ML022550226

From kanterella
Jump to navigation Jump to search
Transcript of Public Meeting at Oak Harbor High School, Oak Harbor, Oh Re Davis-Besse Plant
ML022550226
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 08/20/2002
From:
FirstEnergy Nuclear Operating Co, NRC/RGN-III
To:
References
Download: ML022550226 (147)


Text

1 1

2 PUBLIC MEETING BETWEEN U.S. NUCLEAR REGULATORY COMMISSION O350 PANEL 3 AND FIRST ENERGY NUCLEAR OPERATING COMPANY OAK HARBOR, OHIO 4 ---

5 Meeting held on Tuesday, August 20, 2002, at 2:00 p.m. at the Oak Harbor High School, Oak Harbor, Ohio, 6 taken by me Marie B. Fresch, Registered Merit Reporter, and Notary Public in and for the State of Ohio.

7 ---

8 PANEL MEMBERS PRESENT:

9 U. S. NUCLEAR REGULATORY COMMISSION 10 Mr. John Grobe, Chairman, MC 0350 Panel William Dean, Vice Chairman, MC 0350 Panel 11 Anthony Mendiola, Section Chief PDIII-2, NRR 12 Christine Lipa, Projects Branch Chief Jon R. Johnson, Deputy Director 13 Office of Nuclear Reactor Regulation Washington, D.C.

14 Douglas Simkins, NRC Resident Inspector Melvin Holmberg, Metallurgist, Region 3 15 FIRST ENERGY NUCLEAR OPERATING COMPANY 16 Lew Myers, FENOC Chief Operating Officer 17 Robert W. Schrauder, Director - Support Services 18 J. Randel Fast, Plant Manager James J. Powers, III 19 Director - Nuclear Engineering L. William Pearce, 20 Vice President FENOC Oversight Clark Price, Manager - Business Services 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

2 1 MR. GROBE: Good afternoon.

2 My name is Jack Grobe. Im the Chairman of the NRC 3 Oversight Panel for the Davis-Besse Nuclear Power Station.

4 This is our next in a series of monthly meetings, public 5 meetings to discuss between the NRC and First Energy 6 Nuclear Operating Company the status of the Davis-Besse 7 Plant and their approach to activities that are intended to 8 get them to restart Davis-Besse.

9 What I would like to do to start is to introduce the 10 NRC staff that are here today, and then ask Mr. Myers to 11 introduce his staff here on the stage.

12 I would like to point out also that there is a 13 handout available to members of the public out in the area 14 outside the auditorium. If you neglected to pick one up, 15 please pick one of those up.

16 Again, my name is Jack Grobe. On my immediate left 17 we have a special visitor today. His name is Jon Johnson.

18 Jon is the Deputy Office Director for the Office of Nuclear 19 Reactor Regulation in our headquarters office in Rockville, 20 Maryland.

21 On my far left is Mel Holmberg. Mel is Senior 22 Metallurgist for Region 3 Office in the Chicago NRC 23 Office.

24 Tony Mendiola is next to Mel. Tony is the 25 Supervisor of the Licensing Organization thats responsible MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

3 1 for Davis-Besse in our headquarters office.

2 Bill Dean is the Deputy Chairman, Vice Chairman of 3 the Oversight Panel. Hes the Deputy Director of the 4 Division of Engineering in our headquarters offices in 5 Rockville.

6 On my immediate right is Christine Lipa. Christine 7 is the Branch Chief in Region 3 in Chicago responsible for 8 Davis-Besse.

9 (Noise) 10 We have some competing noise. If youre unable to 11 hear me for any reason, please raise a hand or throw 12 something up here, we can make sure that you hear.

13 In addition up here on the stage is Doug Simpkins.

14 Doug is the Resident Inspector. He works at the 15 Davis-Besse Plant for the NRC.

16 (Off the record/fixing microphones) 17 MR. GROBE: Maybe its not a 18 mike problem.

19 I was introducing Doug Simpkins. Doug is the 20 Resident Inspector. He works for the NRC here at the 21 Davis-Besse Plant and lives in the community.

22 Also in the audience is Rolland Lickus. Rolland 23 raise your hand back there. Rolland is our State Governed 24 Affairs Liaison out of our Region 3 Office in Chicago.

25 In addition in the audience is Vyka Mitlyng. Vyka MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

4 1 is one of our Public Affairs Officers out of the NRC Region 2 3 Office.

3 And Nancy Keller, Resident Office Assistant, here 4 assisting us in the logistic of this meeting.

5 I also want to thank the Oak Harbor High School and 6 particularly Mr. Stucker for facilitating these meetings.

7 Hes done an outstanding job.

8 Lew, why dont you introduce your staff.

9 MR. MYERS: With us today in 10 the audience we have Bob Saunders, the President of First 11 Energy Nuclear Operating Company. Raise your hand or stand 12 up. His wife, Carol. My wife, Linda.

13 Gary Leidich is the Executive Director -- or 14 Executive Vice President of the Nuclear Operating Company.

15 Steve Loehlein is with us today. Steve was the 16 person that did the Technical Root Cause Report and also 17 headed the team of Nuclear Management Root Cause.

18 David Gudger is with us. He is in charge of our 19 Corrective Action Group.

20 Tim Chambers is here.

21 Mark McCullough is with us; Containment Health.

22 Dave Baker is Reactor Head. I think hes on 23 schedule.

24 And then Mike Ross is with us today. And hes here 25 as Operation Excellence Plan.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

5 1 Tony Seller, Restart.

2 And then Dave Eshelman is Management Performance.

3 To my left, Jim Powers at the table. Jim is the 4 Director of Engineering. He came to us from the Perry 5 Plant. Hes also running the programs reviews and the 6 system reviews.

7 Bob Schrauder next to him. Bob came to us from 8 Perry also. He is the Director of Support and hes here 9 for the Nuclear Reactor Vessel Head Project.

10 And Clark Price is with us today. And Clark is 11 going to give you some status on some of our performance 12 indicators, and Clark is running the Restart Action Plan, 13 if you will.

14 Next to me is Bill Pearce. The last time you were 15 here, you asked for some quality reviews, so we brought 16 Bill with us today.

17 And then Randy Fast is with us also. Randy is our 18 Plant Manager in charge of Containment Health.

19 Im Lew Myers, Chief Operating Officer of First 20 Energy Nuclear Operating Company.

21 MR. GROBE: Okay, thank you.

22 Sounds like we have the problem solved. Thats 23 great.

24 At this time, I would like to turn the agenda over 25 to Christine Lipa. Christine is going to summarize some MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

6 1 recent activities and facilitate a discussion of our 2 research checklist, as well as recent inspection plans.

3 Christine.

4 MS. LIPA: Okay, thank you.

5 The couple other things I wanted to mention, Jack 6 mentioned we had handouts in the foyer. The Licensee also 7 brought a handout.

8 And we also have feedback forms that will enable 9 anybody who wants to give us feedback on how this meeting 10 goes, so we can incorporate those feedback items into 11 future meetings.

12 The next thing on the agenda I would like to cover 13 is the summary of the last monthly meeting that we held 14 here in Oak Harbor, as well as the meeting we held last 15 week in the Region 3 Office in Lisle, Illinois.

16 So, well go to the next slide.

17 This really just covers a few of the milestones that 18 have taken place since March, with the risk assessment that 19 the First Energy folks submitted in April.

20 The Root Cause Analysis Report that focused on the 21 technical issues were submitted in April, on April 18th.

22 Licensee submitted their Return to Service Plan on 23 May 21. That was revised on July 12. Its been revised 24 again just recently in August.

25 And then, of course, we held a public meeting last MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

7 1 week in the Region 3 Office in Lisle, Illinois, and we have 2 handouts that are available on the web page. The Licensee 3 will be summarizing that discussion later in this meeting 4 tonight.

5 Just to go over what we covered at last months 6 public meeting here in Oak Harbor, is the next slide. Its 7 a summary of that meeting and we focused on the Licensees 8 Return to Service Plan and their 7 Building Blocks.

9 I wanted to point out that the transcript, this 10 meeting tonight is being transcribed, by the way, but also 11 the transcript for that July 16th meeting is available on 12 our website, with more detailed discussion.

13 Here is some of the highlights of what we talked 14 about last month. We talked about the Licensees efforts 15 on the reactor head resolution. They purchased the Midland 16 head, cleaned it, moved it here and are preparing to 17 install it, by opening the containment.

18 Then we also talked about the Containment Health 19 Plan. One of the things in there was that the Licensee had 20 expanded the scope of their efforts in looking at 21 containment health and looking at other compliments besides 22 those affected by boric acid in the containment. Looking 23 at the vessel liner in terms of integrity of the vessel 24 liner; also looking at the containment air coolers.

25 Then we talked about the System Health Assurance MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

8 1 Plan and the progress that theyve made. And looking at 2 their programs, they gave us a sense of where theyre 3 headed with what types of things theyre looking at in 4 those programs. And we do plan some future inspections on 5 all of these plans, but at the public meetings we discussed 6 their progress and the systems that they were focusing on 7 and what else they were planning to do, and what they were 8 doing with those findings.

9 Again, thats what Clark Price is planning to talk 10 with us about later, the various findings that come out of 11 these reviews.

12 And then we also talked about Management and Human 13 Performance Excellence Plan, and that was really a big 14 focus of the meeting that was held last week in the Region 15 3 Office, was to understand what this months of effort in 16 looking at the root cause and trying to determine what it 17 really was, what the root causes were and what the plans 18 are for corrective action.

19 We really didnt focus too much on the last two of 20 the Building Blocks at last months meeting. So, that 21 covers the first two items on todays agenda.

22 The third item on todays agenda is a discussion of 23 NRC Restart Checklist. We did discuss this last month and 24 there have been a few changes, but well just go through 25 the, for your reference.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

9 1 The first page is basically unaffected from what you 2 saw last month. This was issued, by the way, on August 3 16th by the NRC. The Licensee has a copy of it. This will 4 be available on our website.

5 The second page is not too much change, but I did 6 want to talk about Item 6, which is what we call Licensing 7 Issue Resolution. And this covers various license 8 amendments and relief requests that are formal documents 9 between the Licensee and the NRC that cover very specific 10 items. And we have six of them listed between this page 11 and the next page.

12 And right now, these are the ones that weve 13 identified that are necessary for restart, but were still 14 working with, with NRC and with the Licensee to ensure that 15 we have a common understanding of which particular ones do 16 need to be resolved before we start, and if there are any 17 new ones.

