L-08-110, Corrective Action Program Assessment Plan for 2008

Corrective Action Program Assessment Plan for 2008

ML081000622
Person / Time
Site:	Davis Besse
Issue date:	04/08/2008
From:	Allen B FirstEnergy Nuclear Operating Co
To:	Caldwell J Region 3 Administrator
References
L-08-110
Download: ML081000622 (21)

Text

FENOC -

hrstEnergy Nuclear Operating Company 550 1 Nor!h Stale Route 2 Oak Harbor Ohio 43449 Barry S. Allen Vice Presiden: ~ Nuc!ear 4 79-32 1 - 7676 Fax 4 19-321-7582 April 8, 2008 L-08-110 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region 111 2443 Warrenville Road, Suite 21 0 Lisle, IL 60532-4352

Subject:

Davis-Besse Nuclear Power Station, Unit I Docket Number 50-346, License Number NPF-3 Submittal of the Corrective Action Proqram Implementation Independent Assessment Plan for the Davis-Besse Nuclear Power Station - Year 2008 The purpose of this letter is to submit the assessment plan and related information for the year 2008 independent assessment of the Davis-Besse Nuclear Power Station (DBNPS) Corrective Action Program Implementation. The Nuclear Regulatory Commission (NRC) letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order, (letter DBNPS Log Number 1-4524) requires submittal of the identity of the external assessment organization, including the qualifications of the assessors, and the scope and depth of the assessment plan, ninety (90) days prior to the assessment.

Therefore, in accordance with the Confirmatory Order, FENOC is submitting the Corrective Action Program Implementation Independent Assessment Plan, including the identification and qualifications of the assessors. The onsite portion of the assessment is scheduled to commence on July 7, 2008, with this portion of the assessment lasting approximately two weeks. A final debrief marking the end of the assessment will be conducted with the DBNPS staff by August 4,2008. The final assessment report and action plans, if required, will be submitted to the NRC within 45 days following the final debrief.

RECEIVED APR 0 9 2008

Davis-Besse Nuclear Power Station, Unit 1 Page 2 of 2 L-08-110 There are no regulatory commitments included in this letter. If there are any questions or if additional information is required, please contact Mr. Dale R. Wuokko, Acting Manager - Site Regulatory Compliance, at (41 9) 321 -71 20.

Sincerely, Barry S. -Allen L J S1 JCS

Enclosure:

Corrective Action Program Implementation Assessment Plan for the Davis-Besse Nuclear Power Station - 2008 cc:

USNRC Document Control Desk DB-1 NRCINRR Project Manager DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

Enclosure L-08-110 Corrective Action Program Implementation Assessment Plan for the Davis-Besse Nuclear Power Station - 2008 (1 8 pages to follow)

NUMBER:

COIA-CAP-2008 ASSESSMENT AREA:

Corrective Action Program Implementation PURPOSE:

The purpose is to provide the 2008 independent and comprehensive assessment of the Corrective Action Program implementation at the Davis-Besse Nuclear Power Station.

The assessment will be performed in accordance with the requirements of the March 8,2004, Confirmatory Order Modifying License number NPF-3 and Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments. The assessment will be used to identify areas for improvement requiring corrective actions with action plans and areas in need of attention for other improvement opportunities. The assessment will also be used to assess the rigor, criticality, and overall quality of available Davis-Besse internal self-assessment activities in the implementation of the Corrective Action Program.

SCOPE:

The Independent Assessment Team will evaluate the following areas associated with the Corrective Action Program implementation:

Corrective actions taken in response to the Areas in Need of Attention (ANAs) identified during the 2007 Independent Assessment of the Davis-Besse Corrective Action Program Corrective Action Program implementation since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program (August 2007) as follows:

I. Identification, classification, and categorization of conditions adverse to quality

2. Evaluation and resolution of problems

3. Corrective action implementation & effectiveness

4. Trending program implementation & effectiveness

5. Effect of program backlogs

6. Effectiveness of internal assessment activities Page 1 of 18

Corrective Action Program Implementation Assessment Plan - 2008 The Assessment Team will conduct the following activities:

1. Identification, Classification, and Categorization of Conditions Adverse to Quality The 2008 Independent Assessment Team will review activities to assess the effectiveness of the identification, classification, and categorization of Conditions Adverse to Quality for issues identified since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program (August 2007), including:

a. Review and evaluate the identification, classification, and categorization of at least twenty-five (25) selected Condition Reports categorized after Management Review Board (MRB) review.

b. Review a sampling of SAP non-maintenance notifications initiated since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program (August 2007) to determine if the conditions were properly categorized. Analyze for issues which should have been identified as Conditions Adverse to Quality but were not or were only partially iden ti fi ed.

c. Interview at least ten (1 0) individuals from various parts of the Davis-Besse Nuclear Power Stations management and staff. Ascertain the Davis-Besse Nuclear Power Station staffs commitment to the Corrective Action Program, the extent of their understanding of the Davis-Besse Nuclear Power Stations problem identification process, and their willingness to report problems.

d. Evaluate the adequacy of the Davis-Besse Nuclear Power Stations identification, classification, and categorization of a minimum of twenty (20) corrective actions for sharing operational experience feedback with the industry.

e. Review a sampling of in-plant logs (e.g., control room log) and records to verify that conditions adverse to quality are captured appropriately in the CAP.

