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| issue date = 11/16/2006
| issue date = 11/16/2006
| title = Response to NRC Followup Supplemental Inspection Report; 05000528/2006010, 05000529/2006010; 05000530/2006010
| title = Response to NRC Followup Supplemental Inspection Report; 05000528/2006010, 05000529/2006010; 05000530/2006010
| author name = Levine J M
| author name = Levine J
| author affiliation = Arizona Public Service Co
| author affiliation = Arizona Public Service Co
| addressee name = Mallett B S
| addressee name = Mallett B
| addressee affiliation = NRC/RGN-IV/ORA
| addressee affiliation = NRC/RGN-IV/ORA
| docket = 05000528, 05000529, 05000530
| docket = 05000528, 05000529, 05000530
Line 14: Line 14:
| page count = 33
| page count = 33
}}
}}
See also: [[followed by::IR 05000528/2006010]]


=Text=
=Text=
{{#Wiki_filter:PAl A subsidiary  
{{#Wiki_filter:PAl                             A subsidiary ofPinnacle West CapitalCorporation James M. Levine                                         Mail Station 7602 Palo Verde Nuclear           Executive Vice President         Tel (623) 393-5300     PO Box 52034 Generating Station           Generation                       Fax (623) 393-6077     Phoenix, Arizona 85072-2034 102-05594-JM LISAB/JAP/DJS/DC E November 16, 2006 Dr. B. S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 400 Arlington, TX 76011-4005
of Pinnacle West Capital Corporation
 
James M. Levine Mail Station 7602 Palo Verde Nuclear Executive  
==Dear Sir:==
Vice President  
 
Tel (623) 393-5300 PO Box 52034 Generating  
==Subject:==
Station Generation  
Palo Verde Nuclear Generating Station (PVNGS)
Fax (623) 393-6077 Phoenix, Arizona 85072-2034
Units 1, 2, and 3 Docket Nos: 50-528, 50-529, 50-530 Response to NRC Followup Supplemental Inspection Report (05000528/2006010; 05000529/2006010; 05000530/2006010)
102-05594-JM  
The intent of this letter is to document the actions that APS is taking to address the remaining open items, as described in the NRC Followup Supplemental Inspection Report (NRC Inspection Report 50-528/529/530/2006-010), dated October 11, 2006.
LISAB/JAP/DJS/DC  
The report discussed the results of the NRC inspection using Inspection Procedure 95002 for the facility's Yellow finding. APS has modified its action plan to address comments from the NRC inspection report as well as our own concerns as we continue to monitor and adjust the plan in response to results.
E November 16, 2006 Dr. B. S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory  
The inspection report discussed the results of the ten focus areas that the inspection team reviewed. The inspection report identified that, with respect to the Yellow finding, nine of those areas are closed. APS will continue improvements in each of the nine areas and will monitor the effectiveness of those actions. The closed focus areas include:
Commission
Focus Area 1, "Procedures Did Not Contain Necessary Requirements" Focus Area 2, "Lack of Specific Provisions in the Design and Licensing Basis" Focus Area 4, "Inadequate Communication of Design Information" II
611 Ryan Plaza Dr., Suite 400 Arlington, TX 76011-4005
 
Dear Sir: Subject: Palo Verde Nuclear Generating  
U. S. Nuclear Regulatory Commission Dr. B. S. Mallett Response to NRC Followup Supplemental Inspection Report dated October 11, 2006 Page 2 Focus Area 5, "Inadequate Problem Identification and Resolution" Focus Area 6, "Limited or Weak Operating Experience Program" Focus Area 7, "Limited Experience and Training" Focus Area 8, "Limited Resources" Focus Area 9, "Limited Nuclear Assurance Department Oversight" Focus Area 10, "Limited Procedural Guidance" One focus area remaine'd open, requiring additional action:
Station (PVNGS)Units 1, 2, and 3 Docket Nos: 50-528, 50-529, 50-530 Response to NRC Followup Supplemental  
Focus Area 3, "Lack of Questioning Attitude and Technical Rigor of Individuals."
Inspection  
APS agrees that corrective actions for concerns involving questioning attitude, technical rigor, and technical review have not been fully effective. Performance measures and metrics to monitor the corrective actions that have been taken in this area had not been fully developed and, therefore, had not been effective in identifying needed adjustments to the corrective actions. These remaining issues and our actions to address them are listed in detail in the enclosure. We are confident these actions when implemented will address our and the NRC's remaining concerns for this area and will support closure of the Yellow finding.
Report (05000528/2006010;  
Two focus areas, while closed for the purposes of the 95002 inspection, also require additional actions:
05000529/2006010;  
* Focus Area 5, "Inadequate Problem Identification and Resolution." While corrective actions specific to the Yellow finding have been completed, we understand that improvement in the corrective action program is still needed. It is our understanding that future NRC reviews associated with this area will be handled under the PI & R substantive crosscutting issue. The Corrective Action Area of our Performance Improvement Plan will include the actions to address these corrective action program deficiencies.
05000530/2006010)
    " Focus Area 6, "Limited or Weak Operating Experience Program." The inspection team concluded that corrective actions did not incorporate routine use of operating experience (OE) in emergent activities. Further NRC review of corrective actions related to OE in daily activities will be performed during NRC assessment of Focus Area 3. Our actions to address these concerns are incorporated into the enclosed action plan.
The intent of this letter is to document the actions that APS is taking to address the remaining  
As discussed in the inspection report, during the September 7, 2006 public meeting, APS indicated that success measures would be developed for NRC review prior to our request for an additional NRC assessment of the Yellow finding.
open items, as described  
 
in the NRC Followup Supplemental  
U. S. Nuclear Regulatory Commission Dr. B. S. Mallett Response to NRC Followup Supplemental Inspection Report dated October 11, 2006 Page 3 The actions described in the enclosure provide the success measures for focus areas 3 and 6. The measures are currently in various stages of implementation and completion, as noted.
Inspection
APS will notify the NRC when these measures have been implemented sufficiently and show the desired results, as defined in the enclosed plan. At that time, we will request a followup inspection. The listed completion dates are for completion of the related action items and do not represent dates by which we expect to have achieved the results required to ask for a followup inspection.
Report (NRC Inspection  
The actions described in this letter represent corrective action plans; they are not considered to be regulatory commitments.
Report 50-528/529/530/2006-010), dated October 11, 2006.The report discussed  
Should you have any further questions, please contact Craig Seaman at (623) 393-5421.
the results of the NRC inspection  
Sincerely, 1A JMLISAB/JAP/DJS/DCE/gt
using Inspection  
 
Procedure 95002 for the facility's  
==Enclosure:==
Yellow finding. APS has modified its action plan to address comments from the NRC inspection  
 
report as well as our own concerns as we continue to monitor and adjust the plan in response to results.The inspection  
0 95002 Inspection Closure Action Plan cc:   B, S. Mallett         NRC Region IV Regional Administrator M. B. Fields         NRC NRR Project Manager G. G. Warnick         NRC Senior Resident Inspector for PVNGS
report discussed  
 
the results of the ten focus areas that the inspection
ENCLOSURE 95002 Inspection Closure Action Plan
team reviewed.  
 
The inspection  
95002 Inspection Closure Action Plan Action Item 1: Revise Operational Decision Making guidance (ODP- 16)
report identified  
Problem Statement: Station personnel are missing opportunities to use the Operational Decision Making process for degraded conditions.
that, with respect to the Yellow finding, nine of those areas are closed. APS will continue improvements  
Action Plan Goal: To develop additional tools for Operational Decision Making and increase the use and effectiveness of ODP-16.
in each of the nine areas and will monitor the effectiveness  
Actions Previously Taken:
of those actions. The closed focus areas include: Focus Area 1, "Procedures  
(a) Benchmarked current guidance contained in Operations ODP- 16 (Principles for Effective Operational Decision-Making and the use of Management Review Teams) with guidance from other utilities (Exelon and Entergy).
Did Not Contain Necessary  
(b) Implemented an interim change to procedure ODP-16 based on benchmarking results.
Requirements" Focus Area 2, "Lack of Specific Provisions  
Current Status: Decision Making Errors (DME) metric indicates that additional actions are required.
in the Design and Licensing  
Actions to be taken:
Basis" Focus Area 4, "Inadequate  
(a) The following actions will be taken to improve the use of ODMI process:
Communication  
E Include an assessment for emergent issues in the Shift Manager Turnover (SMTO) 0 Include an assessment for off-normal alignment in the Crew Turnover sheet.
of Design Information" I I
m Include an assessment for shift activities in the crew briefing template.
U. S. Nuclear Regulatory  
0 Brief the Operations staff on the resultant Operations Department Practice changes.
Commission
0 Perform formal training in License Operator Continuing Training (LOCT) on the Operational Decision Making process. Training to include review of case studies.
Dr. B. S. Mallett Response to NRC Followup Supplemental  
Metric Intent: To measure the number of Decisions Making Errors (DME) for Operations, Engineering, Maintenance, and site as captured via the Corrective Action Program (CRDRs).
Inspection  
Events captured in the metric that occurred pre-2006 are referred to as "Latent" and are tracked for informational purposes.
Report dated October 11, 2006 Page 2 Focus Area 5, "Inadequate  
Metrics: Site metric for Decision Making Errors
Problem Identification  
: 1. Decision Making Errors - Operations
and Resolution" Focus Area 6, "Limited or Weak Operating  
: 2. Decision Making Errors - Engineering
Experience  
: 3. Decision Making Errors - Maintenance
Program" Focus Area 7, "Limited Experience  
: 4. Decision.Making Errors - Palo Verde site
and Training" Focus Area 8, "Limited Resources" Focus Area 9, "Limited Nuclear Assurance  
: 5. Decision Making Errors - Latent Effectiveness Review: Perform a self-assessment on the effectiveness of the ODMI process by 03/30/07.
Department  
Due Date: Complete actions by 03/30/07.
Oversight" Focus Area 10, "Limited Procedural  
Page 1 of 29 11/16/06
Guidance" One focus area remaine'd  
 