18 Then on the third page of the checklist, there is a 19 new item here, which is number 7. All along we had planned 20 to do this piece, but we thought it was appropriate to 21 include it as part of the restart checklist.

22 Item 7 is a Confirmatory Action Letter Resolution in 23 March and it was revised in May. And that has very 24 specific items on it that the Licensee has agreed to do 25 before restart.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

10 1 As part of our O350 process, we will be assessing 2 each of those items, and closing each of those items. And 3 one of them in particular that weve added to the checklist 4 here is verification that all the Confirmatory Action 5 Letter Items are resolved. One of those include a public 6 meeting to discuss Readiness for Restart.

7 Okay. On the next item under agenda, Item 3 is a 8 status of the NRC inspections. And, recently we completed 9 the Augmented Inspection Team Follow-up. And just to 10 explain this a little bit. Back in April here, we had an 11 exit of the Augmented Inspection Team findings. And that 12 was, we had that exit here in April and their report was 13 issued on May 3.

14 Then I did find a lot of findings, a lot of 15 observations. It was summarized as several missed 16 opportunities for the Licensee to have identified the 17 condition over the years before it was identified in March 18 of 2002.

19 So, that report was issued in May. Its Report 20 2002-03. Thats available on our website.

21 So, what we did as part of the follow-up for that, 22 we held an Augmented Inspection Team Follow-up Inspection.

23 And we had, the exit meeting for that inspection was held 24 August 9th. It was not a public meeting. So, thats why 25 were discussing the results today. And those results will MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

11 1 be documented in Inspection Report 2002-08, which will be 2 on our website. Its still being prepared right now.

3 And in that report, the results that we have will be 4 considered as unresolved items until our risk assessment is 5 complete. And our risk assessment is one of the items that 6 we have been working on in NRC.

7 The next slide.

8 On the Augmented Inspection Team result is a little 9 more detail of the results of that inspection and numerous 10 apparent violations in five areas. And Ill go through 11 those five areas and Ill give you some examples, but I 12 just wanted to a little bit before we got into that, 13 explain the way this inspection works is the inspector goes 14 to the plant, reviews the documents, gathers the facts, 15 tries to put those facts together and then has an exit 16 meeting with the Licensee. After that, they come back to 17 the regional office and those findings go through the 18 management review.

19 So, were in the management review phase. So, the 20 findings are still considered preliminary until the report 21 is signed off.

22 All the items that we looked at as part of this 23 Augmented Inspection Team Follow-up are considered directly 24 related to the Vessel Head Degradation Issue. So, the 25 significance is being worked together.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

12 1 In accordance with our Inspection Manual 0612, which 2 is our guidance for regular inspection reports, all of 3 these issues, even though some of them appear to be 4 noncompliances or violations, will be characterized as 5 unresolved items. Theyre apparent violations whose 6 significance has yet to be determined.

7 When our significance determination process or risk 8 determination is completed, we will be able to issue those 9 violations and they will no longer be resolved --

10 unresolved items.

11 So, let me get into some of the examples. The first 12 one is an apparent violation of Technical Specifications, 13 which requires that there be no pressure boundary leakage; 14 and obviously because there were leakage, there was leakage 15 at the cracks in the nozzles, that is pressure valve 16 leakage, that is a violation of Technical Specifications.

17 The next area of violation was the adequacy of 18 corrective actions. And there were several apparent 19 violations of 10 CFR 50 which is a Code of Federal 20 Regulations, Regulation B16 for inadequate corrective 21 actions.

22 And the examples are numerous missed opportunities 23 to have identified the condition of the degradation of the 24 reactor vessel head, and some of the examples include the 25 deferral of the surface structure modification that would MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

13 1 have permitted access for adequate cleaning and inspection 2 of the vessel head.

3 Also inadequate corrective action for the radiation 4 monitor plugging that was going on inside the containment.

5 And the containment air cooler bin found that was going on 6 in the containment.

7 The next area of apparent violation is in 8 procedures, following procedures. And there were several 9 examples of procedures that were not being followed in the 10 boric acid, specifically the Boric Acid Corrosion Control 11 Procedure and the Corrective Action Procedure.

12 The fourth area was adequacy of procedures. And the 13 inspectors found problems with the Boric Acid Corrosion 14 Control Procedure regarding its adequacy. One example is 15 that focus was only on bolted connections and did not in 16 all cases require documentation of engineering 17 evaluations. It did refer to engineering evaluations that 18 needed to be done, but it did not require documentation.

19 The next area is completeness and accuracy of 20 information; and this is 10 CFR 50.9, Federal Regulation 21 50.9 that requires complete and accurate information. And 22 there were several documents that we looked at and there 23 are apparent discrepancies in the accuracy of some of those 24 documents, such as work orders, corrective action 25 documents, and responses to a generic letter and bulletin.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

14 1 And, the scope of this inspection did not focus on or 2 attempt to address the intent. It was mostly focused on 3 whether the document was correct or not.

4 Now, these findings are considered unresolved 5 items. And I mentioned that earlier, because the 6 significance is not completed yet, but also NRC Office of 7 Investigation still has investigations ongoing that relate 8 to some of these issues, so they will not, they will remain 9 unresolved items until that is completed.

10 Thats what I have for summary of the NRC 11 follow-up. Ill next turn it over to Mel Holmberg to talk 12 about one of the other inspections.

13 MR. HOLMBERG: Okay, thank you 14 Christine.

15 Im not sure, can people hear me? I dont hear 16 myself out in the audience. All right, thank you.

17 As Christine said, my name is Mel Holmberg. Im the 18 Lead Inspector for, associated with the Licensee 19 Containment Health Plan, and what Ill be discussing this 20 afternoon is the results of our NRC review on the 21 Licensees efforts at determining the extent of condition 22 for boric acid corrosion of components inside containment.

23 Basically, the effort that I will be discussing is 24 an effort of three weeks in length that the NRC conducted 25 reviews of the activities the Licensee conducted inside MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

15 1 containment; focused on areas like dissimilar metal welds, 2 some of the containment general area inspections, 3 including components such as the service water piping, some 4 of the containment liner areas, and also review of 5 videotapes the Licensee performed on the reactor vessel.

6 As a result of this inspection, which ended July 26, 7 the NRC identified two findings, which were considered 8 violations of NRC requirements. The first finding was 9 associated with lack of acceptance criteria and 10 requirements to follow inspection plans; and the second 11 finding was associated with inadequate training and 12 certification of inspection personnel.

13 And for the walkdown inspections, the failure to 14 properly certify inspection personnel. Some of the 15 observations that we had in terms of inconsistent methods 16 to track completion of inspections, and some of the 17 observations were where we identified additional components 18 that had evidence of corrosion, led the Licensee to 19 conclusions and our staffs conclusions that these 20 inspections were not entirely effective.

21 As a result the Licensee decided to repeat these 22 inspections, and that effort is currently underway.

23 Ill describe briefly each of the findings. Tell 24 you where theyre at right now with those items.

25 The first finding that was identified dealt with MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

16 1 lack of acceptance criteria requirements to follow 2 inspection plans. Here, there were three initial plans 3 that were used to actually direct field activities. And 4 these three areas that they focused on were dissimilar 5 metal welds, the reactor vessel and containment general 6 area.

7 However, these plants did not have the same quality 8 assurance program requirements that apply to the safety 9 related procedures, and they also lacked requirements or 10 acceptance criteria; failure to incorporate appropriate 11 acceptance criteria and implement requirements to adhere to 12 the plans is considered a violation of 10 CFR 50, NRC 13 Reg 5.

14 In response to that issue the Licensee has now 15 issued procedures instead of plans and has acceptance 16 criteria for each of the procedures and has begun again to 17 perform the inspections of the containment components.

18 The second finding dealt with inadequate training 19 and certification of inspection personnel. And this issue 20 centers around the standard that the Licensee had selected 21 to train personnel. Its called VT-2 Standard, and thats 22 a term that comes from the ASME or the American Society for 23 Mechanical Engineers. And to become a VT-2 inspector, the 24 requirement was to have six hours minimum training and 60 25 hours relevant work experience.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

17 1 I identified in fact neither one of those 2 requirements was met for the inspection personnel that were 3 used to conduct the inspection.

4 And again, this was considered failure to have the 5 required inspection training and hours work experience was 6 considered a violation of 10 CFR 50, NRC Reg 5.

7 Again, to correct this issue, the Licensee has 8 currently developed a new training standard which is, at 9 this point appears to be more rigorous than previous 10 training standard, and their personnel now have specific 11 requirements that need to be met both for written testing 12 and program standards that are being applied.

13 And basically, I will turn it back over to Christine 14 for further comments.

15 MS. LIPA: Okay. Thanks 16 Mel.

17 Couple of other inspections that we have ongoing 18 right now are the inspections of the new vessel head and 19 the co-data package. Also the opening and the closing of 20 containment. And then some other upcoming inspections 21 would be a review of the license and inspection of the 22 Licensee Program Review.

23 Well also be beginning our inspection of the 24 Management Human Performance Building Block and also 25 beginning review of the Systems Health Building Block. So, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

18 1 those are some other upcoming NRC inspections that will be 2 discussed at the next public meeting.

3 Thats all I have for Agenda Item 3.

4 Jack, do you have comments?

5 MR. GROBE: Lew, we provided 6 the results of our inspections in an ongoing fashion from 7 our staff when we were on site through regular interactions 8 with your staff, as well as at the completion of each 9 inspection through an exit interview. I wanted to briefly 10 summarize the results of inspections that have been 11 completed since our last public meeting, and give folks 12 here as well as yourselves a sense of what inspections we 13 expect to have subsequent to the results at our next public 14 meeting in September.

15 So, thats just a brief summary of the activities 16 that the NRC has had underway and expects to begin in the 17 next several weeks.

18 At this point, unless there is any other comments 19 from members of the panel, I would like to turn it over to 20 you and your staff.

21 MR. MYERS: Thank you.

22 Our Desired Outcomes today:

23 One is to, the first is to demonstrate that the 24 Integrated Schedule of activities at Davis-Besse is well 25 underway.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

19 1 Second, to introduce the actions to achieve and 2 ensure sustained Management and Human Performance 3 Excellence at Davis-Besse.

4 We recently did a root cause with the regulator, as 5 they said last week, and well discuss those root causes as 6 we go through the report, and other corrective actions as 7 we go forward.