2. Evaluation and Resolution of Problems The Assessment Team will perform an analysis of at least ten (1 0) selected issues or problems that have gone through the entire applicable Corrective Action Program process, to identify strengths and weaknesses in their evaluation and resolution. The Assessment Team will:

a. Analyze the Full Apparent Cause or Root Cause evaluation of at least five (5) selected Condition Reports.

b. Analyze the Limited or Full Apparent Cause or Root Cause evaluation of at least five (5) selected Condition Reports related to human performance.

c. Analyze the problems selected above. Determine the Davis-Besse Nuclear Power Stations effectiveness in implementing the Corrective Action Program.

d. Identify any strengths or weaknesses to responses found during the detailed analysis above.

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Corrective Action Program Implementation Assessment Plan - 2008

3. Corrective Action Implementation i? Effectiveness The Assessment Team will perform an analysis of Conditions Adverse to Quality corrective action implementation and effectiveness since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program (August 2007). The Assessment Team will:

a.

b.

C.

d.

Evaluate the timeliness of corrective actions for at least twenty (20) Condition Reports.

Review the number of repeat condition reports and corrective actions and evaluate the effectiveness of corrective actions.

Evaluate the adequacy of the Davis-Besse Nuclear Power Stations implementation of corrective actions for operational experience feedback from the industry.

Review the activities of the Corrective Action Review Board (CARB) and evaluate the effectiveness of the CARB.

4. Trending Program Implementation 8, Effectiveness The Assessment Team will assess the sites implementation of existing trending programs.

5. Effect of Program Backlogs The Assessment Team will perform an analysis of the effect of program backlogs on organizational and operational effectiveness. The Assessment Team will:

a. Review program backlogs and the trend of the backlogs.

b. Evaluate the impact of the backlog and backlog trend on organizational and operational effectiveness.

6. Effectiveness of Internal Assessment Activities Self-Assessments The Assessment Team will evaluate the effectiveness of the Davis-Besse Nuclear Power Stations self-assessment activities associated with the implementation of the Corrective Action Program. The Assessment Team will:

a.

b.

Review the results of Davis-Besse Nuclear Power Station assessments/reviews conducted since the 2007 Independent Assessment of the Corrective Action Program. Determine if the assessments/reviews were comprehensive and whether effective actions were taken to correct problems or weaknesses identified.

Evaluate the effectiveness of self-assessment capability by reviewing findings and corrective actions associated with at least five (5) of the following:

i.

11.

111.

Focused self-assessment reports Nuclear Oversight Assessments/reviews (including assessments/reviews of both onsite and offsite safety committee activities)

Evaluations conducted on the implementation of the Corrective Action Program since the 2007 Independent Assessment Page 3 of 18

Corrective Action Program implementation Assessment Pian - 2008

c. Determine if the Davis-Besse Nuclear Power Station is aggressive in correcting self-assessment findings on the implementation of the Corrective Action Program by determining whether the corrective actions are adequate, timely, properly prioritized, and that effectiveness reviews are ensuring the desired results.

d. Interview at least four (4) selected individuals involved with the oversight function, as well as the audited organization, to gain their insight on the effectiveness of their effort and the responsiveness of FENOC management and staff to CAP issues raised.

Onsite and Offsite Safety Review Board Activities The Assessment Team will evaluate the effectiveness of the safety review boards oversight of the implementation of the Corrective Action Program since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program (August 2007) by reviewing minutes, assessmentsheviews, or other actions initiated by the boards as they relate to risk significance or major corrective action successes or failures. The Assessment Team will review the following, as necessary:

a. Identify what issues are reviewed by the safety review committees and review five (5) actions, if available, initiated by the safety committees to identify, assess, and correct areas of weakness.

b. Review assessments/reviews of the Corrective Action Program conducted since the last Independent Assessment under the cognizance of the offsite safety review board and determine if the assessmentheview findings were consistent with such external assessments as INPO, NRC, and consultants.

c. Evaluate the Davis-Besse Nuclear Power Stations follow-up to five (5) items, if available, on the Corrective Action Program identified by the safety review boards, including board-initiated assessment/review findings and any recurring problems.

7. Review of Corrective Actions from Previous Independent Assessment of the Davis-Besse Corrective Action Program The Independent Assessment Team will review existing open Corrective Actions and S A P items developed in response to Areas in Need of Attention and Areas for Improvement fiom the previous independent inspections. The 2008 Independent Assessment Team will identify individual strengths or weaknesses to responses found during an analysis of the closed items.