open, requiring  
Metric Description Decision Making Errors Operations, Engineering, Maintenance, Palo Verde Site, Latent Criteria: The following are inputs to the overall DME metric for each group listed above.
additional  
: 1. Lack of technical rigor o A deficient product or document due to technical inaccuracies because all the facts were not gathered, the facts were incorrect, and/or the wrong conclusions were made. This includes "narrow focus" approaches to problems or solutions.
action: Focus Area 3, "Lack of Questioning  
: 2. Failure to recognize hazard, error, or deficiency o A failure to recognize a deficient or abnormal condition - unawareness.
Attitude and Technical  
: 3. Lack of questioning attitude o Information received or observed and is contrary to the expected or the norm. Some amount of knowledge-based analysis is performed, but is inadequate. Usually characterized as mindset, tunnel vision, and wrong assumptions.
Rigor of Individuals." APS agrees that corrective  
: 4. Proceeding in the face of uncertainty o Confronted with an abnormal situation or information and no gathering of facts, conclusions, and/or decision making are apparent and action is taken. Characterized as overly optimistic, overconfident, etc.
actions for concerns involving  
: 5. Non-conservative decision-making o All the facts are gathered and weighed, but the wrong or non-conservative decision is made between two or more possible solutions (e.g., production over safety margin). Characterized as "can do" attitude, inappropriate attitude, etc.
questioning  
Data ,oal:
attitude, technical  
o Site DME Metric goal is management directed.
rigor, and technical  
o Department DME Metric goal is trend only.
review have not been fully effective.  
o Latent DME Metric is information only.
Performance
Data comes from: Corrective Action Program database.
measures and metrics to monitor the corrective  
Page 2 of 29 11/16/06
actions that have been taken in this area had not been fully developed  
 
and, therefore, had not been effective  
Decision Making Errors Operations Monthly Number of Errors 10 9
in identifying  
8 7
needed adjustments  
6 5
to the corrective  
Good I1 4
actions. These remaining issues and our actions to address them are listed in detail in the enclosure.  
3 2
We are confident  
1 0
these actions when implemented  
Jan   Feb   Mar     Apr May Jun   Jul Aug Sep Oct Nov Dec 2006 Page 3 of 29 11/16/06
will address our and the NRC's remaining  
 
concerns for this area and will support closure of the Yellow finding.Two focus areas, while closed for the purposes of the 95002 inspection, also require additional  
Decision Making Errors Engineering Monthly Number of Errors 10 9
actions:* Focus Area 5, "Inadequate  
8 7
Problem Identification  
6 5
and Resolution." While corrective  
I Good 4
actions specific to the Yellow finding have been completed, we understand  
3 2
that improvement  
1 0
in the corrective  
Jan   Feb   Mar     Apr May Jun   Jul Aug Sep Oct Nov Dec 2006 Page 4 of 29 11/16/06
action program is still needed. It is our understanding  
 
that future NRC reviews associated  
Decision Making Errors Maintenance 10 9
with this area will be handled under the PI & R substantive  
8 7
crosscutting  
6 5                                                       Good I1 4
issue. The Corrective  
3 2
Action Area of our Performance  
1 0
Improvement  
Jan Feb Mar Apr May Jun   Jul Aug Sep Oct Nov Dec 2006 Page 5 of 29 11/16/06
Plan will include the actions to address these corrective  
 
action program deficiencies." Focus Area 6, "Limited or Weak Operating  
Decision Making Errors Palo Verde Site 10 9
Experience  
8 7
Program." The inspection  
6 5                                                         Good 4
team concluded  
3 2
that corrective  
1 0
actions did not incorporate  
Jan Feb Mar Apr May   Jun   Jul Aug Sep Oct Nov Dec 2006 Page 6 of 29 11/16/06
routine use of operating  
 
experience (OE) in emergent activities.  
Decision Making Errors Latent Monthly Number of Errors 10 9
Further NRC review of corrective  
8 7
actions related to OE in daily activities  
6 5
will be performed  
I Good 4
during NRC assessment  
3 2
of Focus Area 3. Our actions to address these concerns are incorporated  
1 0
into the enclosed action plan.As discussed  
Jan   Feb   Mar     Apr May Jun   Jul Aug Sep Oct- Nov Dec 2006 Page 7 of 29 11/16/06
in the inspection  
 
report, during the September  
95002 Inspection Closure Action Plan Action Item 2: Monitoring Operability Determination (OD) quality Problem Statement: Quality of Operability Determinations does not always meet site expectations.
7, 2006 public meeting, APS indicated  
Action Plan Goal: To ensure that Operability Determinations meet procedural requirements.
that success measures would be developed  
Actions Previously Taken:
for NRC review prior to our request for an additional  
(a) Established an OD Quality Review Board with Engineering, NAD, Performance Improvement and Training representation.
NRC assessment  
(b) Included results of Engineering Product Review Board (EPRB) reviews in the OD Quality metric.
of the Yellow finding.  
Current Status: Metrics indicate inconsistent use of the OD program. This will be addressed by the following actions:
U. S. Nuclear Regulatory  
Actions to be Taken:
Commission
(a) Incorporate changes to 40DP-9OP26 (Operability Determination procedure) to support new action request process roll-out.
Dr. B. S. Mallett Response to NRC Followup Supplemental  
(b) Implement changes to the OD Quality Review Board:
Inspection  
        "   Develop a charter for the OD Quality Review Board
Report dated October 11, 2006 Page 3 The actions described  
        "   Include qualifications for the OD Quality Review Board to include Shift Manager experience and an off-site/independent individual (c) Change OD Timeliness metric to include corrective action due dates.
in the enclosure  
Metric Intent: To measure the quality of Operability Determinations.
provide the success measures for focus areas 3 and 6. The measures are currently  
Metrics:
in various stages of implementation  
: 1. Operability Determination Quality
and completion, as noted.APS will notify the NRC when these measures have been implemented  
: 2. Operability Determination Timeliness Effectiveness Review: Perform a self-assessment on the effectiveness of the OD quality process by 03/30/07.
sufficiently  
Due Date: Complete actions by 03/30/07.
and show the desired results, as defined in the enclosed plan. At that time, we will request a followup inspection.  
Page 8 of 29 11/16/06
The listed completion  
 
dates are for completion  
Metric Description Operability Determination Quality Criteria:
of the related action items and do not represent  
: 1. Self identify potential challenges to operability o Number of issues identified by oversight agency.
dates by which we expect to have achieved the results required to ask for a followup inspection.
o Number of corrective action documents the CRDR Review Committee sent for control room review because initiator and leader failed to identify Control Room review required.
The actions described  
o Number of work documents not sent to Control Room that were subsequently determined to be degraded / non-conforming tech specifications systems, structures and components during weekly review by work control Senior Reactor Operator.
in this letter represent  
: 2. Timely Identification to Operations of Operability Issues o Corrective action documents that were not processed/identified to the Shift Manager within the same shift as discovery of the degraded / non-conforming condition affecting technical specifications systems, structures and components.
corrective  
o Work documents that were not identified to Shift Manager within same shift for degraded
action plans; they are not considered  
              / non-conforming conditions affecting tech specifications systems, structures and components.
to be regulatory  
: 3. Inadequate tech information or communication of information for the IOD o Does not follow requirements of section 3.2.2 of the Operability Determination procedure as a minimum.
commitments.
o Immediate Operability Determinations (IOD) not sent to responsible Engineering leader for review when Prompt Operability Determination (POD) is not requested.
Should you have any further questions, please contact Craig Seaman at (623) 393-5421.Sincerely, 1A JMLISAB/JAP/DJS/DCE/gt
          .o IOD contains inaccurate information.
Enclosure:
o IOD does not provide sufficient justification and a POD is not requested (Shift Technical Advisor / Engineering leader review)
0 95002 Inspection  
: 4. Inadequate tech information or communication of information for the POD o Does not follow requirements for POD as described in section 3.5 of OD procedure.
Closure Action Plan cc: B, S. Mallett M. B. Fields G. G. Warnick NRC Region IV Regional Administrator
o Nuclear Assurance Department / Shift Technical Advisor section leader determines POD is inadequate.
NRC NRR Project Manager NRC Senior Resident Inspector  
o Engineering Product Review Board determines POD is "unacceptable".
for PVNGS  
: 5. Shift Manager Review of POD o Shift Manager concurrence with POD conclusion is documented in the POD.
ENCLOSURE 95002 Inspection  
o Simple Quality Verification and Validation of the POD product should have caught an error but did not.
Closure Action Plan  
Data goal: Metric goal is "trend only" and management directed.
95002 Inspection  
Data comes from: Corrective Action Program database.
Closure Action Plan Action Item 1: Revise Operational  
Page 9 of 29 11/16/06
Decision Making guidance (ODP- 16)Problem Statement:  
 