8 Three is to provide indicators that demonstrate our 9 progress to date. A lot of activities going on at the 10 plant and to give you some of our performance indicators.

11 Final, fourth is to demonstrate increased standards 12 of quality oversight of the Quality Oversight Organization, 13 if you will. One of the key things that weve done is we 14 brought Bill Pearce with us today to talk about the issues 15 in our quality area.

16 And then finally, is to provide the status of some 17 of our other Building Blocks as time permits.

18 Next slide.

19 As you remember, at our last meeting, we have, as we 20 got into the Davis-Besse issue, we created six Building 21 Blocks, with the center being the collection of the Restart 22 Action Plan.

23 The Building Blocks consist of the Reactor Head 24 Resolution Plan, the Program Compliance Plan, the 25 Containment Assurance Plan, which is now a total Health MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

20 1 Assurance Plan of Containment, the System Health Plan, the 2 Restart Test Plan; we got to restart test all of the 3 activities that weve done during the outage; and finally 4 is Management Human Performance Excellence Plan that 5 restart completed.

6 Responsible for that plan was Bob Saunders, my boss 7 and I was responsible to the plant at the site; and 8 finally, I believe an independent team, Steve Loehlein 9 headed that team, that completed the reports and gave that 10 to us the first of last week.

11 Now, according to the recent, the Building Blocks 12 Report through the Restart Overview Panel that we had 13 yesterday, that panel is now chaired by Leo Karns. I think 14 Leo is with us today in the audience. There he is out 15 there. He is the new chair. He came up the last time, our 16 chairman. So, Leo is taking that function.

17 That group is a group of very impressive independent 18 individuals. And anybody that dont think theyre 19 independent, they could you tell you, come in and sit at 20 one of the meetings. They give us a lot of feedback on 21 some of the things we need to do as management team to 22 restart the Davis-Besse Plant.

23 In fact, what I would like to do is talk about some 24 of the things theyve given us already on recommendations.

25 Theyve given us over 80 recommendations formally. And MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

21 1 quite a couple hundred informally.

2 One of the recommendations they gave us was to 3 expand the scope of the Containment Health, to the new 4 Containment Health Plan, not focus just on boric acid, but 5 some of the long term issues that we have in our 6 containment that were trying to address now.

7 They also gave us some advice on developing 8 procedures and instituting stricter standards on quality.

9 And what we were finding out is these procedures, like the 10 word I use, primary word, prioritize becomes part of our 11 normal ways of doing business at the plant.

12 Finally, they place some, help us place some 13 independent oversight or review boards and subcommittees in 14 place. That can be engineering review boards that were put 15 in place. So, brought in some good talent there.

16 They suggested some specific plants that might be a 17 benchmark for management practices and standards that had 18 similar issues to our Davis-Besse Plant. Weve been to 19 those plants and picked up some improvements there that we 20 would talk about later on.

21 And finally, Safety Conscious Work Environment.

22 Something were all concerned about. I know that I have 23 meetings with the employees, our chairman, and several of 24 the members start coming to the plant and meeting with our 25 employees. And were really stressing safety conscious MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

22 1 work environment. Were looking to be, to be more 2 proactive, looking for issues.

3 And, then finally, the extended root cause to 4 consider what effect some of the things we were finding has 5 on all of our plants. Its important as we go across these 6 issues or find these strengths, that we carry these forward 7 to our other plants.

8 The next slide.

9 At the last meeting we talked about the 10 organization. There has been a couple of changes since 11 that time. Dave Gudger is now in charge of the Corrective 12 Action Program. I think hes with us today. Dave came to 13 us from our Perry Plant.

14 And also youll see on the slide that I have now 15 taken the duties as Site Vice President and will remain in 16 that position until after restart.

17 The first area that we want to talk about today are 18 the Management Root Causes. We had a meeting with the 19 Regulatory last week in Chicago, four-hour meeting went 20 over Root Causes, and Ill try not to spend that long 21 today, but try to brief you on what we told them.

22 Earlier investigations that we did, both from 23 Augmented Inspection Team and we did our Technical 24 Evaluation Process; both concluded one thing, that 25 management had ineffectively implemented processes and thus MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

23 1 failed to detect plant problems as opportunities arose.

2 And you heard that at the end of their investigation, that 3 opportunities to identify these problems were missed.

4 Knowing the history of the plant, we looked back and 5 decided to do the Technical Root Cause that was submitted 6 earlier this year, but we knew that since these missed 7 opportunities were management concerns, and we were going 8 to make management changes, that we had to wait to do our 9 Management Root Cause Reports, so we went ahead and did a 10 Technical Root Cause Report.

11 Before we did that, this strength in our 12 organization brought Gary Leidich in as Executive Director.

13 They promoted me to Chief Operating Officer and Executive 14 Vice President, and Bill Pearce as Vice President FENOC 15 Oversight. So, we wanted to get that out of the way.

16 Then, I was charged to come to the plant and we 17 chartered a Root Cause Team and we wanted to understand why 18 over the period of time, that Davis-Besse personnel failed 19 to identify the corrosion of the reactor pressure vessel 20 head. These were missed opportunities, if you would.

21 We wanted to go back. We had issues before that 22 failed to fix those problems, so it was important that we 23 went and go all the way down to understand the problem.

24 Let me share with you some of the things that we 25 found out. For root cause, there is never one root cause, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

24 1 there is lots of contributing causes, lots of root causes, 2 but weve lumped those in four basic areas that we think, 3 with the exit of the AIT team a couple of weeks ago, were 4 the findings that Christine went over, our report appears 5 very much in line with some of the issues that were brought 6 up there.

7 Lists, our people over time, there is a focus on 8 production, combined with minimum actions to meet 9 regulatory requirements that resulted in the acceptance of 10 the degraded conditions.

11 That sounds real good. Let me tell you what that 12 means. At a nuclear plant or any commercial plant there is 13 also a focus on production. Always a focus on production.

14 Thats what we do for a living. But we have to balance 15 that very carefully with nuclear safety and safety concerns 16 and assure that we do an appropriate technical review as we 17 find and fix problems.

18 If you look over about a five year period, what we 19 found is we had some degradation in that process, that we 20 were not thoroughly investigating issues as issues arose.

21 And thats one of the things that caused these missed 22 opportunities to exist.

23 The next area we reviewed was inadequate 24 implementation of the Corrective Action Program. We heard 25 the AIT report that the program was inadequate. Let me MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

25 1 tell you, the program did not meet all the bells and 2 whistles of the regulatory process. However, the program 3 was adequate to find and fix the reactor vessel head 4 problem. It was adequate to do that, but we failed to 5 implement the program appropriately.

6 The next area was failure to integrate and apply key 7 industry information and site knowledge and experience and 8 compare the new information to baseline knowledge.

9 The word that comes to mind there is complacency.

10 Davis-Besse over a period of years was an excellent 11 performer. And as time went by and industry experience in 12 specfic issues grew, we were complacent and we failed to 13 look at the industry experience and our own requirements, 14 if you will, and improve our programs and processes to look 15 for this issue. In fact, we tend to justify why the issue 16 didnt exist.

17 Some steps in the Boric Acid Corrosion Control 18 Procedure were not followed. If you go to look at the 19 procedure we had in place, there were several times that we 20 had missed opportunities that we were just not clearly 21 following the procedure that we identified.

22 So, weve gone back and really strengthened the 23 procedure to have sign-offs and checklists to make sure 24 that we have a very strong, healthy Boric Acid Procedure 25 Control Program at all of our nuclear plants. Its now a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

26 1 common process at all of our plants.

2 With that, let me go into some of the contributing 3 causes. Some decisions were made without considering the 4 need for safety analysis. What thats got to do, we tend 5 to identify things and put them into our Corrective Action 6 Program, but we did not perform the detail analysis that 7 many times, that we should have. To say, what could be 8 causing this issue? Missed opportunities again.

9 Corrective Action Program was not state-of-the-art.

10 What we find there is some differences, sometimes in 11 improvements, but also that there were times that the 12 programs at our Davis-Besse Plant was not quite the same 13 program as we have at our other plants, nor was it 14 implemented the same way. Well talk about some of those 15 corrective actions.

16 Now, let me take a few minutes in each one of these 17 areas to talk about the corrective actions, if you will.

18 As we went into this issue, we developed our Restart Action 19 Plan consisting of Building Blocks. The Building Blocks 20 themselves were designed to help us with many of the 21 corrective actions.

22 The System Health Assurance Plan provides a rigorous 23 system review, if you will. Weve got people out in the 24 two-step plan looking at our system, that went through the 25 systems, looking at long term issues, looking for system MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

27 1 health problems, walkdowns, and we brought in a lot of 2 system expertise, lessons learned from other plants like 3 D.C. Cook, as were doing this.

4 So, these System Health Reviews are really 5 strengthening the rigor of looking at our systems, system 6 health.

7 Program Compliance Plan ensures programs meet the 8 industry high standards. Were going back to a large 9 number of our programs. We have a two-phase approach.

10 There is five programs right now that were doing a very 11 in-depth latent issues review with a large integrated 12 team.

13 On the other programs, were going through what we 14 call Phase One Review, and were looking at each and every 15 program to ensure its compliance phase, it has good 16 ownership, and the implementation appears to be adequate.

17 Those two plans, if you will, were designed to help 18 us with recovery of the plant.

19 Finally, Management and Human Performance Excellence 20 Plan will ensure that we have strong and sustained safety 21 focus. What do we mean by that? Well, let me go through 22 the issues, and what Ill do is spend some time with each 23 issue talking about the corrective actions.

24 The first issue that I talked about earlier was 25 Nuclear Safety Focus. Well, weve strengthened our MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

28 1 corporate oversight. As I said, my position didnt exist.

2 Bills position didnt exist as Nuclear Oversight, 3 Executive VP. And the then the Executive VP, Gary 4 Leidichs position didnt exist. So, weve really 5 strengthened our corporate oversight of the plant.

6 Now, that was the first thing that we did. Then, we 7 turned around and we wanted to look at the Davis-Besse 8 team. One of the major issues that we had was management 9 involvement in day-to-day activities and leadership. We 10 now have in place a new Senior Team at Davis-Besse that are 11 proven high standard people, with proven industry 12 performance. We think that team will take the plant 13 forward.

14 New Management Observation Program. Its really not 15 a new program. We have a very good computerized Management 16 Observation Program at both Perry and Davis-Besse, and at 17 Beaver Valley plant. Were bringing that program over to 18 Davis-Besse, and well start using it as the program here 19 to perform the next bullet, Scheduled Management 20 Observation.