INDEPENDENT ASSESSMENT TEAM (BIOGRAPHIES ATTACHED):

. Jon R. Johnson, Advanced Technologies and Laboratories International (ATL), On-Site Team Leader Kenneth G. Murphy, ATL, Report Coordinator-Reviewer Paul D. Swetland, ATL, Senior Reviewer William W. Webster, Surry Power Station, Peer Reviewer Kim Kieler, South Texas Project, Peer Reviewer Jeff Bonner, Diablo Canyon Power Plant, Peer Reviewer

Corrective Action Proaram ImDlernentation Assessment Plan - 2008 SCHEDULE:

Date May 29,2008 June 2 to July 6,2008 July 6,2008 July 7 to July 18,2008 August 4,2008 August 11,2008 Activity Distribute selected documentation to the CAP Assessment Team members to begin offsite review Preparation Period - Offsite (in-office) review of Davis-Besse material in preparation for onsite assessment CAP Assessment Team will assemble at plant site to begin site assessment activities CAP Assessment Team performs onsi te assessment; Assessment Team provides Davis-Besse with preliminary findings during debrief meeting Draft report fiom CAP Assessment Team delivered to Davis-Besse for review and comment; final debrief meeting (marks completion of assessment)

Davis-Besse comments incorporated and final CAP Assessment report delivered to Davis-Besse management Final assessment report and Davis-Besse action plans (if required by findings) will be submitted to the NRC within forty-five (45) days of the completion of the assessment.

ASSESSMENT METHODS:

The Independent Assessment Team will use an approach similar to the NRC Inspection Procedure 40500, Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems, and NOBP-LP-200 1, FENOC Self-Assessment/Benchmarking, to evaluate the effectiveness of the implementation of the Corrective Action Program.

The assessment methodology may include any combination of the following:

. Observing activities

. Interviewing personnel

. Reviewing documentation Evaluating or performing trend analysis Reviewing procedures, instructions, and programs Comparing actual performance levels with pre-established performance indicators The following general standards of acceptable corrective actions will apply to the assessment of Davis-Besse Corrective Action Program implementation:

The problem is identified in a timely manner commensurate with its significance and ease of discovery.

. Identification of the problem is accurate and complete and includes consideration of the generic implications and possible previous occurrences.

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Corrective Action Program Implementation Assessment Plan - 2008

. The problem is properly prioritized for resolution commensurate with its safety significance.

The root causes of the problem are identified and corrective actions are appropriately focused to address the causes and to prevent recurrence of the problem.

. Corrective actions are completed in a timely manner.

The assessment team will review the referenced procedure/documents during the Preparation Period prior to site arrival.

The Assessment Team will identify, as applicable, Areas of Strength, Areas in Need of Attention, and Areas for Improvements as defined in the current revision of Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments. The Team will provide an overall concluding statement on the effectiveness of the Corrective Action Program implementation using the rating categories of DBBP-VP-0009.

REFERENCES:

NRC Inspection Procedure 40500, Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems NOP-LP-2001, Corrective Action Program NOB P-LP-200 1, FENOC Self-AssessmentIBenchmarking NOBP-LP-2007, Condition Report Process Effectiveness Review NOBP-LP-2008, FENOC Corrective Action Review Board Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments Condition Reports and CR Trend Reports, August 2007 through July 2008 Past NRC Inspection Reports that are applicable to the area assessed Past applicable Self-Assessments Davis-Besse Fleet Oversight quarterly performance reports for past four quarters Related Operating Experience since the 2007 Independent Assessment of the Davis-Besse Corrective Action Program Company Nuclear Review Board (CNRB) meeting minutes from last four CNRB intervals Field Observation Reports Applicable Section or Area Performance Indicators Previous Independent Assessment Reports and Action Plans (subsequent to first annual assessments)

Davis-Besse section Integrated Performance Assessment (IPA) Reports Davis-Besse Component Health Trending Reports Page 6 of 18

Corrective Action Proaram lmdementation Assessment Plan - 2008 RESUMES Jon R. Johnson Mr. Johnson advises national and international nuclear utility and governmental executives regarding nuclear safety and regulatory policy. He received the Presidential Meritorious Rank Award from the President of the United States for sustained superior achievement in managing programs in the Senior Executive Service; directed Nuclear Regulatory Commission licensing and inspection activities (Reactor Oversight Program) at all nuclear power reactor facilities in the United States; and is responsible for leadership of NRC renewal of operating licenses, licensing of advanced nuclear reactors and risk-informed regulations. Mr. Johnson is a Registered Professional Engineer in the Commonwealth of Massachusetts and was Qualified as Chief Engineer and Engineering Officer of the Watch on a US Navy nuclear power plant.

Education M.S., Engineering-Nuclear Engineering, University of Virginia, 197 1 B.S., Bachelor of Science (Physics-with distinction), US Naval Academy, 1970 Qua Iifica tions/A reas of Expertis e Reactor Safety Licensing and Inspection Policy-Directly managed NRCs headquarters program office functions for all operating reactors and research reactors in the US including licensing, engineeringhechnical review, inspection and oversight programs (ROP), license renewal, maintenance rule implementation, development of risk-informed regulations, and operator licensing, advanced reactor licensing, and generic Technical Specification development.

Provided advice on policy matters to the NRC Commissioners, the Congress, and the White House. Directly managed implementation of NRCs Reactor Oversight Process (ROP) including engineeringhechnical review, inspection, assessment, enforcement, security, and emergency response functions for all NRCs operating reactors in the northeast (Region I) and southeast (Region 11). As a senior nuclear safety and engineering consultant, provide advice to national and international nuclear utility and governmental managers regarding nuclear reactor licensing and inspection policy. Advise the nuclear industry regarding advanced reactor policy.

License Renewal-Served as the NRCs Chairman of the License Renewal Steering Committee.