Station personnel  
Operability Determination Quality Number of Operability Determinations that did not meet expectations for Quality 10 9
are missing opportunities  
8 7
to use the Operational
6 5
Decision Making process for degraded conditions.
                                                                      'I Good 4
Action Plan Goal: To develop additional  
3 2
tools for Operational  
1 0
Decision Making and increase the use and effectiveness  
Jan Feb Mar Apr May Jun   Jul Aug   Sep Oct   Nov Dec 2006 Page 10 of 29 11/16/06
of ODP-16.Actions Previously  
 
Taken: (a) Benchmarked  
Metric Description Operability Determination Timeliness Criteria: Corrective Action(s) for each Operability Determination (OD) will be completed in accordance with the schedule established by the Director of Operations.
current guidance contained  
Data goal: Number of ODs that have corrective actions that have exceeded the schedule date.
in Operations  
Data comes from: Corrective Action Program database.
ODP- 16 (Principles  
Page 11 of 29 11/16/06
for Effective Operational  
 
Decision-Making  
Operability Determination Timeliness Number of Operability Determinations that did not meet expectations for Timeliness 10 9
and the use of Management  
8 7
Review Teams) with guidance from other utilities (Exelon and Entergy).(b) Implemented  
6 5
an interim change to procedure  
                                                                    .I Good 4
ODP-16 based on benchmarking  
3 2
results.Current Status: Decision Making Errors (DME) metric indicates  
1 0
that additional  
Jan Feb Mar   Apr May Jun   Jul Aug Sep   Oct Nov Dec 2006 Page 12 of 29 11/16/06
actions are required.Actions to be taken: (a) The following  
 
actions will be taken to improve the use of ODMI process: E Include an assessment  
95002 Inspection Closure Action Plan Action Item 3: Establish reviews of Engineering work products to improve technical adequacy, rigor and questioning attitude Problem Statement: Historical issues indicate a need to monitor the quality of Engineering products and errors in process implementation, including Operability Determinations.
for emergent issues in the Shift Manager Turnover (SMTO)0 Include an assessment  
Action Plan Goal: To see a decrease in the number of Engineering decision-making errors and Engineering products that did not meet expectations per the Engineering Products Review Board (EPRB).
for off-normal  
Actions Previously Taken:
alignment  
(a) Engineering human performance tools were developed from industry benchmarking.
in the Crew Turnover sheet.m Include an assessment  
(b) Engineering and leaders have been trained on tool usage.
for shift activities  
(c) An EPRB was established and has performed quarterly quality and technical accuracy reviews of selected Engineering work products.
in the crew briefing template.0 Brief the Operations  
Current Status: Engineering does not have a formal trouble shooting guide, and EPRB currently meets quarterly.
staff on the resultant  
Actions to be Taken:
Operations  
(a) An Engineering tool is being developed to add formality and consistency to the troubleshooting process.
Department  
(b) The EPRB function is being modified to meet on a monthly basis and to become a senior Engineering leadership review/oversight group for engineering work products and human performance. A new human performance review board will continue reviews of Engineering work products.
Practice changes.0 Perform formal training in License Operator Continuing  
(c) EPRB feedback on process implementation and quality of work products is provided to Engineering management, and used to revise expectations and training to improve performance.
Training (LOCT) on the Operational  
(d) Each of the four Engineering departments assesses and monitors decision-making errors (DMEs) for their department.
Decision Making process. Training to include review of case studies.Metric Intent: To measure the number of Decisions  
Metric Intent: To monitor work product quality and decision-making errors (DME).
Making Errors (DME) for Operations, Engineering, Maintenance, and site as captured via the Corrective  
Metrics: Engineering DME metric.
Action Program (CRDRs).Events captured in the metric that occurred pre-2006 are referred to as "Latent" and are tracked for informational  
: 1. Decision-Making Errors - Engineering. Refer to Action Item 1.
purposes.Metrics: Site metric for Decision Making Errors 1. Decision Making Errors -Operations
: 2. Engineering Product Review Board Results. (Metric display is under development).
2. Decision Making Errors -Engineering
Effectiveness Review: Perform a self-assessment of the effectiveness of engineering products process by 02/01/07.
3. Decision Making Errors -Maintenance
Due Date: Complete actions by 02/01/07.
4. Decision.Making  
Page 13 of 29 11/16/06
Errors -Palo Verde site 5. Decision Making Errors -Latent Effectiveness  
 
Review: Perform a self-assessment  
Metric Description Decision-Making Errors - Engineering Engineering department decision-making errors are compiled and reflected monthly.
on the effectiveness  
Refer to Action Item 1 Page 14 of 29 11/16/06
of the ODMI process by 03/30/07.Due Date: Complete actions by 03/30/07.Page 1 of 29 11/16/06  
 
Metric Description
{DRAFT)                                   Metric Description Engineering Product Review Board Results Criteria: A minimum of 20 engineering products will be reviewed monthly. Engineering product types subject to sampling will be defined.
Decision Making Errors Operations, Engineering, Maintenance, Palo Verde Site, Latent Criteria:  
: 1. Product meets expectations
The following  
: 2. Comment(s) made, no changes required
are inputs to the overall DME metric for each group listed above.1. Lack of technical  
: 3. Product must be changed - CRDR issued
rigor o A deficient  
: 4. Margin impacted, no plant impact - CRDR issued
product or document due to technical  
: 5. Margin and plant impacted - CRDR issued Data goal: 90% or more meet criteria 1 & 2 Data comes from: Monthly Engineering Product Review Board results.
inaccuracies  
                                                                            =..DRAFT&.
because all the facts were not gathered, the facts were incorrect, and/or the wrong conclusions  
Page 15 of 29 11/16/06
were made. This includes "narrow focus" approaches  
 
to problems or solutions.
Engineering Product Review Board Results Metric Display is Under Development Page 16 of 29 11/16/06
2. Failure to recognize  
 
hazard, error, or deficiency
95002 Inspection Closure Action.Plan Action Item 4: Improve use of Operating Experience Problem Statement: Operating Experience (OE) is not consistently used for emergent issues.
o A failure to recognize  
Action Plan Goal: To reduce plant events through the use of Operating Experience thereby improving plant performance and enhancing safety.
a deficient  
Actions Previously Taken:
or abnormal condition  
(a) Completed a self assessment of the OE program.
-unawareness.
(b) Document high-tiered OE in the Corrective Action Program.
3. Lack of questioning  
(c) Developed checklist for high-tiered OE.
attitude o Information  
(d) Perform independent reviews of high-tiered OE evaluations.
received or observed and is contrary to the expected or the norm. Some amount of knowledge-based  
Current Status: Low-level OE is inconsistently used for emergent issues.
analysis is performed, but is inadequate.  
Action to be Taken:
Usually characterized  
(a) Incorporate station and industry Operating Experience into daily meetings and safety-human performance meetings.
as mindset, tunnel vision, and wrong assumptions.
(b) Publish Operating Experience Outage books prior to each refueling outage. These will outline internal and external Operating Experience and the behaviors to prevent occurrence.
4. Proceeding  
(c) Revise Standard and Expectations Books to include specific expectations and desired behaviors for the use of Operating Experience.
in the face of uncertainty
(d) Implement a station graded approach for the use of OE and reverse pre-job briefing process for normal and emergent work.
o Confronted  
(e) Add OE to work packages for normal and emergent work.
with an abnormal situation  
(f) Make search engines more available to employees to make searching for OE easier.
or information  
Metric Intent: To measure Palo Verde's use of OE on emergent issues.
and no gathering  
Metrics: Operation Experience (OE)
of facts, conclusions, and/or decision making are apparent and action is taken. Characterized  
: 1. OE Use Observations
as overly optimistic, overconfident, etc.5. Non-conservative  
: 2. Inadequate Use of OE Effectiveness Review: Conduct effectiveness review/self-assessment to include how/when OE is being used.
decision-making
Due Date: Complete actions by 06/01/07.
o All the facts are gathered and weighed, but the wrong or non-conservative  
Page 17 of 29 11/16/06
decision is made between two or more possible solutions (e.g., production  
 
over safety margin). Characterized  
Metric Description OE Use Observations Criteria: Percentage of field observations in which OE was appropriately utilized or discussed.
as "can do" attitude, inappropriate  
Data 2oal: Percentage of observations in which OE use or discussion meets or exceeds 90 percent of the opportunities. Goal is set by management.
attitude, etc.Data ,oal: o Site DME Metric goal is management  
Data comes from: Performance Improvement Team, field, and management observation programs.
directed.o Department  
Page 18 of 29 11/16/06
DME Metric goal is trend only.o Latent DME Metric is information  
 
only.Data comes from: Corrective  
OE Use Observations Percentage of Observations that incorporated Adequate OE Percent 100 90 80 70 60 50                                                                 Good I
Action Program database.Page 2 of 29 11/16/06  
40 30 20 10 0
Decision Making Errors Operations
Jan   Feb Mar Apr May   Jun     Jul Aug Sep Oct Nov   Dec 2006 Page 19 of 29 11/16/06
Monthly Number of Errors 10 9 8 7 6 5 4 3 2 1 0 I1 Good Jan Feb Mar Apr May Jun Jul Aug Sep 2006 Oct Nov Dec Page 3 of 29 11/16/06  
 
