronic document management system. The purpose of the action step was to ensure that calculation interdependencies would be identified such that when a calculation is revised, all affected and relevant calculations would be revised.

Following creation of this step, an evaluation was performed that concluded the station's electronic document management system possessed the capability to identify the calculation interdependencies and electronically link calculations. This is accomplished via a process called "path walking." Accordingly, this step will be appropriately documented and a sustainability assessment will be performed by the end of 2Q05 to justify use of the station's electronic document system as the method utilized to fulfill the requirements of Step OP-14-005.10.

Eauipment Reliability, Action Plans EQ-15-011 and EQ-15-012 EQ-15-011, Bolted Fault Calculations: Bolted fault calculations were scheduled to be completed during 1Q05. Reference (3) incorrectly identified the completion date as 4004.

In early January 2005, it was identified that there were several quality-related concerns with the software application being used to complete the short circuit and degraded voltage calculations. Corrective Action Program (CAP) action request CAP061406 was initiated on January 11, 2005, to document these issues. On February 2, 2005, additional significant inconsistencies and errors were identified in the methodology for the "AC Electrical Distribution System Model" in the software application. These issues were documented in CAPs 061829 and 061830. These CAPs were provided to and discussed with the PBNP Region Ill PBNP Project Engineer on February 9, 2005.

Page 4 of 5 Enclosure 3

Enclosure Update to Point Beach Nuclear Plant Confirmatory Action Letter Commitments On February 14, 2005, CAP 062066 was initiated to document that NMC would not meet the 1Q05 CAL commitment because of the impact of these electrical calculation software quality issues. Based upon the nature and significance of the errors and issues associated with the electrical calculation software model, the decision was made to abandon work performed to date using that application, and to develop a recovery plan, including schedule and budget, that utilizes a different software application. A recovery plan has been developed and implemented. The schedule necessitates that the due date for this CAL commitment be revised to 3Q05.

As part of continued work in this area, it was recently determined that additional data crucial to the development of the electrical system model must be obtained from the nuclear steam supply system vendor. This information is expected to provide component-specific technical data to be utilized as input into the electrical model. This information is currently expected to arrive at PBNP in late June 2005. Upon review, the completeness of this data will be confirmed and any identified deficiencies will be addressed. Due to the critical nature of acquiring this data in a complete and timely manner, NMC remains committed to completion of this project in 3Q05, but also recognizes the obligation to advise NRC of the potential for a schedule impact based on this uncertainty. NMC will keep NRC advised as to the outcome of this development.

EQ-15-012. Manhole and Cable Vault Floodinq: An effectiveness review was conducted during 3Q04 in accordance with the requirements of Action Step EQ-15-012.9. A review of the results of this effectiveness review indicated that the work performed to date was not fully effective in resolving the manhole and cable vault flooding issues. CAPO60550 was initiated to document the findings of this effectiveness review and to perform additional corrective actions.

Page 5 of 5 Enclosure 3

committed to N u d m r m e n c e Point Beach Nuclear Plant Operated by Nudear ManagementCompany, LLC February 10,2006 NRC 2006-0008 Regional Administrator Region Ill U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 2 10 Lisle, lL 605324352 Point Beach Nuclear Plant, Units 4 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Commitments for Continued Performance Improvement at Point Beach Nuclear Plant On February 2,2006, a meeting was held between representatives of Nuclear Management Company, LLC (NMC) and U. S. Nuclear Regulatory Commission (MRC)

Region Ill. The meeting focused upon additional improvements that are planned in the Engineering department and the Corrective Action Program (CAP) to ensure sustainable and predictable performance.

This letter formalizes our commitment to continued improvement to ensure sustainable and predictable performance. SpecificalIy, NMC commits to the following long-term continuous performance improvement actions at Point Beach Nuclear Plant (PBNP) over the next two-year period:

1. Corrective Action Proqram

a. Perform a Root Cause Evaluation (RCE) that evaluates the two main drivers from our recent assessment of the Corrective Action Program by March 31,2006.

b. The PBNP Excellence Plan will be revised to track the corrective actions resulting from the RCE by April 14, 2006. The Excellenoe Plan actions will be controlled by the applicable procedures and monitored by the Picture of Excellence Review Group (PERG).

6610 Nudear Road Two Rivers, W m s l n 5424j T e l e p b 920,755,232l Enclosure 4

Regional Administrator Page 2

c. Assessments of CAP performance will be performed every six months for the next two-yearperiod. The assessments will alternately be independent assessments and self-assessments. The first assessment will be an independent assessment to be performed and actions incorporated in the Point Beach Excellence Plan by September I,2006. The independent team assessments will consist of members from industry, outside of the NMC fleet, and have a host peer outside of our Performance Assessment Department.

NMC will provide the charter and members of the assessment team to the NRC prior to the start of each assessment and the results after each assessment.

2. Enaineerins De~aftmentImprovements

a. The long-term improvement actions discussed at the February 2,2006, meeting which have resulted from the recent Engineering assessment, wilt be incorporated into the Point Beach Excellence Plan by March 2,2006. The Excellence Plan actions will be controlled by the appticable procedures and monitored by the Picture of Excellence Review Group (PERG).

b. Assessments of Engineering performance will be pedormed every six months for the next two-year period. The assessments will alternately be independent assessments and self-assessments. The first assessment will be an independent assessment to be performed and actions incorporated into the Excellence Plan by August I,2006. The independent team assessments wiil consist of members from industry, outside of the NMC fleet, and have a host peer outside of Engineering. MMC will provide the charter and members of the assessment team to the NRC prior to the start of each assessment and the results after each assessment.

Please contact me at Point Beach Nuclear Plant at (920) 755-7658 if there are questions regarding the information provided in this letter or its enclosure.

I Dennis L. Koehl Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Document Control Desk NRR Project Manager, Point Beach Nuclear Plant Enclosure 4