Provided NRC oversight of the technical staffs safety evaluation and environmental reviews as well as the budgeting and management of resources to implement Commission policy. Served as the NRC principle spokesman along with the Industry Steering Committee Chairman during periodic open public meetings to discuss high priority issues needing regulatory decisions.

Supervised Regional inspections of aging management programs.

Engineering and Technical Reviews-As Deputy Director, NRR, responsible for NRC policy on engineering and technical reviews including regulations and industry standards endorsed for implementation, for NRC reviewer qualifications, and for the preparation of safety evaluations of license applications. As consultant to a major nuclear utility, review self assessments of engineering processes and design controls including safety design margins for critical components and systems. As Deputy Regional Administrator was responsible for oversight of all inspections of design and engineering activities at all power and research reactors and fuel facilities in the Southeastern US; as senior NRC executive in charge of the NRC Inspection Page 7 of 18

Corrective Action Proaram ImDlementation Assessment Plan - 2008 Manual Chapter (IMC) 0350 process for oversight and performance improvement of the Brunswick and Browns Ferry stations, provided oversight of all regulatory reviews of engineering design and construction activities. As NRC Manager in Region I, led the Team which determined that Seabrook was constructed in substantial conformance with the engineering processes and design as described in the FSAR, a major factor in the operating license issuance.

Quality Assurance Programs-As Member of Safety Review Board for nuclear utility review all aspects of quality assurance activities and non-conformance reports as well as all self assessments of safety related activities. As an NRC inspector and Manager, reviewed detailed implementation of NRC requirements in 10 CFR 50, Appendix B.

Spent Fuel Repository Reviews-As the Chairman of the Executive Assessment Board and a Member of the Executive Team, evaluated major DOE effort to prepare a license application to the NRC for the worlds first deep geological spent he1 repository. Provided regulatory advice and licensing guidance.

Administration.- As Deputy Regional Administrator, Region 11, directly responsible for administering licensing, inspection, enforcement, budgeting, travel, human resource, legal, public affairs, state liaison, training, and emergency preparedness programs for one of NRCs largest regional offices. This included reactor safety as well as radioactive materials safety (medical and industrial) and fuel facility safety programs.

Security-Served as special senior safety and security advisor to the NRCs Office of the Executive Director for Operations; managed twelve teams to assess safety and security strategy at all power plants in the U.S. As the Associate Director for Inspection and Programs, and Deputy Director, Office of Nuclear Reactor Regulation, responsible for physical security inspection and licensing programs as well as security regulation development at all civilian reactors in the US. Following 9-1 1, served on NRCs Executive Task Force to establish strategic plan for NRCs comprehensive re-evaluation of security effectiveness and establish interim requirements.

Diagnostic Evaluations and Self Assessments-As NRC manager and inspector, served on numerous inspection teams evaluating licensees self assessment program effectiveness. Served as NRCs SES manager and chairman of the Brunswick and Browns Ferry IMC0350 oversight panels to monitor and lead the recovery actions from prior poor performance. Subsequently both facilities completed world records for safe operating periods.

Nuclear Oversight-Served as member and chairman of nuclear oversight boards for major US utility and major DOE contractor. Provided advice to CNO and President on matters involving nuclear safety, operations excellence, and licensing strategies.

Training and Qualification-As Associate Director and Deputy Director of NRR, was directly responsible for NRCs inspector training and qualification programs as well as oversight of civilian reactor operator licensing and training programs. Directly monitored revision of NRCs inspector training and qualification program and served as chairman of certification boards. In Page 8 of 18

Corrective Action Pronram Implementation Assessment Plan - 2008 US Navy served as Division Director, responsible for course of instruction for 15 instructors and 800 students in course relating reactor physics to a naval nuclear power plant.

As nuclear safety consultant, developed and presented unique course on risk-informed regulatory approaches and inspection techniques to Eastern European regulators and utility managers.

Principal expert speaker at workshops in Europe for the IAEA on nuclear regulatory strategies in a deregulated electricity market and use of technical support organizations by the regulator.

Public Communications-As Executive in NRC headquarters as well as two Regional offices represented the NRC to the White House, Congress, state and local officials, the public and news media. Chaired NRC steering committees, public meetings, workshops, licensee performance reviews and enforcement conferences. Served as NRCs chief spokesman during emergency exercises.

Reactor Operations - As a senior nuclear safety consultant, provide reactor operations and nuclear safety advice to nuclear utility managers. As NRC executive in two Regional offices as well as headquarters, was responsible for the safety oversight (ROP) of 103 operating power reactors and 36 research reactors in the US. As NRC Senior Resident Inspector, conducted daily reactor plant operations and maintenance inspections and regulatory oversight. As US Naval officer, qualified as Chief Engineer and Engineering Officer of the Watch. Directed dual-reactor plant operations at sea and during refueling overhaul. As an NRC inspector and Regional manager, directly responsible for construction completion and operational readiness inspections and regulatory oversight for power reactors in the licensing stage. As Region I1 executive, chaired NRCs licensing and inspection IMC 0350 panels to assess readiness of Progress Energys Brunswick site and TVAs Browns Ferry reactor to restart following extended shutdown periods. As US Naval officer conducted readiness assessments prior to plant restarts.