Decision Making Errors Engineering
Metric Description Inadequate Use of OE Criteria: Inadequate use/evaluation/implementation/etc. of Operating Experience - either Industry OE or Palo Verde OE. Specifically - inadequate use/evaluation/implementation, etc. of industry or Palo Verde OE that could have prevented a Palo Verde site or department clock reset.
Monthly Number of Errors 10 9 8 7 6 5 4 3 2 1 0 I Good Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 4 of 29 11/16/06  
Data 2oal: For "trend only" on an interim basis.
Decision Making Errors Maintenance
Data comes from: A review of Apparent Cause Evaluation and Significant CRDR Evaluation events looking for missed opportunities for Operating Experience use.
10 9 8 7 6 5 4 3 2 1 0 I1 Good Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 5 of 29 11/16/06  
Page 20 of 29 11/16/06
Decision Making Errors Palo Verde Site 10 9 8 7 6 5 4 3 2 1 0 Good Jan Feb Mar Apr May Jun Jul Aug Sep 2006 Oct Nov Dec Page 6 of 29 11/16/06  
 
Decision Making Errors Latent Monthly Number of Errors 10 9 8 7 6 5 4 3 2 1 0 I Good Jan Feb Mar Apr May Jun Jul 2006 Aug Sep Oct- Nov Dec Page 7 of 29 11/16/06  
Inadequate Use of OE Number of events that could have been prevented by using available OE Events 10 9
95002 Inspection  
8 7
Closure Action Plan Action Item 2: Monitoring  
6 5
Operability  
Good
Determination (OD) quality Problem Statement:  
                                                                        'I 4
Quality of Operability  
3 2
Determinations  
1 0
does not always meet site expectations.
Feb   Feb Mar Apr   May Jun Jul Aug   Sep Oct Nov Dec 2006 Page 21 of 29 11/16/06
Action Plan Goal: To ensure that Operability  
 
Determinations  
95002 Inspection Closure Action Plan Action item 5: Establish a formal plant walkdown process Problem Statement: Identification of degraded / non-conforming conditions has not been consistently achieved.
meet procedural  
Action Plan Goal: To ensure that the appropriate plant personnel, such as Auxiliary Operators (AOs), plant engineers and system engineers, identify degraded / non-conforming systems, structures, or components.
requirements.
Actions Previously Taken:
Actions Previously  
(a) Implemented a program to walk down safety-significant systems weekly (as defined in procedure 79DP-9ZZ02) on a 12-week schedule. This walkdown is performed by Operations and Engineering.
Taken: (a) Established  
Current Status: Formalizing the program and the training to ensure that appropriate plant personnel identify these types of conditions.
an OD Quality Review Board with Engineering, NAD, Performance
Actions to be Taken:
Improvement  
(a) Create a "stand-alone" procedure to walk down safety-significant systems weekly on a 12-week schedule.
and Training representation.(b) Included results of Engineering  
        " Add instructions to identify personnel safety issues and other common walkdown areas of interest.
Product Review Board (EPRB) reviews in the OD Quality metric.Current Status: Metrics indicate inconsistent  
        " Develop a plant walkdown pre-job brief to ensure consistency of issues identified in the walkdowns.
use of the OD program. This will be addressed  
        "   Include Maintenance Fix It Now (FIN) team in the weekly walkdowns.
by the following  
        " Coordinate weekly schedule with Maintenance and Engineering.
actions: Actions to be Taken: (a) Incorporate  
(b) Provide plant walkdown classroom training for AOs.
changes to 40DP-9OP26 (Operability  
(c) Develop and administer a practical demonstration of plant walkdowns to the AOs.
Determination  
(d) Provide additional plant Walkdown training to improve general knowledge of walkdown expectations for STAs, FIN, Maintenance Engineers and System Engineers.
procedure)  
(e) Develop a metric to monitor performance.
to support new action request process roll-out.(b) Implement  
Metric Intent: To measure the number of degraded / non-conforming issues identified by the walkdown teams and NAD.
changes to the OD Quality Review Board: " Develop a charter for the OD Quality Review Board" Include qualifications  
Metrics:
for the OD Quality Review Board to include Shift Manager experience  
: 1. Safety-Significant Systems Walkdowns - Operations / Engineering Walkdown Teams.
and an off-site/independent  
: 2. Safety-Significant Systems Walkdowns - Nuclear Assurance Department Walkdown Teams.
individual (c) Change OD Timeliness  
Effectiveness Review: Perform an effectiveness review of plant walkdowns.
metric to include corrective  
Due Date: Complete actions by 03/30/07.
action due dates.Metric Intent: To measure the quality of Operability  
Page 22 of 29 11/16/06
Determinations.
 
Metrics: 1. Operability  
Metric Description Safety-Sihnificant Systems Walkdowns - Operations / Engineering Walkdown Teams Criteria: Degraded / non-conforming conditions identified by Operations / Engineering walkdown teams.
Determination  
Data Goal: Progressively fewer degraded / non-conforming conditions identified over time -
Quality 2. Operability  
management directed goal.
Determination  
Data comes from: Operations / Engineering walkdowns and resultant corrective action document(s).
Timeliness
Page 23 of 29 11/16/06
Effectiveness  
 
Review: Perform a self-assessment  
Safety-Significant Systems Walkdowns Operations / Engineering Walkdown Teams Number of Degraded / Non-Conforming Conditions Identified 10 9
on the effectiveness  
8 7
of the OD quality process by 03/30/07.Due Date: Complete actions by 03/30/07.Page 8 of 29 11/16/06  
6 5                                                                             Good I
Metric Description
4 3
Operability  
2 1
Determination  
0 Jan   Feb   Mar   Apr May   Jun   Jul   Aug     Sep Oct Nov Dec 2006 Page 24 of 29 11/16/06
Quality Criteria: 1. Self identify potential  
 
challenges  
Metric Description Safety-Significant Systems Walkdowns - Nuclear Assurance Department Walkdown Teams Criteria: Degraded / non-conforming conditions, identified by Nuclear Assurance Department (NAD),
to operability
not previously identified by Operations / Engineering walkdown teams.
o Number of issues identified  
Data Goal: Progressively fewer degraded / non-conforming conditions identified over time -
by oversight  
management directed goal.
agency.o Number of corrective  
Data comes from: NAD walkdowns and resultant corrective action document(s).
action documents  
Page 25 of 29 11/16/06
the CRDR Review Committee  
 
sent for control room review because initiator  
Safety-Significant Systems Walkdowns Nuclear Assurance Department Walkdown Teams 10 9
and leader failed to identify Control Room review required.o Number of work documents  
8 7
not sent to Control Room that were subsequently  
6 5
determined
I1 Good 4
to be degraded / non-conforming  
3 2
tech specifications  
1 0
systems, structures  
Jan Feb Mar   Apr May Jun   Jul Aug Sep Oct Nov Dec 2006 Page 26 of 29 11/16/06
and components
 
during weekly review by work control Senior Reactor Operator.2. Timely Identification  
95002 Inspection Closure Action Plan Action Item 6: Palo Verde independent review of plant walkdown results Problem Statement: The walkdown process is new and Nuclear Assurance Department (NAD) oversight is needed to ensure identification of degraded / non-conforming conditions by plant walkdown teams.
to Operations  
Action Plan Goal: To see a decrease in the number of degraded / non-conforming systems, structures, or components identified by NAD and not previously noted by the line or from the formal integrated walkdown teams.
of Operability  
Actions Previously Taken:
Issues o Corrective  
(a) Utilizing the NAD Find It Now (FIN) team to conduct independent walkdowns, after the weekly plant walkdown team.
action documents  
Current Status: Performing walkdowns.
that were not processed/identified  
Actions to be Taken:
to the Shift Manager within the same shift as discovery  
: 1. Observe and evaluate training described in Action Item 5.
of the degraded / non-conforming  
Metric Intent: To measure the number of degraded / non-conforming systems, structures, or components identified by NAD and not previously noted by the line from the formal integrated walkdown teams.
condition  
Metric: Refer to Action Item 5 for metric.
affecting technical  
Effectiveness Review: Continuing monitoring will be conducted.
specifications  
Due Date: Complete actions by 03/30/07.
systems, structures  
Page 27 of 29 11/16/06
and components.
 
o Work documents  
95002 Inspection Closure Action Plan Action Item 7: Perform a review of 95002 metrics (10 Focus Areas) to ensure compliance with the metric guideline Problem Statement: A review of the 95002 metrics /performance indicators has indicated that a consistent methodology was not used to develop metrics. Some metrics were not effective.
that were not identified  
Action Plan Goal: To make 95002 metrics consistent and effective.
to Shift Manager within same shift for degraded/ non-conforming  
Actions Previously Taken:
conditions  
(a) Performed a review of each 95002 Focus Area metric.
affecting  
(b) Adjusted metric with appropriate management review and approval.
tech specifications  
(c) Conducted independent review of 95002 metrics.
systems, structures  
Current Status: Review of the 95002 metrics indicates that three metrics require adjustment.
and components.
Actions to be Taken:
3. Inadequate  
: 1. Adjust the three metrics.
tech information  
Due Date: Complete actions by 12/1/06.
or communication  
Page 28 of 29 11/16/06
of information  
 
