ML063320538
| ML063320538 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/16/2006 |
| From: | Levine J M Arizona Public Service Co |
| To: | Mallett B S Region 4 Administrator |
| References | |
| 102-05594-JML/SAB/JAP/DJS/DCE, IR-06-010 | |
| Download: ML063320538 (33) | |
See also: IR 05000528/2006010
Text
PAl A subsidiary
of Pinnacle West Capital Corporation
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;
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" I I
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 M. B. Fields G. G. Warnick NRC Region IV Regional Administrator
NRC NRR Project Manager 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 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
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
Decision Making Errors Maintenance
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
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
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 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
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
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