21 Its our intention to have managers in the field 22 observing scheduled work activities each and every week to 23 make sure that we have good ownership, were following our 24 procedures, and good rigor in activities we perform; both 25 in routine maintenance activities, engineering activities, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

29 1 and last but most important training activities.

2 Weve created a case study. Thats sort of a simple 3 word. Its not really a case study, its more than that.

4 Were sitting down with each and every group at our plant 5 and going over this issue in great detail. Were looking 6 at the root causes by group and explain to each group how 7 they affected this issue; how they can prevent it from 8 happening.

9 At the end of that, were going through the 10 standards of each group and then were giving a test to 11 each and every employee. At least well know what the 12 standards are and we can go on from there.

13 Then, were reinforcing our safety conscious work 14 environment every day. Now, we have several programs in 15 place, the four stages Ill talk about later; the 16 management review of our employees, what we call town 17 meetings to improve our safety focus at the Davis-Besse 18 Plant.

19 Continuing with Nuclear Safety Focus. Weve staffed 20 organizational effectiveness experts, that are now on our 21 staff in helping us with our organization as we go forward; 22 thats employees.

23 Our four Cs Meetings are Compliments, 24 Communications, Concerns, and Changes. We had the first 25 meeting a couple weeks ago. We had another meeting today.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

30 1 And well close another meeting out on Friday. I did that 2 to meet with our employees individually, let them do a 3 facilitative, bring up their concerns, their issues, their 4 compliments. So, its anonymous. And then I come back 5 after they do that, and look at the issues independently.

6 And its sort of an anonymous proactive process to 7 strengthen our safety culture.

8 Ownership for excellence review of all of our 9 managers and directors. Our plan for evaluating the 10 attributes of the managers and directors is through 11 ownership and excellence.

12 Weve done this at other plants. Were improving 13 our ownership programs. As we start up and go forward, 14 well be performing ownership for excellence reviews of 15 each and every manager and director at our plant.

16 Competency assessment is something we picked up from 17 one of the other plants, that they were building into 18 leadership in action, for each one of our supervisors. All 19 of our key supervisors, well do competency assessments on; 20 four different groups as we go prior to start up.

21 That concludes our actions on Nuclear Safety Focus.

22 The next area --

23 MR. GROBE: Lew, before you go 24 on, did I hear you correctly, you said the Ownership for 25 Excellence Review of Managers and Directors and Competency MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

31 1 Assessment of Supervisors; that will all be completed prior 2 to restart?

3 MR. MYERS: There is about 4 four groups of people. Ops, I forget the groups, but well 5 complete those prior to restart, yes.

6 MR. GROBE: Okay. Is this 7 described in the Building Block on Management and Human 8 Performance Excellence?

9 MR. MYERS: It will be in 10 Management Review Performance Excellence Plan.

11 MR. GROBE: So, that plan is 12 going under revision right now?

13 MR. MYERS: Right.

14 MR. GROBE: I would like to go 15 back, if I could one slide. You indicated that youre 16 reinforcing the safety conscious work environment.

17 You recently completed I believe a study of the 18 safety conscious work environment at the plant. Has that 19 been completed?

20 MR. MYERS: Yes.

21 MR. GROBE: Is that going to 22 be discussed in some of your succeeding slides?

23 MR. MYERS: I can discuss 24 that, if you like.

25 Bill, do you want to discuss that?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

32 1 MR. GROBE: Sure, I think that 2 would be helpful.

3 MR. PEARCE: Okay.

4 MR. MYERS: Go ahead.

5 MR. PEARCE: You want me to do 6 it now?

7 MR. GROBE: Sure.

8 MR. PEARCE: We did a survey, a 9 survey, its industry standard survey that weve done 10 several times in the past. And what were trying to do in 11 doing that is understand where are we in the issues of 12 people being able to bring issues forward in the 13 organization, feel comfortable without reprisal, that they 14 can bring issues up and that kind of thing.

15 And of course, whats been seen in the industry over 16 a number of years is when you have this kind of problem, 17 that our employees or all employees kind of get a feeling 18 that, that they cant bring an issue forward as well as 19 they normally can. So, thats why we wanted to do the 20 survey, was to see where are we now in that regard.

21 What we discovered was that we had done a survey in 22 1999, I forget which month, early in 1999, and we had done 23 another one this year in January. And, so now were doing 24 a third one. All the same survey and all we changed on it 25 was we added a couple of questions because of the issue MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

33 1 were in, but generally the same survey.

2 And what it told us is that we had some issues in 3 1999 that were kind of low range in the area that were 4 requesting. And at the first of this year before we found 5 the head problem, our ratings were actually pretty strong, 6 good. And now, the one taken in August, were back to 7 where we were in the ratings in about the 1999 time frame.

8 So, you know, it was good and now its bad again.

9 Overall, what does that mean? I think it means that, that 10 we have to put together a proactive plan to solicit those 11 issues from employees and make sure that we work a lot of 12 communication and trust issues, so that our folks believe 13 that without any question that we want them to bring issues 14 up; we value the information when we get it; and that well 15 act on it without hesitation.

16 And, of course, in that regard, they always have the 17 right if we dont act on it, to go to NRC, which is 18 guaranteed under law.

19 But thats kind of the baseline what we found on the 20 survey, Jack.

21 MR. GROBE: Bill, do you think 22 that, in fact, there was improvement in the safety culture 23 of the organization between 99 and 2001, or do you think 24 that was a fidelity problem in the survey?

25 MR. PEARCE: Well, in my heart MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

34 1 looking back at what weve looked at, I would have to 2 conclude that we probably thought even down in the 3 organization that we were in a better condition for those 4 issues than we actually were, and now weve maybe come back 5 more toward reality. I guess thats how I see it.

6 MR. MYERS: Let me answer that 7 too. You go look at the plant back in the last survey 8 weve done, just completed a very long run. The 9 performance has been outstanding. The employees felt good 10 about the status of the plant at that time.

11 When you go through an event like were going 12 through now, the question is how did we get here. You 13 know, we trusted different groups. We trusted management.

14 We trusted everybody to keep us out of the situation. This 15 is our livelihood. How did we get here? It puts a 16 terrible stress on an organization.

17 So, the results that Im seeing now, I would expect 18 to see. What weve got to do now is understand these 19 faults and move forward, be very proactive.

20 MR. GROBE: The word thats 21 often used in describing, what I think youre describing is 22 complaisant. Is that what youre sensing, that the 23 organization had become complaisant and tolerated lower 24 standards and thats why you were ranked higher in your 25 survey?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

35 1 MR. PEARCE: Yes.

2 MR. MYERS: Thats a good 3 analysis.

4 MR. GROBE: There was a 5 condition report initiated earlier this month and Ill just 6 read this. This is a description of the condition 7 identified. Says, based upon interviews conducted as part 8 of the Phase 2 Detailed Review and Corrective Action 9 Program, hesitancy to document our organization, human 10 performance and problematic issues on our condition reports 11 due to a fear of retaliation, as well as other reasons, 12 including the boomerang effect, continues to exist.

13 Could you help me understand what that means, and 14 why it continues to exist four or five months after a 15 shutdown of the plant?

16 MR. MYERS: Well, I think if 17 you look at some of our employees, its hard to tell your 18 managers that you have problems with them, and there is 19 probably some hesitancy to do that, to right the management 20 issues or complaints that are management issues.

21 Thats one of the reasons I started the Four Cs 22 Program, anonymous way for a group of people to get 23 together and complain back to me if they want to; I can 24 come and address that issue.

25 So, its difficult for people to do that. And then, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

36 1 often when you do write something like that, its a 2 boomerang effect. What happens, you wind up trying to 3 solve the problem, puts more work on you, youre already 4 working hard already.

5 I think thats the argument under the times, thats 6 probably an appropriate CR, and its driven us, its 7 driving us to take some actions to communicate better, be 8 more proactive in that area.

9 MR. GROBE: So, the corrective 10 action you laid out hereto, reestablishment of some 11 standards, new managers, your observation program having 12 managers in the field, case study, the four Cs meetings, 13 these things will turn around this condition report 14 document in early August?

15 MR. MYERS: Sure.

16 MR. PEARCE: Jack, thats part 17 of it. Right now, were formulating exactly what were 18 going to do. As you know, we just had the survey completed 19 within the last week. And were formulating exactly where 20 were going from here. What are the additional actions 21 that we need to take going forward beyond what some of the 22 things we had already put in place. And I think that 23 certainly its going to change some of the things we do 24 going forward.

25 Ive already worked on power plants, so I know were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

37 1 going to do some things differently. Were not prepared to 2 present that today, but the next meeting we could, if you 3 wish.

4 MR. GROBE: Okay. The, one of 5 the artifacts of this kind of a situation that youve got 6 yourself into, is a number of issues or deficiencies or 7 concerns or problems that may not have gotten documented.

8 How are you trying to identify those, unearth them, get 9 them out of the drawers and into the systems?

10 MR. MYERS: You know, if you 11 look, one of the things we found consistently is our, from 12 a plant material condition standpoint, our people have 13 documented their concerns, CRs at a very, fairly low rate.

14 So, from a plant standpoint, thats sort of what were 15 saying. Now, from a management standpoint, this is a 16 process of a lot of clearing.

17 Now to answer that question, how we look at those 18 things. There is Program Reviews that were doing and a 19 System Reviews. As we go through the Program Reviews and 20 the System Reviews, were specifically looking for those 21 long term latent issue type problems thats been laying 22 around, long-term type problems, trying to address those.

23 Meeting with the system engineers, and we have some outside 24 vendors in.

25 So, were looking for those type of long-term MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

38 1 material condition issues as we go through this. Theyre 2 problematic.

3 Let me add this too. In general, the overall 4 material condition of the Davis-Besse plant as we walk the 5 system down, is in general good. You know, we are finding 6 a lot of, several hundred CRs that were written.

7 Generally, when you walk our plant down, you look at the 8 material condition, its pretty good.

9 MR. GROBE: In addition to the 10 structured reviews you have, are you also asking all the 11 staff to lift the carpet and bring the issues back out from 12 underneath?