for the IOD o Does not follow requirements  
95002 Inspection Closure Action Plan 95002 Inspection Readiness Review Evaluate the readiness for a 95002 inspection. The criteria are:
of section 3.2.2 of the Operability  
(a) Actions above are completed or progressing satisfactorily, (b) Metrics and data streams that supply them have been independently verified to accurately portray actual performance (c) Metrics are either satisfactory or improving. Monitor and adjust actions will be taken for performance that is declining or not improving.
Determination  
Actions to be Taken (a) Develop effectiveness and inspection readiness plan.
procedure as a minimum.o Immediate  
(b) Assemble a team to conduct a readiness review, which should include two industry individuals.
Operability  
(c) Evaluate completed readiness review results and determine if additional actions are required.
Determinations (IOD) not sent to responsible  
Metrics/Measures: Closure of 95002 NRC finding.
Engineering  
Due Date: To be determined based on Metric results.
leader for review when Prompt Operability  
Page 29 of 29 11/16/06}}
Determination (POD) is not requested..o IOD contains inaccurate  
information.
o IOD does not provide sufficient  
justification  
and a POD is not requested (Shift Technical Advisor / Engineering  
leader review)4. Inadequate  
tech information  
or communication  
of information  
for the POD o Does not follow requirements  
for POD as described  
in section 3.5 of OD procedure.
o Nuclear Assurance  
Department  
/ Shift Technical  
Advisor section leader determines  
POD is inadequate.
o Engineering  
Product Review Board determines  
POD is "unacceptable".
5. Shift Manager Review of POD o Shift Manager concurrence  
with POD conclusion  
is documented  
in the POD.o Simple Quality Verification  
and Validation  
of the POD product should have caught an error but did not.Data goal: Metric goal is "trend only" and management  
directed.Data comes from: Corrective  
Action Program database.Page 9 of 29 11/16/06  
Operability  
Determination  
Quality Number of Operability  
Determinations  
that did not meet expectations  
for Quality 10 9 8 7 6 5 4 3 2 1 0'I Good Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 10 of 29 11/16/06  
Metric Description
Operability  
Determination  
Timeliness
Criteria:  
Corrective  
Action(s)  
for each Operability  
Determination (OD) will be completed  
in accordance  
with the schedule established  
by the Director of Operations.
Data goal: Number of ODs that have corrective  
actions that have exceeded the schedule date.Data comes from: Corrective  
Action Program database.Page 11 of 29 11/16/06  
Operability  
Determination  
Timeliness
Number of Operability  
Determinations  
that did not meet expectations  
for Timeliness
10 9 8 7 6 5 4 3 2 1 0.I Good Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 12 of 29 11/16/06  
95002 Inspection  
Closure Action Plan Action Item 3: Establish  
reviews of Engineering  
work products to improve technical  
adequacy, rigor and questioning  
attitude Problem Statement:  
Historical  
issues indicate a need to monitor the quality of Engineering
products and errors in process implementation, including  
Operability  
Determinations.
Action Plan Goal: To see a decrease in the number of Engineering  
decision-making  
errors and Engineering  
products that did not meet expectations  
per the Engineering  
Products Review Board (EPRB).Actions Previously  
Taken: (a) Engineering  
human performance  
tools were developed  
from industry benchmarking.(b) Engineering  
and leaders have been trained on tool usage.(c) An EPRB was established  
and has performed  
quarterly  
quality and technical  
accuracy reviews of selected Engineering  
work products.Current Status: Engineering  
does not have a formal trouble shooting guide, and EPRB currently  
meets quarterly.
Actions to be Taken: (a) An Engineering  
tool is being developed  
to add formality  
and consistency  
to the troubleshooting  
process.(b) The EPRB function is being modified to meet on a monthly basis and to become a senior Engineering  
leadership  
review/oversight  
group for engineering  
work products and human performance.  
A new human performance  
review board will continue reviews of Engineering  
work products.(c) EPRB feedback on process implementation  
and quality of work products is provided to Engineering  
management, and used to revise expectations  
and training to improve performance.(d) Each of the four Engineering  
departments  
assesses and monitors decision-making  
errors (DMEs) for their department.
Metric Intent: To monitor work product quality and decision-making  
errors (DME).Metrics: Engineering  
DME metric.1. Decision-Making  
Errors -Engineering.  
Refer to Action Item 1.2. Engineering  
Product Review Board Results. (Metric display is under development).
Effectiveness  
Review: Perform a self-assessment  
of the effectiveness  
of engineering  
products process by 02/01/07.Due Date: Complete actions by 02/01/07.Page 13 of 29 11/16/06: *
Metric Description
Decision-Making  
Errors -Engineering
Engineering  
department  
decision-making  
errors are compiled and reflected  
monthly.Refer to Action Item 1 Page 14 of 29 11/16/06  
{ DRAFT)Metric Description
Engineering  
Product Review Board Results Criteria:  
A minimum of 20 engineering  
products will be reviewed monthly. Engineering  
product types subject to sampling will be defined.1.2.3.4.5.Product meets expectations
Comment(s)  
made, no changes required Product must be changed -CRDR issued Margin impacted, no plant impact -CRDR issued Margin and plant impacted -CRDR issued Data goal: 90% or more meet criteria 1 & 2 Data comes from: Monthly Engineering  
Product Review Board results.=..DRAFT&.
Page 15 of 29 11/16/06  
Engineering  
Product Review Board Results Metric Display is Under Development
Page 16 of 29 11/16/06  
95002 Inspection  
Closure Action.Plan
Action Item 4: Improve use of Operating  
Experience
Problem Statement:  
Operating  
Experience (OE) is not consistently  
used for emergent issues.Action Plan Goal: To reduce plant events through the use of Operating  
Experience  
thereby improving  
plant performance  
and enhancing  
safety.Actions Previously  
Taken: (a) Completed  
a self assessment  
of the OE program.(b) Document high-tiered  
OE in the Corrective  
Action Program.(c) Developed  
checklist  
for high-tiered  
OE.(d) Perform independent  
reviews of high-tiered  
OE evaluations.
Current Status: Low-level  
OE is inconsistently  
used for emergent issues.Action to be Taken: (a) Incorporate  
station and industry Operating  
Experience  
into daily meetings and safety-human performance  
meetings.(b) Publish Operating  
Experience  
Outage books prior to each refueling  
outage. These will outline internal and external Operating  
Experience  
and the behaviors  
to prevent occurrence.(c) Revise Standard and Expectations  
Books to include specific expectations  
and desired behaviors  
for the use of Operating  
Experience.(d) Implement  
a station graded approach for the use of OE and reverse pre-job briefing process for normal and emergent work.(e) Add OE to work packages for normal and emergent work.(f) Make search engines more available  
to employees  
to make searching  
for OE easier.Metric Intent: To measure Palo Verde's use of OE on emergent issues.Metrics: Operation  
Experience (OE)1. OE Use Observations
2. Inadequate  
Use of OE Effectiveness  
Review: Conduct effectiveness  
review/self-assessment  
to include how/when OE is being used.Due Date: Complete actions by 06/01/07.Page 17 of 29 11/16/06  
Metric Description
OE Use Observations
Criteria:  
Percentage  
of field observations  
in which OE was appropriately  
utilized or discussed.
Data 2oal: Percentage  
of observations  
in which OE use or discussion  
meets or exceeds 90 percent of the opportunities.  
Goal is set by management.
Data comes from: Performance  
Improvement  
Team, field, and management  
observation  
programs.Page 18 of 29 11/16/06  
OE Use Observations
Percentage  
of Observations  
that incorporated  
Adequate OE Percent 100 90 80 70 60 50 40 30 20 10 0 I Good Jan Feb Mar Apr May Jun Jul 2006 Aug Sep Oct Nov Dec Page 19 of 29 11/16/06  
Metric Description
Inadequate  
Use of OE Criteria:  
Inadequate  
use/evaluation/implementation/etc.  
of Operating  
Experience  
-either Industry OE or Palo Verde OE. Specifically  
-inadequate  
use/evaluation/implementation, etc. of industry or Palo Verde OE that could have prevented  
a Palo Verde site or department  
clock reset.Data 2oal: For "trend only" on an interim basis.Data comes from: A review of Apparent Cause Evaluation  
and Significant  
CRDR Evaluation  
events looking for missed opportunities  
for Operating  
Experience  
use.Page 20 of 29 11/16/06  
Inadequate  
Use of OE Number of events that could have been prevented by using available  
OE Events 10 9 8 7 6 5 4 3 2 1 0'I Good Feb Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 21 of 29 11/16/06  
95002 Inspection  
Closure Action Plan Action item 5: Establish  
a formal plant walkdown process Problem Statement:  
Identification  
of degraded / non-conforming  
conditions  
has not been consistently  
achieved.Action Plan Goal: To ensure that the appropriate  
plant personnel, such as Auxiliary  
Operators (AOs), plant engineers  
and system engineers, identify degraded / non-conforming  
systems, structures, or components.
Actions Previously  
Taken: (a) Implemented  
a program to walk down safety-significant  
systems weekly (as defined in procedure  
79DP-9ZZ02)  
on a 12-week schedule.  
This walkdown is performed  
by Operations  
and Engineering.
Current Status: Formalizing  
the program and the training to ensure that appropriate  
plant personnel  
identify these types of conditions.
Actions to be Taken: (a) Create a "stand-alone" procedure  
to walk down safety-significant  
systems weekly on a 12-week schedule." Add instructions  
to identify personnel  
safety issues and other common walkdown areas of interest." Develop a plant walkdown pre-job brief to ensure consistency  
of issues identified  
in the walkdowns." Include Maintenance  
Fix It Now (FIN) team in the weekly walkdowns." Coordinate  
weekly schedule with Maintenance  
and Engineering.(b) Provide plant walkdown classroom  
training for AOs.(c) Develop and administer  
a practical  
demonstration  
of plant walkdowns  
to the AOs.(d) Provide additional  
plant Walkdown training to improve general knowledge  
of walkdown expectations  
for STAs, FIN, Maintenance  
Engineers  
and System Engineers.(e) Develop a metric to monitor performance.
Metric Intent: To measure the number of degraded / non-conforming  
issues identified  
by the walkdown teams and NAD.Metrics: 1. Safety-Significant  
Systems Walkdowns  
-Operations  
/ Engineering
Walkdown Teams.2. Safety-Significant  
Systems Walkdowns  
-Nuclear Assurance  
Department
Walkdown Teams.Effectiveness  
Review: Perform an effectiveness  
review of plant walkdowns.
Due Date: Complete actions by 03/30/07.Page 22 of 29 11/16/06  
Metric Description
Safety-Sihnificant  
Systems Walkdowns  
-Operations  
/ Engineering  
Walkdown Teams Criteria:  
Degraded / non-conforming  
conditions  
identified  
by Operations  
/ Engineering  
walkdown teams.Data Goal: Progressively  
fewer degraded / non-conforming  
conditions  
identified  
over time -management  
directed goal.Data comes from: Operations  
/ Engineering  
walkdowns  
and resultant  
corrective  
action document(s).
Page 23 of 29 11/16/06  
Safety-Significant  
Systems Walkdowns Operations  
/ Engineering  
Walkdown Teams Number of Degraded / Non-Conforming  
Conditions  
Identified
10 9 8 7 6 5 4 3 2 1 0 I Good Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 24 of 29 11/16/06  
Metric Description
Safety-Significant  
Systems Walkdowns  
-Nuclear Assurance  
Department  
Walkdown Teams Criteria:  
Degraded / non-conforming  
conditions, identified  
by Nuclear Assurance  
Department (NAD), not previously  
identified  
by Operations  
/ Engineering  
walkdown teams.Data Goal: Progressively  
fewer degraded / non-conforming  
conditions  
identified  
over time -management  
directed goal.Data comes from: NAD walkdowns  
and resultant  
corrective  
action document(s).
Page 25 of 29 11/16/06  
Safety-Significant  
Systems Walkdowns Nuclear Assurance  
Department  
Walkdown Teams 10 9 8 7 6 5 4 3 2 1 0 I1 Good Jan Feb Mar Apr May Jun Jul 2006 Aug Sep Oct Nov Dec Page 26 of 29 11/16/06  
95002 Inspection  
Closure Action Plan Action Item 6: Palo Verde independent  
review of plant walkdown results Problem Statement:  
The walkdown process is new and Nuclear Assurance  
Department (NAD)oversight  
is needed to ensure identification  
of degraded / non-conforming  
conditions  
by plant walkdown teams.Action Plan Goal: To see a decrease in the number of degraded / non-conforming  
systems, structures, or components  
identified  
by NAD and not previously  
noted by the line or from the formal integrated  
walkdown teams.Actions Previously  
Taken: (a) Utilizing  
the NAD Find It Now (FIN) team to conduct independent  
walkdowns, after the weekly plant walkdown team.Current Status: Performing  
walkdowns.
Actions to be Taken: 1. Observe and evaluate training described  
in Action Item 5.Metric Intent: To measure the number of degraded / non-conforming  
systems, structures, or components  
identified  
by NAD and not previously  
noted by the line from the formal integrated
walkdown teams.Metric: Refer to Action Item 5 for metric.Effectiveness  
Review: Continuing  
monitoring  
will be conducted.
Due Date: Complete actions by 03/30/07.Page 27 of 29 11/16/06  
95002 Inspection  
Closure Action Plan Action Item 7: Perform a review of 95002 metrics (10 Focus Areas) to ensure compliance  
with the metric guideline Problem Statement:  
A review of the 95002 metrics /performance  
indicators  
has indicated  
that a consistent  
methodology  
was not used to develop metrics. Some metrics were not effective.
Action Plan Goal: To make 95002 metrics consistent  
and effective.
Actions Previously  
Taken: (a) Performed  
a review of each 95002 Focus Area metric.(b) Adjusted metric with appropriate  
management  
review and approval.(c) Conducted  
independent  
review of 95002 metrics.Current Status: Review of the 95002 metrics indicates  
that three metrics require adjustment.
Actions to be Taken: 1. Adjust the three metrics.Due Date: Complete actions by 12/1/06.Page 28 of 29 11/16/06  
95002 Inspection  
Closure Action Plan 95002 Inspection  
Readiness  
Review Evaluate the readiness  
for a 95002 inspection.  
The criteria are: (a) Actions above are completed  
or progressing  
satisfactorily, (b) Metrics and data streams that supply them have been independently  
verified to accurately
portray actual performance (c) Metrics are either satisfactory  
or improving.  
Monitor and adjust actions will be taken for performance  
that is declining  
or not improving.
Actions to be Taken (a) Develop effectiveness  
and inspection  
readiness  
plan.(b) Assemble a team to conduct a readiness  
review, which should include two industry individuals.(c) Evaluate completed  
readiness  
review results and determine  
if additional  
actions are required.Metrics/Measures:  
Closure of 95002 NRC finding.Due Date: To be determined  
based on Metric results.Page 29 of 29 11/16/06
}}