Emergency Preparedness-Responsible for NRCs Regional office and Headquarters reactor safety incident response functions. Served as member of NRCs Executive Team in HQ incident Response Center during the Indian Point 2 steam generator tube rupture and response to the 9-1 1 attack on the World Trade Center. Participated on many exercises as well as directed NRCs emergency response to reactor events. Completed training and qualification as NRC Team Leader for Incident Investigation Teams.

Strategic Planning-Served as NRCs Office of Nuclear Reactor Regulation representative on NRCs Strategic Planning Panel to update and reform the agencys Strategic Plan.

Recommended and developed key approached to strategies, goals, and objectives as well as methods and means of measuring effectiveness or success.

Professional Experience Independent Consultant, 2003 to Present: Senior Nuclear Safety Consultant Member of Off-Site Safety Committee for major US nuclear utility providing advice and guidance on reactor safety and engineering management. Provide regulatory and technical advice to major reactor vendor on Design Certification. Provide management advice and conduct safety assessments for US DOE. Senior safety and security advisor to the NRCs Office of the Executive Director for Operations. Provided advice on risk-informed licensing approaches and inspection techniques for international regulators and utility managers. Chair of Executive Page 9 of 18

Corrective Action Program Implementation Assessment Plan - 2008 Assessment Board for DOE M&O contractor. Member of Executive Team providing regulatory advice and licensing guidance for a geological spent fuel repository for the Department of Energy.

US Nuclear Regulatory Commission, 1978 to 2003: Senior Executive Deputy Director, Office of Nuclear Reactor Regulation-assisted the Director in managing a staff of 600 highly skilled personnel in the engineeringkechnical reviews, licensing, inspection, assessment, event response, security, and rulemaking activities at all nuclear reactor facilities in the US. Responsibilities included the technical review, certification, and licensing of advanced reactors and the renewal of current power reactor operating licenses. Held progressively more responsible supervisory positions including Senior Resident Inspector and Branch Chief in Philadelphia and Director, Division of Reactor Projects and Deputy Regional Administrator in the Atlanta office. Responsible for engineering, maintenance and operations inspection, enforcement, security, and emergency response functions for reactors and fuel cycle facilities.

Qualified in boiling and pressurized water reactor technologies, nuclear criticality controls for nuclear fuel facilities, and various root cause analyses techniques.

United States Navy, 1970 to 1978: Nuclear Trained Officer Reactor Mechanical Assistant on nuclear powered aircraft carrier in charge of dual-reactor operations and all nuclear mechanical systems as well as all chemistry and radiological controls.

As Director, Division of Reactor Principles, US Naval Nuclear Power School, supervised 15 instructors and 800 students in course of instruction for the application of nuclear physics to a naval nuclear power plant. Directly supervised and operated a dual-reactor nuclear powered cruiser at sea and during a refueling overhaul. Graduated in top 15% of nuclear power school.

Security Clearance Active DOE Q Clearance Inactive NRC Q Clearance Certifications and Accreditations Chairman Executive Oversight Board for major DOE M&O contractor Member of Off Site Safety Review Committee for major US Nuclear Utility Principle speaker for IAEA workshops for European utility and regulatory managers Chairman NRC License Renewal Steering Committee Chairman NRCs Oversight Panel for IMC 0350 Reviews Member NRCs SES Performance Review Board Certified NRC Inspector and Incident Investigation Team Leader Registered Professional Engineer, Commonwealth of Massachusetts Qualified as Chief Nuclear Engineer and Engineering Officer of the Watch, US Navy A wards Presidential Rank Meritorious Executive Award NRC Performance and Special Achievement Awards NRC EEO Award for Outstanding Recruitment of Hispanic Engineers Page 10 of 18

Corrective Action Program Implementation Assessment Plan - 2008 Paul D. Swetland During a 35+ year career in civilian and naval nuclear power, Mr. Swetland has integrated a detailed knowledge of power plant operations with a vigilant safety perspective. He has recent experience assessing and implementing utility corrective action programs at Davis-Besse and Kewaunee, and has led and participated in NRC team and individual inspections. Mr. Swetland successfully managed several NRC regulatory programs involving maintenance, engineering, and operation of nuclear facilities, and developed a talent for assessment of nuclear utility performance, including root cause analysis.

Education B.S., Naval Architecture, U.S. Naval Academy, 1971 Professional Experience Advanced Technologies and Laboratories International, Inc. (ATL), 1998 to Present: Senior Executive Consultant.

Mr. Swetland conducted Component Design Basis Audit and NRC inspection preparation and follow-up at Kewaunee Power Station (January to February 2007). He independently assessed Davis Besse corrective action program implementation (August 2006); performed comprehensive root cause analysis for the Davis-Besse corrective action program; and implemented corrective action program restart improvement plans for the Davis-Besse NRC Inspection Manual Chapter (IMC) 0350 recovery effort (September 2002 to June 2003). Mr.

Swetland generated NRC operator license exams for Duke Power and Florida Power and Light Company plants. He assessed operator license candidates at St Lucie, McGuire, and Catawba and conducted audits of the fire protection program at Prairie Island.

Nuclear Regulatory Commission, 1996 to 1997: Project Engineer (Projects Branch Chief; July-September 1997).