13 MR. MYERS: Let me go to my 14 next slide.

15 MR. GROBE: Okay.

16 MR. MYERS: The next area of 17 corrective action, if you will, concerns our Corrective 18 Action Program.

19 For the audience, what is Corrective Action Program?

20 That is the program that is sacred to us as managers of our 21 plant that we use to identify and fix our problems; for the 22 material condition problems, procedural problems, or 23 program problems, its our, its our lifes blood for 24 documenting, finding and fixing our problems.

25 One of the things were doing now, is that program MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

39 1 appeared to have some, at least some problems of 2 implementation as we went looking back on the record, 3 vessel head events. So, prior to even doing the root 4 cause, we decided that was one of the programs we were 5 going to do the Latent Issues Review on.

6 So, weve had a group of industry experts in here 7 and theyre finalizing a report now where they spent time 8 going back and looking at our Corrective Action Program and 9 the health of that program. So, thats coming to 10 completion.

11 Were improving, one of the things in the management 12 performance area, the criteria for categorizing our CRs 13 that were really, was not effectively implemented.

14 And, let me explain that. We let people write CRs, 15 condition reports, on just about any issue. The required 16 program is very limited from a regulatory standpoint, but 17 we allow our people to write condition reports on broken 18 trucks, if they want to.

19 And, as we take, as we generate these CRs, every 20 morning we review the CRs to ensure that theyre properly 21 categorized. Are they conditions adverse to quality of our 22 plant or are they just nonconforming conditions, or 23 nonquality conditions, or are they just management issue 24 type of conditions. So, we categorize those, the CRs that 25 are written each and every day; except on the weekends.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

40 1 What we found as we went through the Management 2 Human Performance Review, was we had not properly 3 categorized several of the CRs that we looked at.

4 For example, you know, condition reports that were 5 written on containment coolers were not, not at high level, 6 not considered condition adverse to quality. It should 7 have been classified higher. We didnt do that well.

8 So, what were doing now, weve already reviewed the 9 criteria. Every morning at the morning meeting, were 10 going over the CRs that are generated, and were 11 effectively implementing the corrective actions 12 categorization.

13 Bill is monitoring that. I monitor that.

14 Existing longstanding conditions are now being 15 reviewed as significant conditions adverse to quality.

16 What we mean by that? Well, as we go through the program 17 reviews, as we go through system reviews, were looking for 18 longstanding issues, things the system is telling us, this 19 has been around for five years, ten years, hasnt worked 20 well.

21 So, well take those issues and well try to 22 reclassify those as appropriate, not every one of them, as 23 a significant issue adverse to quality. And what that will 24 do is give a detailed management review of root cause, if 25 you will, to make sure that the strong corrective action is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

41 1 effected.

2 Weve strengthened the review board. Its called 3 the Corrective Action Review Board. And what happens there 4 is, the causes, when we try to find and fix problems, go to 5 that board, make sure that weve done a good job of 6 reviewing for root causes if need, or parent causes or 7 whatever.

8 We now have a Director. In fact, its our Plant 9 Manager, Randy Fast. Hes the chairman of that board. So, 10 weve strengthened the management ownership of the board.

11 As we move forward, we will routinely for the next 12 year or two, anyway, perform assessments categorization.

13 You know, we think we got a categorization, could step 14 down, but we cant afford to step back. Were reviewing 15 every CR at the morning meetings every day.

16 Now, repeat conditions are being evaluated for the 17 significant conditions adverse to quality. One of the 18 things, containment air coolers, became the norm; became 19 the norm. Write a condition report; write a condition 20 report. And none of them high priority.

21 So, as we look for repeat conditions, well be 22 really strengthening on the ownership of those and try to 23 classify them as inappropriate, significant conditions 24 adverse to quality.

25 Require the use of formal cause determination MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

42 1 techniques for root cause and basic cause evaluations to 2 ensure analytical rigor is applied. If you go look at all 3 the CRs, we write thousands of CRs a year, there is only a 4 handful that are really significant issues and get detailed 5 root causes. Typically, we do apparent causes or basic 6 causes and what we find is we havent done a good job of 7 training people to do those type of evaluations. So, well 8 be strengthening that area.

9 Define and implement training for cause 10 evaluations. Thats to get the root causes and evaluations 11 consistently performed at each of our sites.

12 Improve guidance on reviews for effectiveness of 13 corrective actions. If you take the corrective action, 14 its important to spend some time and you go back and make 15 sure those corrective actions really solve the problem.

16 Were effective and were strengthening that process and in 17 fact were providing guidelines for effectiveness reviews.

18 Implement an effective site-wide equipment trending 19 program. We typically do engineering reports on our 20 systems, probably on a quarterly basis. Were going to 21 strengthening our process to look for trending of 22 degradation. We do an adequate job at any rate.

23 Technical rigor, the next area, if you will.

24 MR. GROBE: Lew, before you go 25 on, did you have a question?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

43 1 MR. DEAN: Im sorry. I 2 wanted to get back to a question that related to the 3 surveys and the meeting you had with your staff. Is that 4 reinforcing some of the things that you saw on the survey, 5 safety conscious work environment survey in terms of --

6 MR. MYERS: Yes.

7 MR. DEAN: Can you describe 8 the global perception that you see on the part of the 9 staff?

10 MR. MYERS: Well, in the 11 meeting that I had, its very independent so far. Our 12 staff will tell you they know their performance has 13 declined. They see that now. They openly tell me that.

14 They openly tell me the management bottom had decayed away, 15 which is exactly what we saw on the root cause, you know, 16 where we looked at managers to see how the containment is 17 doing, is relevant.

18 They also tell me that once you get talking to them, 19 theyre not the least bit shy. And they tell me, we 20 havent done a very good job of communicating to them.

21 Also they found things out through the newspaper before 22 they find out from us. And were trying to strengthen that 23 communication in our newsletters and online television 24 system.

25 One of the things we did last week as a result of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

44 1 that was, for feedback, is prior to going to meet with NRC 2 on the root cause, the day before, right before we left, we 3 had an all hands meeting with a couple hundred employees to 4 go over the results of the management review before we did 5 it with you; and to talk about the safety culture survey we 6 had just completed.

7 So, we did that last week. So, each one of those 8 areas that they give us, we try to address.

9 MR. DEAN: Thank you.

10 MR. GROBE: You described your 11 corrective actions for nuclear safety focus and now 12 corrective action program. Thats a fairly broad set of 13 corrective action going forward. Two questions. One, the 14 Corrective Action Review Board.

15 Randy, youre fairly new to the organization. You 16 chaired that. Are there other members of the Corrective 17 Action Review Board that are either independent or new to 18 the site?

19 MR. FAST: We have some 20 engineers, but we also have some oversight, so both the 21 quality comes in to monitor those meetings, as well we have 22 independent assessment that provides feedback to us about 23 the things that they see as we review the significant 24 conditions of first quality, and the reports.

25 MR. GROBE: Like I said, this MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

45 1 is a, this is going to be a good going forward. Have you 2 queried the staff about issues or concerns that theyve had 3 in the past that they did not bring up, because of this 4 problem with corrective action program, and safety focused 5 concerns?

6 MR. MYERS: I would say that 7 were doing that now. All those details brought in place.

8 One of the things we chartered, is an action from 9 the Restart Oversight Panel, is Buzz Galbraith, our 10 Chairman, and Jere Witt, from the county, is starting some 11 individual independent meetings with our employees, and 12 giving us feedback as a management team at the Restart 13 Oversight Panel.

14 Thats another action were getting ready to take.

15 I just looked at the charter for that action today.

16 MR. GROBE: Okay. Thats 17 probably something that before our next public meeting is 18 to spend some time out at the plant talking with the 19 staff.

20 MR. MYERS: Good.

21 MR. GROBE: Finding out what 22 theyre thinking.

23 MR. MYERS: We would invite 24 that.

25 The next area is Technical Rigor. What do we mean MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

46 1 by that? Thats a level of detail that we go into when 2 were solving problems.

3 It appeared to be problems there. So, one of the 4 things we found was that we were given mixed messages on 5 some of our standards. At the FENOC level we have 6 policies, our business plans. Our business plans 7 specifically say that our priorities are the following:

8 Safety first, people second, reliability third, and finally 9 cost. Thats our priorities in that order.

10 We found there is documents at our Davis-Besse Plant 11 that dont support some of the, policies that dont support 12 our business plan in FENOCs vision. Weve come back and 13 made a list of all of those policies and procedures. One 14 of the things we do at FENOC, we went and we have completed 15 already and approved a Nuclear Operating Procedure that now 16 makes it a requirement that any time you generate one of 17 these site causes that could be, give you misleading 18 information, thats got to come to the Executive Team to be 19 reviewed and approved by us, for us to generate policy at 20 Davis-Besse.

21 We strengthened that, and we did that by creating a 22 Nuclear Operating Procedure that talks about, and our 23 approval process we talk about. Thats complete.

24 Weve established an Engineering Assessment Board 25 that reinforces our standards of engineering. And once MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

47 1 again, its built with these type of changes that we have 2 now, rebaseline your standards, if you will. That puts 3 stress on the people in the organization that reinforced 4 the products that we didnt have to. And when that 5 happens, it tends to cause issues. And, thats another 6 reason we have to be sensitive to the issues we discuss 7 while we go.

8 We have established a Periodic System Walkdown 9 Program. You know, let me talk about the engineering a 10 moment. Weve established a Periodic Engineering Program 11 Review Process. As weve gone through these reviews of our 12 programs and systems, the question comes to mind, why did 13 we have a procedure in place that our system engineers use 14 all the time for system reviews. They are supposed to be 15 doing routine system reviews and bringing their piers over 16 from the other plants to help them do reviews.

17 So, weve taken the documents and the lessons 18 learned from this issue, and the Buildings Blocks, and 19 weve turned those into, are turning those into permanent 20 processes that will be integral to all of our plants before 21 its over with. So, the System Review and Program Review 22 is part of the normal culture, if you would.

23 Weve rebaselined the standards and expectations 24 into each of our groups. Weve already done that with 25 engineering, and were going to look at rebaseline and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

48 1 making sure those standards are right with us there. That 2 should help us with technical rigor.

3 The next area we talked about is Procedure 4 Compliance. You know, thats an area that people have been 5 storing away for years. It seemed like it went away too 6 far to the right. Weve established a training program to 7 applicable Boric Acid Inspectors.

8 If you go look at, we talked a little while ago 9 about VT-2 qualifications. What we really found when we 10 looked at VT-2 qualifications, I think that most people 11 use, is that we really did not train the people 12 adequately.