Latest revision as of 22:03, 13 March 2020

Response to NRC Followup Supplemental Inspection Report; 05000528/2006010, 05000529/2006010; 05000530/2006010
ML063320538
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 11/16/2006
From: James M. Levine
Arizona Public Service Co
To: Mallett B
Region 4 Administrator
References
102-05594-JML/SAB/JAP/DJS/DCE, IR-06-010
Download: ML063320538 (33)
v • d • e


Text

PAl A subsidiary ofPinnacle West CapitalCorporation James M. Levine Mail Station 7602 Palo Verde Nuclear Executive Vice President Tel (623) 393-5300 PO Box 52034 Generating Station Generation Fax (623) 393-6077 Phoenix, Arizona 85072-2034 102-05594-JM LISAB/JAP/DJS/DC E November 16, 2006 Dr. B. S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 400 Arlington, TX 76011-4005

Dear Sir:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos: 50-528, 50-529, 50-530 Response to NRC Followup Supplemental Inspection Report (05000528/2006010; 05000529/2006010; 05000530/2006010)

The intent of this letter is to document the actions that APS is taking to address the remaining open items, as described in the NRC Followup Supplemental Inspection Report (NRC Inspection Report 50-528/529/530/2006-010), dated October 11, 2006.

The report discussed the results of the NRC inspection using Inspection Procedure 95002 for the facility's Yellow finding. APS has modified its action plan to address comments from the NRC inspection report as well as our own concerns as we continue to monitor and adjust the plan in response to results.

The inspection report discussed the results of the ten focus areas that the inspection team reviewed. The inspection report identified that, with respect to the Yellow finding, nine of those areas are closed. APS will continue improvements in each of the nine areas and will monitor the effectiveness of those actions. The closed focus areas include:

Focus Area 1, "Procedures Did Not Contain Necessary Requirements" Focus Area 2, "Lack of Specific Provisions in the Design and Licensing Basis" Focus Area 4, "Inadequate Communication of Design Information" II

U. S. Nuclear Regulatory Commission Dr. B. S. Mallett Response to NRC Followup Supplemental Inspection Report dated October 11, 2006 Page 2 Focus Area 5, "Inadequate Problem Identification and Resolution" Focus Area 6, "Limited or Weak Operating Experience Program" Focus Area 7, "Limited Experience and Training" Focus Area 8, "Limited Resources" Focus Area 9, "Limited Nuclear Assurance Department Oversight" Focus Area 10, "Limited Procedural Guidance" One focus area remaine'd open, requiring additional action:

Focus Area 3, "Lack of Questioning Attitude and Technical Rigor of Individuals."

APS agrees that corrective actions for concerns involving questioning attitude, technical rigor, and technical review have not been fully effective. Performance measures and metrics to monitor the corrective actions that have been taken in this area had not been fully developed and, therefore, had not been effective in identifying needed adjustments to the corrective actions. These remaining issues and our actions to address them are listed in detail in the enclosure. We are confident these actions when implemented will address our and the NRC's remaining concerns for this area and will support closure of the Yellow finding.

Two focus areas, while closed for the purposes of the 95002 inspection, also require additional actions:

  • Focus Area 5, "Inadequate Problem Identification and Resolution." While corrective actions specific to the Yellow finding have been completed, we understand that improvement in the corrective action program is still needed. It is our understanding that future NRC reviews associated with this area will be handled under the PI & R substantive crosscutting issue. The Corrective Action Area of our Performance Improvement Plan will include the actions to address these corrective action program deficiencies.

" Focus Area 6, "Limited or Weak Operating Experience Program." The inspection team concluded that corrective actions did not incorporate routine use of operating experience (OE) in emergent activities. Further NRC review of corrective actions related to OE in daily activities will be performed during NRC assessment of Focus Area 3. Our actions to address these concerns are incorporated into the enclosed action plan.

As discussed in the inspection report, during the September 7, 2006 public meeting, APS indicated that success measures would be developed for NRC review prior to our request for an additional NRC assessment of the Yellow finding.

U. S. Nuclear Regulatory Commission Dr. B. S. Mallett Response to NRC Followup Supplemental Inspection Report dated October 11, 2006 Page 3 The actions described in the enclosure provide the success measures for focus areas 3 and 6. The measures are currently in various stages of implementation and completion, as noted.

APS will notify the NRC when these measures have been implemented sufficiently and show the desired results, as defined in the enclosed plan. At that time, we will request a followup inspection. The listed completion dates are for completion of the related action items and do not represent dates by which we expect to have achieved the results required to ask for a followup inspection.