Mr. Swetland coordinated NRC inspection findings, allegations, and performance assessments for the Limerick, Peach Bottom, and Susquehanna nuclear generating facilities. He conducted corrective action program effectiveness inspections at Limerick.

1980 to 1996: Senior Resident Inspector (Millstone, August 1992 - October 1996, Haddam Neck, November 1983 - July 1987, Maine Yankee, January 1980 - November 1983).

Mr. Swetland was the lead NRC inspector at three separate nuclear generating facilities. He planned, coordinated, and conducted safety inspections to verify maintenance of public health and safety and compliance with NRC regulations, and directed the site inspection staff. Mr.

Swetland drafted utility performance assessments and presented the results to NRC and utility management; represented the NRC in discussions with the media and State and local officials; performed event response inspections including a feed line rupture at Maine Yankee, a reactor cavity seal failure at Haddam Neck, and a drywell spraydown event at Millstone; and participated in integrated and readiness assessment team inspections at Haddam Neck, Indian Point and Millstone.

1991 to 1992: Industrial Applications Section Chief.

Mr. Swetland managed the NRC licensing and inspection of over 500 industrial users of source and byproduct radioactive material. He approved inspection documents and coordinated Page I 1 of 18

Corrective Action Program Implementation Assessment Plan - 2008 enforcement sanctions; participated in event response and Site Decommissioning Management Program activities; supervised eight assigned inspectors/license reviewers; and directed the Branch personnel recruitment efforts.

1987 to 1991: Projects Section Chief.

Mr. Swetland managed the NRC inspection, performance assessment, enforcement, and events response programs for the SaledHope Creek, Susquehanna and Indian Point nuclear generating facilities. He supervised field office personnel, including resident inspectors and clerical personnel, and led integrated performance assessment (DET precursor) and augmented incident team inspections. Mr. Swetlands rotational assignments included Projects Branch Chief and Events Assessment Branch Chief (HQ).

Bath Iron Works, 1979 to 1980: Maritime Program Administrator.

Mr. Swetland administered a $1.5 million government research and development contract for the commercial shipbuilding industry.

Submarine Officers Basic School, 1978 to 1979: Senior Instructor.

Mr. Swetland coordinated the curriculum development and instruction of a 12-week course in all aspects of submarine design, safety and operations. He supervised six instructors and up to 120 students.

Naval Submarine School, 1977 to 1978: Sonar Instructor.

Mr. Swetland developed and taught submarine sonar technology courses for naval officers.

SSN 680, 1975 to 1977: Weapons Department Head.

Mr. Swetland managed all aspects of submarine weapons and sensor system operations and maintenance. He was responsible for the training, development, and administration of a staff of 25 degreed engineers, skilled technicians, and laborers. His department was designated best Weapons Department in the Squadron.

SSBN 640, 1973 to 1975: Engineering Division Officer.

Mr. Swetland directed the operation, maintenance, and overhaul of various naval nuclear propulsion and support systems. He supervised 20 nuclear-qualified technicians and managed the ships radiological protection and chemistry programs.

Kenneth G. Murphy Mr. Murphy has 45 years of experience in engineering, consulting services, process safety management, safety training, and team management. He has proven expertise in leading multi-discipline safety assessment teams and accident investigation. He has developed strong planning, organizational, and communications skills during his extensive experience in assessing the safety of nuclear and chemical processes. He has a sound understanding of both process and occupational hazards and their control, including the application of job hazards analysis and nuclear reactor quantitative risk assessment. He has demonstrated ability to work with managers in evaluating their management systems and in improving performance.

Education M.S., Engineering Management, George Washington University, 1973 Page 12 of 18

Corrective Action Program Implementation Assessment Plan - 2006 Certificate Nuclear Science, Oak Ridge School of Reactor Technology, 1963 B.S., Nuclear Engineering, New York State Maritime College, 1962 Pro fessiona I Experience Advanced Technologies Laboratories International, Inc. (ATL), 1999 to Present: Senior Program Analyst.

Mr. Murphy provides a broad range of nuclear and non-nuclear safety consulting services in the areas of safety analysis, accident investigation, safety management system improvements, process safety management, probabilistic risk assessment (PRA), and field assessments.

U. S. Department of Energy (DOE), June 1988 to April 1999: Director of the Safety Technology Division; Chemical Safety Team Leader.

Mr. Murphy initiated the Departments PRA overview program. This program included the development of PRA methods and documentation guidelines, quantitative safety goals, and their implementation procedures. Mr. Murphy also implemented PRA training classes for DOE staff and contractors, and is the Founding Editor of DOES Risk Management Quarterly (currently the Risk Excellence Notes). He also initiated detailed reviews of the PRAs of the entire Departments production and Category A nuclear reactors. In addition, Mr. Murphy upgraded the Departments safety analysis report (SAR) order to reflect new thinking on improved analyses, use of PRA, risk management, and human factors. He also supported Defense Programs in its effort to start the Savannah River production reactors and the Rocky Flats facilities. His work involved assuring that safety significant insights identified by risk analyses were handled correctly and that the contractors performance in implementing new requirements was adequate.