13 So, we went back and created our own training, 14 training program for Boric Acid Inspections. And we 15 believe that thats going to be a program that will take 16 off here at our sites and be recognized as a leader in the 17 industry before its over with.

18 Reinforce the standards and expectations for 19 procedure compliance and the need for work-practice rigor.

20 That gets back to the management observations. As we 21 scheduled these management observations and risk work, on 22 training, we expect to see a strong enforcement of 23 procedure implementation and stress the need for good rigor 24 on the procedures.

25 The next area is implement the Management MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

49 1 Observation Program with weekly schedules. Its not 2 something weve really done at other plants. We have 3 Management Observation Programs, but we havent scheduled 4 each and every manager.

5 To show where we are at our Davis-Besse Plant, were 6 going to schedule our managers to perform weekly 7 inspections. So, as we look at our weekly work of 8 training, maintenance style, well have our managers in the 9 field, and monitor this Management Observation Program.

10 And then Bill and his group are going to provide 11 oversight of how effectively our managers are calling out 12 issues as they see them.

13 Perform independent assessments of procedure 14 compliance. You know, we typically have Assessment 15 Programs, so since this has been such a big issue, we will 16 build that in as self-assessment for the next couple years 17 anyway to make sure we have the right rigor procedure in 18 compliance, because its not the kind of thing you can lay 19 down. Strength today, then be in compliance; and if you 20 dont stay on it for a couple of years, you wont get back 21 to where you really want to be.

22 Discuss procedure compliance regularly at our 23 morning meetings. What we mean there is we look at all the 24 CRs written. Were looking for our procedure compliance in 25 the morning meetings and well receive training and well MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

50 1 attack those trainings.

2 One of the things we talk about is contributing 3 causes. Well address some of the contributing causes, 4 weve established the FENOC decision-making process at 5 Davis-Besse, including the hazard analysis.

6 Thats a really nice bunch of root cause type 7 words. What that means is we have a doc called Tech 19 8 that we use at both our Perry and Davis-Besse Plants.

9 Were turning that into a nuclear operating procedure. It 10 has a lot of philosophies in it on how to address equipment 11 and plant problems.

12 And if we had had that and used that process as we 13 went through our Corrective Action Program, we would have 14 done a better job of doing safety reviews when need to, 15 doing stronger technical reviews. It forces you through 16 that process.

17 So, were going to turn that into a nuclear 18 operating procedure and formalize that process at all three 19 of our sites.

20 Perform corrective action procedure benchmark. We 21 now, as I said, were doing that as we speak. We have a 22 group of experts that are a pretty impressive team of 23 industry, industry experts.

24 Were doing a latent issues review of our Corrective 25 Action Program, and there are some issues with that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

51 1 program. And were going to strengthen that program, but 2 more important than anything else is implementation of the 3 program.

4 MR. GROBE: Lew, before you go on, 5 the root causes that youve identified, safety focus versus 6 production focus and technical rigor; Christine summarized 7 earlier some violations that came out of our Augmented 8 Inspection Team follow-up inspection; and clearly you can 9 see threads through those violations of procedure 10 compliance, lack of safety focus. That was a fairly narrow 11 inspection, focused primarily on the head degradation.

12 Have you seen procedural compliance concerns in 13 other areas of the plant to cross operations and health 14 visits and engineering and maintenance?

15 MR. MYERS: I would say weve 16 seen a lack of rigor in several areas, yes. For example, 17 you know, we talked about one here, that is operability 18 concerns. The same program implemented the same at all 19 three sites is not the same.

20 So, we need to strengthen those operability 21 concerns. And Mike Cross is working that as we speak. The 22 operation rigor. So, yeah, we seen that pretty much across 23 the board.

24 MR. GROBE: Okay.

25 MR. MYERS: When we did the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

52 1 root cause last week, we talked about management incentive 2 focus from safety, or the lack thereof. You know, Ive 3 been a pretty high level person in this organization many 4 years, and I dont think that its any programs are ever, 5 in fact, I dont even know what incentives are, to be 6 truthful about it, but I notice it never swayed my 7 decision, but its an issue and its an issue at the high 8 level we need to address.

9 I know Bob and Gary and myself, were going to 10 address those issues and make sure that our incentive 11 program is properly in line.

12 Establish policies to support safety. We need 13 strong operational involvement. We need good managers in 14 the field and good decision making. We are strengthening 15 that.

16 You know, in summary, if you look at this issue, I 17 think our First Energy procedure, at one of our large staff 18 meetings in Akron a few weeks ago, in front of every one 19 said it best; said, you know, he has committed to returning 20 the Davis-Besse plant to service in a safe and reliable 21 manner.

22 What we really said was doing the job right the 23 first time. Thats what we need to be about; doing the job 24 right the first time. Just find and fix the problem and 25 quit trying to justify the way. Were committed to meet MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

53 1 that challenge.

2 Thats all I have. Thank you.

3 MR. GROBE: Okay. Questions 4 from the panel members?

5 Bill?

6 MR. DEAN: Lew, relative to 7 the statement here on the next to last slide where you talk 8 about establishing policies, report safety and in 9 particular operations involvement, is there a vision there 10 that you have as an organization relative to how do you see 11 operations fitting within the overall concept of how 12 Davis-Besse is going to operate that may be different than 13 how its operated in the past?

14 MR. MYERS: Do that again for 15 me, I lost you somewhere.

16 MR. DEAN: The involvement of 17 the operations has in leading the organizations as opposed 18 to perhaps how it might have been in the past.

19 MR. MYERS: You want to 20 comment on that, Randy?

21 MR. FAST: When you benchmark 22 the industry, the best of the best, theyre operation 23 driven. License holders of the plants are our operators.

24 Its the eyes and the ears of the plant. The expectations 25 are that they run true to form. They set the standard for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

54 1 the rest of the station, and the station follows 2 operations.

3 That has not been the case at Davis-Besse of late.

4 Part of our Operational Excellence Plan is to clearly 5 communicate to our operations staff their leadership role 6 and then challenge them in assuring the high standards of 7 the plant.

8 In fact, we have one of our high level condition 9 reports. Were just in the final phases of review and 10 approval, and it reinstitutionalizes operations role in 11 that management process. And to ensure proper buy in, we 12 have a meeting on this, this coming Friday, with all of our 13 shift engineers and our shift managers, so we can clarify 14 roles and responsibilities, and the critical role that they 15 play in ensuring the safeguards of the plant.

16 So, the short story is, operations will be the 17 leader of the future and they will set the standards for 18 proper operation of the plant.

19 MR. DEAN: In your efforts in 20 benchmarking in those organizations, what are some of the 21 steps you need besides clarifying roles and 22 responsibilities? Obviously, there are things that need to 23 be done in order to drain that throughout the organization.

24 Everyone else in the organization has to see organization 25 as well. So, what sort of steps are you talking to ensure MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

55 1 that message is seen specifically across the site?

2 MR. FAST: Well, Bill, one of 3 the things I would say is operations role. Although 4 theyre in the plant, they take that for granted, but 5 theyre not bringing that information to the plant staff in 6 the morning meetings, identifying their expectations. And 7 when I talk with shift managers about when was the last 8 time you were in containment, what did you see on your 9 tour, what is it that you think needs to get attention; I 10 get little blank stares.

11 And the reality is, their positions demand that they 12 be out in the plant looking and that they bring those 13 issues forward. And the forum we have in operating our 14 plant on daily meetings, creates the spot where a shift 15 manager can challenge the leadership team in the issues 16 that they see in the plant.

17 Another area that we would, we pointed out at the 18 last public meeting was operability justifications; and as 19 Lew has identified, we dont want to justify, we want to 20 evaluate and properly disposition issues.

21 Weve challenged our operations staff to raise those 22 issues and to call on plant staff to bring the information 23 to the control room, so they can be properly 24 dispositioned. And our operations staff is being asked to 25 push back, ask those tough questions to ensure that the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

56 1 issues are fully evaluated and fully resolved before we 2 identify the corrective action thats necessary. And 3 thats some of the examples of things.

4 We are seeing some improvement in those areas, but 5 there is lots of work yet to do.

6 MR. DEAN: In your pursuit of 7 this, have you established, are there some things you can 8 point to as being ones that would give you signals or signs 9 that they are having some success in that area?

10 MR. FAST: Bill, those are 11 some of the things that were institutionalizing as part of 12 corrective action in the root cause. Im not prepared to 13 talk at length about that, however the matrix of the 14 performance indicators will be clarified and tracked on a 15 crew basis.

16 MR. MYERS: One of the things 17 we said as managers, its important hearing what operations 18 people said. Now you have me, you have shift supervisors, 19 and ops managers and Randy. Thats a pretty strong message 20 by itself. And it may cause us pain for what the message 21 is, but thats where they sit in the morning meeting, and 22 theyre at the head table where they belong.

23 MR. MENDIOLA: I dont have a 24 question per se, I just want to clarify a point I thought I 25 heard. Intrigued by your survey of the staff, and I MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

57 1 understand the results arent necessarily collected and 2 havent been evaluated. I guess I would see a little bit 3 of, will you be coming to us sometime in the future maybe 4 next meeting or so, with a full understanding of those 5 results and what steps you will take from your findings 6 from the surveys?

7 MR. MYERS: Absolutely.

8 MR. GROBE: I think its 9 about time for a break, give our transcribers fingers a 10 rest. But, before we do that, I want to just make a couple 11 of comments.

12 Weve been waiting for awhile to receive the results 13 of your root cause analysis in the area of organizational 14 effectiveness. We received that last Thursday. And I 15 think that sometime this week, were supposed to get a hard 16 copy document on the docket. Well make that available on 17 our website.

18 Ive commented in the past, and Ill reiterate this 19 comment. The fact that boric acid as a corrosive is not a 20 surprise to anyone. Its been known for many, many years 21 in the industry. The fact that metals fatigue and crack 22 eventually in service is well known. Those issues resulted 23 in degradation of the head. It wasnt the cracking with 24 the boric acid, it was the lack of safety focus of your 25 staff. And I think youve captured those thoughts fairly MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

58 1 well.

2 This is the root cause of what happened at 3 Davis-Besse. And, you have now articulated that 4 comprehensively and youre beginning to redevelop your 5 Management Performance Improvement Plan to address these 6 issues. As recently as August 3rd, I highlighted this 7 condition report. It indicates that the problem still 8 exists.