The actions described in this letter represent corrective action plans; they are not considered to be regulatory commitments.

Should you have any further questions, please contact Craig Seaman at (623) 393-5421.

Sincerely, 1A JMLISAB/JAP/DJS/DCE/gt

Enclosure:

0 95002 Inspection Closure Action Plan cc: B, S. Mallett NRC Region IV Regional Administrator M. B. Fields NRC NRR Project Manager G. G. Warnick NRC Senior Resident Inspector for PVNGS

ENCLOSURE 95002 Inspection Closure Action Plan

95002 Inspection Closure Action Plan Action Item 1: Revise Operational Decision Making guidance (ODP- 16)

Problem Statement: Station personnel are missing opportunities to use the Operational Decision Making process for degraded conditions.

Action Plan Goal: To develop additional tools for Operational Decision Making and increase the use and effectiveness of ODP-16.

Actions Previously Taken:

(a) Benchmarked current guidance contained in Operations ODP- 16 (Principles for Effective Operational Decision-Making and the use of Management Review Teams) with guidance from other utilities (Exelon and Entergy).

(b) Implemented an interim change to procedure ODP-16 based on benchmarking results.

Current Status: Decision Making Errors (DME) metric indicates that additional actions are required.

Actions to be taken:

(a) The following actions will be taken to improve the use of ODMI process:

E Include an assessment for emergent issues in the Shift Manager Turnover (SMTO) 0 Include an assessment for off-normal alignment in the Crew Turnover sheet.

m Include an assessment for shift activities in the crew briefing template.

0 Brief the Operations staff on the resultant Operations Department Practice changes.

0 Perform formal training in License Operator Continuing Training (LOCT) on the Operational Decision Making process. Training to include review of case studies.

Metric Intent: To measure the number of Decisions Making Errors (DME) for Operations, Engineering, Maintenance, and site as captured via the Corrective Action Program (CRDRs).

Events captured in the metric that occurred pre-2006 are referred to as "Latent" and are tracked for informational purposes.

Metrics: Site metric for Decision Making Errors

1. Decision Making Errors - Operations
2. Decision Making Errors - Engineering
3. Decision Making Errors - Maintenance
4. Decision.Making Errors - Palo Verde site
5. Decision Making Errors - Latent Effectiveness Review: Perform a self-assessment on the effectiveness of the ODMI process by 03/30/07.

Due Date: Complete actions by 03/30/07.

Page 1 of 29 11/16/06

Metric Description Decision Making Errors Operations, Engineering, Maintenance, Palo Verde Site, Latent Criteria: The following are inputs to the overall DME metric for each group listed above.

1. Lack of technical rigor o A deficient product or document due to technical inaccuracies because all the facts were not gathered, the facts were incorrect, and/or the wrong conclusions were made. This includes "narrow focus" approaches to problems or solutions.
2. Failure to recognize hazard, error, or deficiency o A failure to recognize a deficient or abnormal condition - unawareness.
3. Lack of questioning attitude o Information received or observed and is contrary to the expected or the norm. Some amount of knowledge-based analysis is performed, but is inadequate. Usually characterized as mindset, tunnel vision, and wrong assumptions.
4. Proceeding in the face of uncertainty o Confronted with an abnormal situation or information and no gathering of facts, conclusions, and/or decision making are apparent and action is taken. Characterized as overly optimistic, overconfident, etc.
5. Non-conservative decision-making o All the facts are gathered and weighed, but the wrong or non-conservative decision is made between two or more possible solutions (e.g., production over safety margin). Characterized as "can do" attitude, inappropriate attitude, etc.

Data ,oal:

o Site DME Metric goal is management directed.

o Department DME Metric goal is trend only.

o Latent DME Metric is information only.

Data comes from: Corrective Action Program database.

Page 2 of 29 11/16/06

Decision Making Errors Operations Monthly Number of Errors 10 9

8 7

6 5

Good I1 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 3 of 29 11/16/06

Decision Making Errors Engineering Monthly Number of Errors 10 9

8 7

6 5

I Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 4 of 29 11/16/06

Decision Making Errors Maintenance 10 9

8 7

6 5 Good I1 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 5 of 29 11/16/06

Decision Making Errors Palo Verde Site 10 9

8 7

6 5 Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 6 of 29 11/16/06

Decision Making Errors Latent Monthly Number of Errors 10 9

8 7

6 5

I Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct- Nov Dec 2006 Page 7 of 29 11/16/06

95002 Inspection Closure Action Plan Action Item 2: Monitoring Operability Determination (OD) quality Problem Statement: Quality of Operability Determinations does not always meet site expectations.

Action Plan Goal: To ensure that Operability Determinations meet procedural requirements.

Actions Previously Taken:

(a) Established an OD Quality Review Board with Engineering, NAD, Performance Improvement and Training representation.

(b) Included results of Engineering Product Review Board (EPRB) reviews in the OD Quality metric.

Current Status: Metrics indicate inconsistent use of the OD program. This will be addressed by the following actions:

Actions to be Taken:

(a) Incorporate changes to 40DP-9OP26 (Operability Determination procedure) to support new action request process roll-out.

(b) Implement changes to the OD Quality Review Board:

" Develop a charter for the OD Quality Review Board

" Include qualifications for the OD Quality Review Board to include Shift Manager experience and an off-site/independent individual (c) Change OD Timeliness metric to include corrective action due dates.

Metric Intent: To measure the quality of Operability Determinations.

Metrics:

1. Operability Determination Quality
2. Operability Determination Timeliness Effectiveness Review: Perform a self-assessment on the effectiveness of the OD quality process by 03/30/07.

Due Date: Complete actions by 03/30/07.

Page 8 of 29 11/16/06

Metric Description Operability Determination Quality Criteria:

1. Self identify potential challenges to operability o Number of issues identified by oversight agency.

o Number of corrective action documents the CRDR Review Committee sent for control room review because initiator and leader failed to identify Control Room review required.

o Number of work documents not sent to Control Room that were subsequently determined to be degraded / non-conforming tech specifications systems, structures and components during weekly review by work control Senior Reactor Operator.

2. Timely Identification to Operations of Operability Issues o Corrective action documents that were not processed/identified to the Shift Manager within the same shift as discovery of the degraded / non-conforming condition affecting technical specifications systems, structures and components.

o Work documents that were not identified to Shift Manager within same shift for degraded

/ non-conforming conditions affecting tech specifications systems, structures and components.

3. Inadequate tech information or communication of information for the IOD o Does not follow requirements of section 3.2.2 of the Operability Determination procedure as a minimum.

o Immediate Operability Determinations (IOD) not sent to responsible Engineering leader for review when Prompt Operability Determination (POD) is not requested.

.o IOD contains inaccurate information.

o IOD does not provide sufficient justification and a POD is not requested (Shift Technical Advisor / Engineering leader review)

4. Inadequate tech information or communication of information for the POD o Does not follow requirements for POD as described in section 3.5 of OD procedure.

o Nuclear Assurance Department / Shift Technical Advisor section leader determines POD is inadequate.

o Engineering Product Review Board determines POD is "unacceptable".

5. Shift Manager Review of POD o Shift Manager concurrence with POD conclusion is documented in the POD.

o Simple Quality Verification and Validation of the POD product should have caught an error but did not.

Data goal: Metric goal is "trend only" and management directed.

Data comes from: Corrective Action Program database.

Page 9 of 29 11/16/06

Operability Determination Quality Number of Operability Determinations that did not meet expectations for Quality 10 9

8 7

6 5

'I Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 10 of 29 11/16/06

Metric Description Operability Determination Timeliness Criteria: Corrective Action(s) for each Operability Determination (OD) will be completed in accordance with the schedule established by the Director of Operations.

Data goal: Number of ODs that have corrective actions that have exceeded the schedule date.

Data comes from: Corrective Action Program database.

Page 11 of 29 11/16/06

Operability Determination Timeliness Number of Operability Determinations that did not meet expectations for Timeliness 10 9

8 7

6 5

.I Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 12 of 29 11/16/06

95002 Inspection Closure Action Plan Action Item 3: Establish reviews of Engineering work products to improve technical adequacy, rigor and questioning attitude Problem Statement: Historical issues indicate a need to monitor the quality of Engineering products and errors in process implementation, including Operability Determinations.

Action Plan Goal: To see a decrease in the number of Engineering decision-making errors and Engineering products that did not meet expectations per the Engineering Products Review Board (EPRB).

Actions Previously Taken:

(a) Engineering human performance tools were developed from industry benchmarking.

(b) Engineering and leaders have been trained on tool usage.

(c) An EPRB was established and has performed quarterly quality and technical accuracy reviews of selected Engineering work products.

Current Status: Engineering does not have a formal trouble shooting guide, and EPRB currently meets quarterly.

Actions to be Taken:

(a) An Engineering tool is being developed to add formality and consistency to the troubleshooting process.

(b) The EPRB function is being modified to meet on a monthly basis and to become a senior Engineering leadership review/oversight group for engineering work products and human performance. A new human performance review board will continue reviews of Engineering work products.

(c) EPRB feedback on process implementation and quality of work products is provided to Engineering management, and used to revise expectations and training to improve performance.

(d) Each of the four Engineering departments assesses and monitors decision-making errors (DMEs) for their department.

Metric Intent: To monitor work product quality and decision-making errors (DME).

Metrics: Engineering DME metric.