Mr. Murphy also initiated DOEs Chemical Safety Program to bring the safety of DOEs chemical activities on par with its nuclear operations. He helped establish strong ties with chemical industry safety experts and catalyze interest in DOE management in networking with industry safety experts. He also participated as a board member in an investigation of a chlorine accident at the Argonne National Laboratory - West. As a DOE representative, Mr. Murphy assisted the U.S. Chemical Safety and Hazard Investigation Board in adapting DOEs accident investigation protocols to the Boards specific needs in the investigation of chemical industry accidents. He also conducted HAZOP analyses at Rock Flats and Hanford to demonstrate the methods usefulness to DOE. As Director of the Safety Technology Division, Mr. Murphy managed the work of eight process safety engineers. As the Chemical Safety Team Leader, Mr.

Murphy managed five DOE employees and three contractors.

Nuclear Regulatory Commission, Region 1, March 1984 to June 1988: Technical Assistant to the Director of the Division of Reactor Projects; Technical Assistant to the Director of the Division of Reactor Safety; Special Test Programs Section Chief.

As Technical Assistant to the Director of the Division of Reactor Projects, Mr. Murphy worked with resident inspectors on TMI action items, initiated special inspections, developed temporary instructions, and assured their completion by the residents. He also planned resident counterpart meetings. As Technical Assistant to the Director of the Division of Reactor Safety, Mr. Murphy planned and led six major PRA-directed inspections at LWRs, which uncovered safety-significant weaknesses in management programs, plant operations, equipment maintenance, and system testing. He directed the activities of six to eight inspectors. He also developed an inspection module to document the newly developed inspection techniques that used PRA. In Page 13 of 18

Corrective Action Program Implementation Assessment Plan - 2008 addition, Mr. Murphy conducted specialized and augmented team inspections, e.g., main coolant integrity, electric power, emergency heat removal, and Event V. He also supported the Regional Administrator and Division Directors by providing reliability and risk analysis used for decision-making. Mr. Murphy provided training at resident counterpart meetings and for the Regional staff on inspection methods, use of PRA to focus inspections, and instructions on current inspection initiatives. He also developed emergency diesel generator course in cooperation with Kings Point. As Special Test Programs Section Chief, Mr. Murphy managed eight regional inspectors.

U.S. Nuclear Regulatory Commission, Office of Research, March 1978 to March 1984:

Project Manager.

Mr. Murphy analyzed plant design and operational procedures to discover weaknesses that impacted reliability or safety, and used insights from PRAs to recommend changes in safety regulations, plant design, and procedures. Mr. Murphy was Project Manager for IREP PRAs and conceived of and initiated the Commissions most advanced PRA at the LaSalle plant. Mr.

Murphy performed reliability analyses for the reactor protection systems of the four major reactor vendors in support of the ATWS Rule, and performed reliability analyses for auxiliary feedwater systems. This was the first major use of PRA that findamentally changed the Commissions attitude toward the use for systematic risk analyses.

U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, January 1972 to March 1978: Nuclear Engineer.

Mr. Murphy determined the effectiveness of safety systems to minimize release of radioactivity.

He formulated regulations on design basis accidents and control room habitability (protection against both radiological and chemical accidents), and assured their implementation. Mr. Murphy developed computer programs for radiological transport from the containment to the control room, and the site boundary for the determination of operator and public exposure. He took lead positions on a number of committees, including the task force on emergency instrumentation, formulated regulations, and assured implementation of the emergency plans at commercial nuclear reactor sites, and made major contributions to safety guides and the standard review plan.

Hittman Associates, May 1966 to January 1972: Nuclear Engineer.

Mr. Murphy assessed the reliability and safety of the Transit, Snap 19, and Snap 27 space energy systems, and developed air dispersion programs for in-close and worldwide impacts of postulated launch vehicle accidents. He also conducted life and qualification tests of Snap 19 generators, as well as analyzed six alternative flue gas processing methods for the reduction of stack gas emissions from coal fired power stations. Mr. Murphy contributed technical approaches that won a number of important contracts.

U.S. Atomic Energy Commission (AEC), August 1962 to May 1966: Project Manager; Field Engineer.

Mr. Murphy performed core and shielding calculations for the Military Compact Reactor. He served as Project Manager for R&D programs for space power, including high-speed gas turbines, gas bearings, heat pipes, thermoelectrics, and solar cells. Mr. Murphy was also AECs representative overseeing the construction of the High Temperature Lattice Test Reactor and the Plutonium Recycle Experimental Facility.

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Corrective Action Program Implementation Assessment Plan - 2008 Special Training Over 1,500 classroom hours of technical and management courses at NRC and DOE.

Professional Associations American Society of Mechanical Engineers Frequent participant at ASME, AICHE, ANS, PSAM meetings as meeting organizer, chairperson, and speaker Past DOE Representative for Chemical Safety at the Center for Chemical Process Safety and the Chemical Manufacturers Association William W. Webster - Industry Peer Professional Experience Surry Power Station, February 2008 to Present: Supervisor Station Nuclear Safety Mr. Webster provides management of the Surry Power Station Corrective Action program, including oversight of the cause determination evaluations and methods, trending program, corrective action assignments and reviews, and outage startup assessments, He also provides supervision of the Shift Technical Advisors (STA) who provide shift technical support in accordance with NUREG 0578 and 0737. As such, the STAs primary duties are nuclear safety, compliance with design basis and operational documents, and assisting the Shift Manager, as required.