9 I know that youve initiated a number of activities 10 to begin to address this, but its fairly clear that those 11 activities are not yet bearing fruit. And I look forward 12 to the Comprehensive Improvement Program laid out in your 13 Building Block in this area, and measuring, going in the 14 future through our inspections, as well as new performance 15 indicators, progress in this area.

16 I believe that this is going to be the pacing 17 issue. Its one of the most difficult issues to grapple 18 with. I think one of the keys is the assessment which 19 youre going to undertake with the first line supervisor, 20 and find out which have the right safety focus, which can 21 be moved to the right safety focus, and possibly which 22 cant. And, thats critical.

23 So, with those few comments, I just wanted to 24 briefly lay out how our inspection is going to proceed in 25 this area.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

59 1 Weve now received your root cause. Were going to 2 do a thorough review of that; both the NRC staff in Region 3 3, as well as headquarters and possibly some independent 4 contractors who are expert in organizational 5 effectiveness.

6 When we receive your Building Block, revision of 7 your Building Block, well do a thorough review of that to 8 make sure it matches the root causes and we believe 9 addresses the issues that are identified.

10 We will observe through inspection implementation as 11 well as perform independent inspection in this area. And I 12 want to emphasize this is now just beginning, and we look 13 forward to continuing dialogue in these meetings in the 14 future in this area.

15 Why dont we take a five minute break, and give our 16 transcribers fingers a rest. And reconvene at 25 til.

17 Thank you.

18 (Off the record.)

19 MR. GROBE: Lew, I peeked 20 ahead a bit and I definitely want to get through the next 21 two sections on Restart Progress and Nuclear Quality 22 Assessment. Well take a benchmark of time at that point.

23 MR. MYERS: We would also 24 like to do containment also.

25 MR. GROBE: Okay. Are you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

60 1 ready to start back?

2 MR. MYERS: Clark Price will 3 talk to you about Restart Progress and provide you some 4 overviews for our schedules and some of the performance 5 indicators that we look at.

6 MR. PRICE: Good afternoon.

7 As Lew said, my name is Clark Price. As the slide says, 8 Im the Business Services Manager at Davis-Besse, but for 9 the restart effort, Im Restart Action Plan Processor.

10 That was the center building block in the chart that Lew 11 addressed at the beginning of our presentation.

12 I have the responsibility for coordinating all the 13 activities in the Return to Service Plan, the building 14 block activities and also the overall restart effort.

15 Theyve brought me up here today to talk about our 16 excellent progress were making, of course resumption of 17 safe power, safe operation of the plant. Ill be 18 presenting today a few of the key points we developed for 19 monitoring our progress.

20 Let me begin by saying, our focus here at 21 Davis-Besse is to ensure that our people, the plant and our 22 people are meeting a high standard for restart and 23 sustained safe operations. And further, I would like to 24 say our restart plans are just not focused on the next few 25 months, but for the long term safe operation of the plant.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

61 1 Next slide.

2 Since the last public meeting in July, weve been 3 working very hard and made considerable progress. Weve 4 developed governing procedure to control the Restart Action 5 Plan process. We developed Restart Action Plans and we 6 generated schedules for those plans and are completing the 7 integration for the schedules into the Integrated Restart 8 Schedule for the plant.

9 Were making excellent progress through the hard 10 work and dedication of all the employees at the plant. A 11 number of the milestones from the Restart Action Plan, 12 major milestones from the plans are included on this 13 slide. Ill briefly discuss each of those as following 14 presenters will discuss them in more detail.

15 The first item, we have completed System Walkdowns.

16 And this is a major milestone in our System Readiness and 17 Readiness Review Programs, as part of containment -- or 18 excuse me, the System Health Readiness Review Building 19 Block.

20 Weve also are nearing completion, as Mel mentioned 21 earlier, in our containment inspection are near complete.

22 This is a major milestone also in our Containment Health 23 Building Block as we discover and complete all the 24 inspections due to the boric acid center condition 25 degradation occurred as a result of that problem.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

62 1 Weve completed cutting in the shield building, the 2 concrete cutting of the shield building that is a necessary 3 step in the replacement of the reactor vessel head. That 4 has been completed and that operation is currently 5 demobilized.

6 Our containment painting preparations are well 7 underway. Currently, we are prepping the dome of the 8 containment vessel for painting, and removing the existing 9 paint, preparing that for painting, as well as many other 10 areas of containment that are being prepped for painting.

11 We should complete this week an upgrade of our 12 Containment Polar Crane. This was a modification that we 13 performed in the Polar Crane to make it more reliable. And 14 this is a critical activity to support the many activities 15 that we have that are necessary with that crane, is 16 necessary for use between now and restart of the unit.

17 We have removed the coils from three of our 18 containment air coolers and those coils will be replaced in 19 September and October when the new coils come in.

20 As Lew stated, and just presented, we have completed 21 our Management Root Cause Reports. So, we have 22 accomplished many of our milestones in our Restart Action 23 Plans to-date.

24 At this time, I would like to turn over to Jim 25 Powers to talk over a few of the slides of the results of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

63 1 the system walkdowns.

2 MR. POWERS: Thanks, Clark.

3 Jack, at our last meeting you requested an update of 4 what we were finding as part of our reviews. I wanted to 5 give a quick rundown on what we found from the Discovery 6 Phase of our System Health Walkdowns.

7 As you can see from the slide here, there was 8 approximately 80 separate walkdowns were performed over the 9 past several weeks. And, they were consisting of 31 10 systems that we have in the population of our System Health 11 Readiness Review, as well as the five systems that we have 12 for our Latent Issues Level Review, which is a deep slice 13 review. So, a total of 36 systems.

14 And these are material condition walkdowns, as we 15 refer to them, for discovery of problems out in the plant.

16 The Configuration Verification Walkdowns for selected 17 systems will occur later as we get deeper into the Latent 18 Issues Reviews, as we review modification and such, we will 19 get out and look at specifics on systems. Although, there 20 was an element of Configuration Review as part of this 21 walkdown with the drawings of the system.

22 Over 3500 man hours were expended in this effort.

23 We really focused our teams on getting out there and going 24 through the walkdowns. So, it was a focused effort over 25 approximately two weeks. So, the members of the review MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

64 1 teams that are doing the system reviews got out there, and 2 in addition, management oversight participation, as well as 3 operations and maintenance assigned to each one of the 4 teams.

5 Operations provided us specifically SRO involvement 6 on the teams. And generally, I was very pleased with the 7 response of the individuals on the teams. It was a good 8 opportunity for the plant staff to get together 9 multi-discipline advice, and work together, and walkdown 10 the plant and see what kind of standards they have been 11 living with and identify areas which standards should 12 improve.

13 I think there were a number of areas things should 14 improve, and it was positive feedback on the overall effort 15 and were going to use this in the future, not only at 16 Davis-Besse, but other FENOC plants routine walkdowns.

17 Here we show a few pictures of walkdowns ongoing.

18 This is a walkdown of the Reactor Coolant System. You can 19 see the team, several of them are sitting on top of the 20 reactor coolant pump in the containment looking at their 21 drawings and documents as they check off the individual 22 components and attributes of the system that are going 23 down.

24 There is a very specific procedure that we use for 25 these walkdowns that tells the individuals exactly what to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

65 1 look for and theyre all trained for common basis through 2 these walkdowns.

3 MR. MYERS: Those are the 4 motors, right?

5 MR. POWERS: Thats the motor.

6 MR. MYERS: You should say 7 thats a motor.

8 MR. POWERS: That is one of 9 four reactor coolant pump motors, that theyre largely in 10 the containment that theyre checking out.

11 Here theyre checking out the containment air 12 coolers. Weve talked about those in the meetings and the 13 health of our containment air coolers in containment.

14 Again, you can see they have documentation in containment, 15 keep it in bags to keep it clean.

16 They walk through and the individuals identifying 17 equipment, identification tags, so as we go through these; 18 and I participated in these myself. So, we go through, we 19 check the equipment ID, make sure its clear which 20 component were on, how it matches the drawing, whats the 21 condition of the component and note both positive and 22 negative attributes and take digital photographs, so we 23 have a record of what was done.

24 We take it back to the offices and document it all 25 in the Corrective Action Program any discrepancies we find MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

66 1 or questions we have for disposition.

2 Heres the walkdown going on outside the 3 containment. We have management participation actively 4 involved. You can see there is a team that gets into 5 details. Many times our management has been involved in 6 construction of nuclear plants, so they bring a wealth of 7 knowledge to the nuclear teams.

8 Its a very good chance to meet the people and 9 provide expectation on the level of standards that we 10 expect in these walkdowns and consequently in the daily 11 operation of the plant.

12 Heres some examples of things we found.

13 MR. MYERS: Who was 14 participating?

15 MR. POWERS: I think that was 16 Mr. Leidich participating, so we have our Executive Vice 17 President on that one. As I mentioned, many of us go out 18 in the management team to participate.

19 Some of the debris we found in containment, we were 20 not pleased with what we found. This is typical of debris 21 we found in some of the less readily accessed areas of 22 containment and Ill comment just generally.

23 The condition of the plant as Lew mentioned is 24 pretty good, but particularly in the areas that were most 25 actively accessed; the main walkways and around areas, can MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

67 1 get behind components, inside panels that are not 2 frequently opened, indicates containment into areas did not 3 access, we found examples of debris. The basic 4 containment, we found nails and some screws, things like 5 this, and duct tape and tie wrap thats been cut.

6 So, housekeeping issues did not meet our 7 expectations, specifically in containment, we were 8 concerned about the functionality of our emergency sump 9 down there, which would need to strain any of this type 10 debris out, which would migrate over to the drain, if its 11 required for excellent communication.

12 So, this is an example of the type of housekeeping.

13 We are going to be cleaning up these areas, and steps for 14 housekeeping.

15 In the control room is a panel, part of our Safety 16 Feature Actuation System, which is one of the safety 17 control systems at the plant, and this gives a good idea 18 about the level of detail the walkdown teams have gone to 19 looking in this case control room panel. This is a 20 microswitch.

21 And the concern by the electrical engineer who is 22 responsible for engineering for the system, the 23 terminations and the crimping details up in the upper left 24 flyer that you see with the blue plastic sheathing, thats 25 the crimping details determination for the, for that one MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

68 1 terminal. And there is a little bit of exposed wire there, 2 and that does not meet an electrical engineer or 3 electricians expectations. The insulation should be 4 continuous on there, including that blue plastic sleeve.