1. Decision-Making Errors - Engineering. Refer to Action Item 1.
2. Engineering Product Review Board Results. (Metric display is under development).

Effectiveness Review: Perform a self-assessment of the effectiveness of engineering products process by 02/01/07.

Due Date: Complete actions by 02/01/07.

Page 13 of 29 11/16/06

Metric Description Decision-Making Errors - Engineering Engineering department decision-making errors are compiled and reflected monthly.

Refer to Action Item 1 Page 14 of 29 11/16/06

{DRAFT) Metric Description Engineering Product Review Board Results Criteria: A minimum of 20 engineering products will be reviewed monthly. Engineering product types subject to sampling will be defined.

1. Product meets expectations
2. Comment(s) made, no changes required
3. Product must be changed - CRDR issued
4. Margin impacted, no plant impact - CRDR issued
5. Margin and plant impacted - CRDR issued Data goal: 90% or more meet criteria 1 & 2 Data comes from: Monthly Engineering Product Review Board results.

=..DRAFT&.

Page 15 of 29 11/16/06

Engineering Product Review Board Results Metric Display is Under Development Page 16 of 29 11/16/06

95002 Inspection Closure Action.Plan Action Item 4: Improve use of Operating Experience Problem Statement: Operating Experience (OE) is not consistently used for emergent issues.

Action Plan Goal: To reduce plant events through the use of Operating Experience thereby improving plant performance and enhancing safety.

Actions Previously Taken:

(a) Completed a self assessment of the OE program.

(b) Document high-tiered OE in the Corrective Action Program.

(c) Developed checklist for high-tiered OE.

(d) Perform independent reviews of high-tiered OE evaluations.

Current Status: Low-level OE is inconsistently used for emergent issues.

Action to be Taken:

(a) Incorporate station and industry Operating Experience into daily meetings and safety-human performance meetings.

(b) Publish Operating Experience Outage books prior to each refueling outage. These will outline internal and external Operating Experience and the behaviors to prevent occurrence.

(c) Revise Standard and Expectations Books to include specific expectations and desired behaviors for the use of Operating Experience.

(d) Implement a station graded approach for the use of OE and reverse pre-job briefing process for normal and emergent work.

(e) Add OE to work packages for normal and emergent work.

(f) Make search engines more available to employees to make searching for OE easier.

Metric Intent: To measure Palo Verde's use of OE on emergent issues.

Metrics: Operation Experience (OE)

1. OE Use Observations
2. Inadequate Use of OE Effectiveness Review: Conduct effectiveness review/self-assessment to include how/when OE is being used.

Due Date: Complete actions by 06/01/07.

Page 17 of 29 11/16/06

Metric Description OE Use Observations Criteria: Percentage of field observations in which OE was appropriately utilized or discussed.

Data 2oal: Percentage of observations in which OE use or discussion meets or exceeds 90 percent of the opportunities. Goal is set by management.

Data comes from: Performance Improvement Team, field, and management observation programs.

Page 18 of 29 11/16/06

OE Use Observations Percentage of Observations that incorporated Adequate OE Percent 100 90 80 70 60 50 Good I

40 30 20 10 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 19 of 29 11/16/06

Metric Description Inadequate Use of OE Criteria: Inadequate use/evaluation/implementation/etc. of Operating Experience - either Industry OE or Palo Verde OE. Specifically - inadequate use/evaluation/implementation, etc. of industry or Palo Verde OE that could have prevented a Palo Verde site or department clock reset.

Data 2oal: For "trend only" on an interim basis.

Data comes from: A review of Apparent Cause Evaluation and Significant CRDR Evaluation events looking for missed opportunities for Operating Experience use.

Page 20 of 29 11/16/06

Inadequate Use of OE Number of events that could have been prevented by using available OE Events 10 9

8 7

6 5

Good

'I 4

3 2

1 0

Feb Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 21 of 29 11/16/06

95002 Inspection Closure Action Plan Action item 5: Establish a formal plant walkdown process Problem Statement: Identification of degraded / non-conforming conditions has not been consistently achieved.

Action Plan Goal: To ensure that the appropriate plant personnel, such as Auxiliary Operators (AOs), plant engineers and system engineers, identify degraded / non-conforming systems, structures, or components.

Actions Previously Taken:

(a) Implemented a program to walk down safety-significant systems weekly (as defined in procedure 79DP-9ZZ02) on a 12-week schedule. This walkdown is performed by Operations and Engineering.

Current Status: Formalizing the program and the training to ensure that appropriate plant personnel identify these types of conditions.

Actions to be Taken:

(a) Create a "stand-alone" procedure to walk down safety-significant systems weekly on a 12-week schedule.

" Add instructions to identify personnel safety issues and other common walkdown areas of interest.

" Develop a plant walkdown pre-job brief to ensure consistency of issues identified in the walkdowns.

" Include Maintenance Fix It Now (FIN) team in the weekly walkdowns.

" Coordinate weekly schedule with Maintenance and Engineering.

(b) Provide plant walkdown classroom training for AOs.

(c) Develop and administer a practical demonstration of plant walkdowns to the AOs.

(d) Provide additional plant Walkdown training to improve general knowledge of walkdown expectations for STAs, FIN, Maintenance Engineers and System Engineers.

(e) Develop a metric to monitor performance.

Metric Intent: To measure the number of degraded / non-conforming issues identified by the walkdown teams and NAD.

Metrics:

1. Safety-Significant Systems Walkdowns - Operations / Engineering Walkdown Teams.
2. Safety-Significant Systems Walkdowns - Nuclear Assurance Department Walkdown Teams.

Effectiveness Review: Perform an effectiveness review of plant walkdowns.

Due Date: Complete actions by 03/30/07.

Page 22 of 29 11/16/06

Metric Description Safety-Sihnificant Systems Walkdowns - Operations / Engineering Walkdown Teams Criteria: Degraded / non-conforming conditions identified by Operations / Engineering walkdown teams.

Data Goal: Progressively fewer degraded / non-conforming conditions identified over time -

management directed goal.

Data comes from: Operations / Engineering walkdowns and resultant corrective action document(s).

Page 23 of 29 11/16/06

Safety-Significant Systems Walkdowns Operations / Engineering Walkdown Teams Number of Degraded / Non-Conforming Conditions Identified 10 9

8 7

6 5 Good I

4 3

2 1

0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 24 of 29 11/16/06

Metric Description Safety-Significant Systems Walkdowns - Nuclear Assurance Department Walkdown Teams Criteria: Degraded / non-conforming conditions, identified by Nuclear Assurance Department (NAD),

not previously identified by Operations / Engineering walkdown teams.

Data Goal: Progressively fewer degraded / non-conforming conditions identified over time -

management directed goal.

Data comes from: NAD walkdowns and resultant corrective action document(s).

Page 25 of 29 11/16/06

Safety-Significant Systems Walkdowns Nuclear Assurance Department Walkdown Teams 10 9

8 7

6 5

I1 Good 4

3 2

1 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2006 Page 26 of 29 11/16/06

95002 Inspection Closure Action Plan Action Item 6: Palo Verde independent review of plant walkdown results Problem Statement: The walkdown process is new and Nuclear Assurance Department (NAD) oversight is needed to ensure identification of degraded / non-conforming conditions by plant walkdown teams.

Action Plan Goal: To see a decrease in the number of degraded / non-conforming systems, structures, or components identified by NAD and not previously noted by the line or from the formal integrated walkdown teams.

Actions Previously Taken:

(a) Utilizing the NAD Find It Now (FIN) team to conduct independent walkdowns, after the weekly plant walkdown team.

Current Status: Performing walkdowns.

Actions to be Taken:

1. Observe and evaluate training described in Action Item 5.

Metric Intent: To measure the number of degraded / non-conforming systems, structures, or components identified by NAD and not previously noted by the line from the formal integrated walkdown teams.

Metric: Refer to Action Item 5 for metric.

Effectiveness Review: Continuing monitoring will be conducted.

Due Date: Complete actions by 03/30/07.

Page 27 of 29 11/16/06

95002 Inspection Closure Action Plan Action Item 7: Perform a review of 95002 metrics (10 Focus Areas) to ensure compliance with the metric guideline Problem Statement: A review of the 95002 metrics /performance indicators has indicated that a consistent methodology was not used to develop metrics. Some metrics were not effective.

Action Plan Goal: To make 95002 metrics consistent and effective.

Actions Previously Taken:

(a) Performed a review of each 95002 Focus Area metric.

(b) Adjusted metric with appropriate management review and approval.

(c) Conducted independent review of 95002 metrics.

Current Status: Review of the 95002 metrics indicates that three metrics require adjustment.

Actions to be Taken:

1. Adjust the three metrics.

Due Date: Complete actions by 12/1/06.

Page 28 of 29 11/16/06

95002 Inspection Closure Action Plan 95002 Inspection Readiness Review Evaluate the readiness for a 95002 inspection. The criteria are:

(a) Actions above are completed or progressing satisfactorily, (b) Metrics and data streams that supply them have been independently verified to accurately portray actual performance (c) Metrics are either satisfactory or improving. Monitor and adjust actions will be taken for performance that is declining or not improving.

Actions to be Taken (a) Develop effectiveness and inspection readiness plan.

(b) Assemble a team to conduct a readiness review, which should include two industry individuals.

(c) Evaluate completed readiness review results and determine if additional actions are required.

Metrics/Measures: Closure of 95002 NRC finding.

Due Date: To be determined based on Metric results.

Page 29 of 29 11/16/06

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