December 2006 to February 2008: Supervisor Civil Engineering Design Mr. Webster provided supervision of the station Civil Engineering Design department. His primary responsibilities included providing structural and hydraulic design inputs to station planned and emergent work in support of safe and reliable operations. He provided oversight and design support for the station lifting and rigging program in compliance with NUREG 061 2 (Heavy Load) program; performed Maintenance Rule evaluations of structural components; performed inspections and evaluations in accordance with ASME XI requirements for containment concrete inspections; and performed structural analysis for supports and piping systems for station design changes.

August 2001 to December 2006: System Engineer Mr. Webster provided engineering support and ownership/leadership of assigned systems, including operational support, troubleshooting, cause evaluations, Maintenance Rule evaluations, and corrective actions, and proposed modifications to ensure safe and reliable operation. Systems included fire protection, building structural systems, bearing cooling, and plumbing and sewage systems. Mr. Webster was also involved in program ownership for Appendix R program, station flooding, and Security Order B.5.B-required evaluations, procedure development, and program implementation.

1993 to August 2001: Shift Technical Advisor Mr. Webster provided shift technical support in accordance with NUREG 0578 and 0737. As such, the STAs primary duties are nuclear safety, compliance with design basis and operational Page 15 of 18

Corrective Action Program Implementation Assessment Plan - 2008 documents, and assisting the Shift Manager, as required. Mr. Webster trained in 10CFR50.59 evaluations and Root Cause Lead.

June 1990 to 1993: Engineer, Station Nuclear Safety Department Mr. Webster provided technical support of the stations corrective action program, including responsibility of the corrective action program coordinator. He performed reviews of station deviations reports and made appropriate corrective action assignments. Mr. Webster is qualified as Root Cause Team lead and participated in root cause teams and station self assessments.

Kim Kieler - Industry Peer Professional Experience South Texas Project, 2006 to Present: Quality Audits Supervisor Ms. Kieler is responsible for the scheduling and performance of all station audits. She supervises lead auditors that lead all station audits; maintains oversight of Master Scope Lists for continuous in-field monitoring in support of audit objectives; and has supervisory responsibilities, including condition report screening and significance determination, which includes initial cause and event code assignment. Ms. Kieler has 30 years experience in Quality oversight activities. She is a Quality Inspector Level I1 - Multi-discipline (Mechanical; Electrical; I&C; Civil; Visual Weld VT-1,2, 3; Receipt Inspection and Material Testing) and performs in-field Quality Inspection activities during refieling outages.

1989 to 2006: (Multiple roles)

Ms. Kieler was a Qualified Lead Auditor in 2000. She was responsible for oversight and leading numerous plant audits, was team member, and led NUPIC audits and surveys. All audits included departmental corrective action program evaluation. Ms. Kieler was a CAP Supervisor in 1995. Her supervisory responsibilities included condition report screening and significance determination, including initial cause and event code assignment.

1982 to 1989: Ebasco Constructors Inc., Quality Inspector Level I1 Civil discipline Ms. Kieler was responsible for inspection of various civil activities during the construction phase of the South Texas Nuclear Project.

1978 to 1982: Brown & Root Inc., Quality Inspector Level I1 Civil discipline Ms. Kieler was responsible for inspection of various civil activities during the construction phase of the South Texas Nuclear Project.

Jeff Bonner - Industry Peer Professional Experience Diablo Canyon Power Plant, 2002 to Present: Performance Improvement Coordinator Mr. Bonner is a member of the Corrective Action Program group. He is responsible for performing equipment and process root cause analysis in support of the DCPP corrective action program. He has 27 years experience in the commercial nuclear power industry, specialized in Quality Assurance/Quali ty Control program development, imp1 emen t ation, and administration.

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Corrective Action Program Implementation Assessment Plan - 2008 Project Assistance Corporation, 1998 to 2002 Mr. Bonner subcontracted to British Nuclear Fuel Solutions (BNFL-FS) to perform Quality Assurance consulting. He was responsible for corrective action program development, implementation, and management reporting. He also provided additional quality assurance assistance as requested.

Crystal River Unit 3, 1997: Quality Assurance Department Technical Advisor Mr. Bonner performed surveillance of maintenance and operations activities in support of facility restart schedule while on the NRC watch list. He assisted in the performance of scheduled corporate audits and reviewed restart issue packages for accuracy and completeness prior to NRC submittal.

Diablo Canyon Power Plant, 1990 to 1997 Mr. Bonner participated in various activities, including root cause analysis, logistics support for maintenance during outages, quality problem identification, and resolution tracking.

Subcontractor/Consultant, 1980 to 1990 Mr. Bonner was employed by several different nuclear consulting firms as a Level I11 electrical inspector, Certified Quality Auditor, Level I1 instrument inspector, and Level 111 receiving inspector.

US Navy, 1967 to 1980: Chief Electrician on US submarines Mr. Bonner was responsible for operating submarine propulsion systems and maintaining ship electrical distribution and control systems. He is qualified as engineering watch supervisor, surface lookout, ships diver, and helmsmadplanesman.

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Corrective Actton Program Implementatton Assessment Plan - 2008 ASSESSMENT PIAN APPROVALS:

Approved by:

Date: 41 Ol aoog Page 18 of 18