5 And so, this is the type of issue thats written up 6 in Corrective Action Program for this position; is that 7 acceptable. Are the bending of the wires, is that 8 acceptable. The angle that the plugs come in and number of 9 plugs that are terminated on each terminal there; does that 10 meet the design requirements and expectations. So thats 11 the level of detail well get into.

12 Heres another example of a problem we have found 13 that needs a more general review done, and thats going to 14 be done as part of extended condition of Corrective Action 15 Program. This is a fastening device. We have a nut on a 16 bolt there. You can see that the bolt does not extend all 17 the way through the nut. And in the industry, its what we 18 refer to as thread engagement. And we want to see at least 19 one thread sticking out of the nut area, so you know all 20 the threads are fully engaged and you have full structural 21 capability in that fastener.

22 This is one we found, does not meet that 23 requirement. And we will be looking more generally as to 24 the condition of our fasteners and thread engagement as a 25 result of this walkdown.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

69 1 So, some of the generic issues; numerous small valve 2 leaks. Weve seen that, particularly from the Containment 3 Health, some of our Boric Acid Walkdowns. We notice a 4 number of valves we need to repack.

5 We need to improve cleanliness and proper 6 housekeeping in less accessed areas. I mentioned the 7 thread engagement. Not only is it for fasteners, 8 structural fasteners, but packing followers, valves, studs, 9 on components. Its the same issue, that we need to turn 10 our attention to.

11 Also loose conduit and tubing. Walking down the 12 systems, we checked out all the instrumentation, as well as 13 the electrical conduit just to make sure it hadnt loosened 14 through the vibration during operation. Found some cases 15 where it needs to be tightened. And our maintenance people 16 will be doing that.

17 We found crushed tubing and bent sensing lines.

18 This is another issue with standards. These small tubes 19 tend to get damaged during day-to-day operation of the 20 plant and refueling outages. And its really standards 21 issues, that we shouldnt tolerate that, and need to go 22 back and correct the situation rather than living with them 23 like that.

24 This is more significant findings we will be 25 following up on. I talked about the debris in containment.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

70 1 There is also a lot of dust in the control room panel.

2 Its a 25-year old plant. And in the control room panel, 3 dust has accumulated over the years to the point where it 4 was observed; really doesnt meet the expectations of the 5 plant staff. We need to do a cleaning there.

6 There is an issue with thread engagement on 7 pressurizer manway thats part of the Reactor Coolant 8 System Walkdown. We found one of the studs there did not 9 have full thread engagement.

10 There was another potential for motor operated valve 11 lubrication degradation, which can occur over time due to 12 heat in the vicinity and frequency of preventative 13 maintenance lubrication. The effectiveness of 14 lubrication.

15 We talked about the Safety Features Actuation 16 System, and workmanship of the electrical terminations and 17 how they are holding up in the control room cabinets.

18 Were going to be evaluating that, support long term 19 functionality of the system or not. Thats one of the 20 institutions that needs to be done.

21 Then we found some potential noncompliance, or EQ 22 requirements for motor operated valves. These were 23 electrical terminations, T-drains, in the Aux. Feedwater 24 System, which is high engine line break, design 25 considerations for the Aux. Feedwater Rooms. And there is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

71 1 a contribution room to room, and we do have a high energy 2 break, high break, steam environment. And we need to make 3 sure that the adjacent rooms are appropriately treated and 4 keep, to keep that moisture out. Its an area we need 5 improvement. So, thats an extended condition for 6 improvement as well.

7 MR. GROBE: Jim, how did you 8 identify potential lubrication degradation in the leads?

9 MR. POWERS: I think it was in 10 that case from the walkdown. Taking a look at the leads 11 themselves, looking at the grease. I didnt participate on 12 that walkdown on that particular phase, Jack, but I think 13 theyre looking for grease, which is grease hardening, 14 which can be inhibitive on the threads.

15 MR. GROBE: Did you go back to 16 look at your periodic valve testing to see if there was 17 degradation in the test results.

18 MR. POWERS: We havent done 19 that yet. What were doing is collecting all these issues 20 in the Corrective Action Program. As youll see in the 21 coming slides, there is a large number of corrective 22 documents passing over two hundred, and theyre still 23 finishing up the documentation. So, that will be ongoing, 24 Jack. Well be able to get a report out on detailed 25 assessment.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

72 1 MR. GROBE: Okay, thank you.

2 MS. LIPA: I have one 3 question on these. I know you have another slide with more 4 examples, but are you doing as-found reviews? I know you 5 plan to fix a lot of these things before you start, but are 6 you doing as-found reviews for reportability?

7 MR. POWERS: Yes, as-found 8 conditions will be documented in Corrective Action 9 documents. As necessary, operability determinations will 10 be done and reportability will be followed through with the 11 normal process for as-found conditions.

12 MS. LIPA: Okay, thank you.

13 MR. POWERS: We did find an 14 issue with Emergency Diesel Generator, Heating and 15 Ventilation Air Conditioning System Exhaust Hydramotor 16 Damper. Basically, thats the motor enforcement damper on 17 the air cooling system. There was a damper arm loose and 18 it was bound up. And did not look like it was going to 19 work properly for a long term. So, that was a very good 20 find by the walkdown team, with attention to detail needed 21 to be corrected.

22 We also found the exhaust silencers, which are 23 outside the building, muffler essentially large diesel 24 engines, tornado missle shields and where theyre attached 25 to the concrete parapet started to crack and fall. Either MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

73 1 through water freeze and thaw cycles or thermal growth of 2 that shield. So, were assessing that.

3 And as I mentioned, its over 200 CRs initiated 4 to-date. These are snapshots, but we are finding some good 5 issues out there, and the attention to detail and standards 6 as these teams go out is really paying off. And, were 7 continuing to write CRs to finish documenting up everything 8 that we found.

9 With that, Ill turn it back over to Clark for 10 further about measuring profits.

11 MR. PRICE: Thank you.

12 In the last public meeting, we presented some of the 13 performance indicators that we were developing to monitor 14 progress of our restart efforts and our improvement 15 efforts. Two weeks ago, we published our first set of 16 performance indicators and I would like to go through a few 17 of those now.

18 Weve established indicators to track progress on 19 the Building Block Plans, progress on the NRC Inspection 20 Manual Chapter 350 Restart Checklist and also progress 21 towards meeting new standards for restart and sustained 22 operation excellence.

23 The following slides are some examples of those.

24 This first slide represents the restart actions that weve 25 identified today through a process that we have in the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

74 1 Restart Action Plan. These are all the restart actions 2 identified for restart procedures, slightly over 800 right 3 now.

4 These actions at this point are primarily in the 5 form of condition reports; and through evaluation, these 6 condition reports would generate approximately four to five 7 on average corrective actions per condition reports. So 8 you can see our volume is going to go up significantly.

9 Were seeing a steep incline right now, and that is 10 expected because of our program reviews and system reviews, 11 system walkdowns that Jim just referred to are generating a 12 lot of condition reports through the process we have. A 13 lot of those condition reports are being evaluated to 14 criteria that we have in the Restart Action Plan, being 15 identified as required for restart.

16 I would say probably in the last two weeks, we are 17 seeing about 50 percent of the condition reports that were 18 initiating or getting classified as required for restart.

19 MR. GROBE: Clark, let me 20 make sure I understand this. The width of the line going 21 up, thats the number of corrective actions completed?

22 MR. PRICE: Actually, this is 23 an indicator of open restart actions, so everything there 24 is currently open. What we have right now are the 25 condition reports were making up the major portion of our MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

75 1 open actions. Over time, we would expect what will happen 2 is the dark line, which is the corrective actions, will 3 become the larger volume and the condition reports will 4 become smaller.

5 And at restart, the condition reports will be 6 essentially all turned into corrective actions and 7 completed.

8 MS. LIPA: I have a couple 9 questions on this. So, the corrective action is an outcome 10 following condition report?

11 MR. PRICE: Yes, corrective 12 actions through the evaluation and condition report, are 13 the corrective actions that come out of that, are the 14 Restart Station Review Board that we have evaluates both 15 the condition reports up front, and then the corrective 16 actions as theyre developed, to determine whether they 17 meet restart criteria. And the ones out here met restart 18 criteria.

19 MS. LIPA: Okay. I was 20 looking at your plan earlier and there is a flow chart, and 21 at one point you decide whether it becomes a restart list 22 item or restart action item. These must be restart action 23 items.

24 MR. PRICE: These are all 25 restart action items.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

76 1 MS. LIPA: Okay, thank you.

2 MR. PRICE: Any additional 3 questions on this slide?

4 Okay, if we move to the next report. This is a 5 progress report here. Performance measures more in the 6 form of progress report. This is one that we use to 7 monitor the progress of the reactor vessel head project.

8 And primarily what it is, you can see the bars 9 identify, the yellow bar is our schedule, target schedule, 10 and the blue bars are the current schedule. And you can 11 see that project, were pretty much right on schedule.

12 No questions on that, Ill move on.

13 The next slide is our System Readiness Reviews.

14 This is the progress report that we have for the 31 systems 15 reviews that are going through the System Readiness Review 16 Process under the System Health Building Block.

17 The small inset box notes Progress Review Process; 18 and until the box on the right starts filling up, we dont 19 get any actual report completions here.

20 The schedule, as you can see right now, looks like 21 were not making any progress; however, what that schedule 22 represents right there is the walkdown period that weve 23 just gone through. It has been completed and now the 24 reports will start coming out of that process over the next 25 few weeks; well be completing all those reviews.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

77 1 MR. GROBE: Clark, just so I 2 understand. So, none of the system reviews have been 3 completed such that the report has developed and presented 4 to your Engineering Review Panel?

5 MR. PRICE: That is correct.

6 That have not been completed.

7 MR. GROBE: When will the 8 panel receive the first completed report?

9 MR. PRICE: As soon as 10 possible looks like about next week, should start seeing 11 reports being completed based on the schedule.

12 MR. GROBE: I see, okay. So, 13 it goes from 31 to 30.

14 MR. PRICE: Right. That would 15 identify the reports based on the schedule should be 16 available for review.

17 MR. GROBE: Just out of 18 curiosity, do you know which system that is?

19 MR. PRICE: No, I do not.

20 MR. POWERS: I think it might 21 be 125, Jack, that was pretty well on the head, moving 22 along. I think that was it. Ill get back to you on 23 detail with that.

24 MR. GROBE: Okay. Were going 25 to want to see the results of these early on, so we can get MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

78 1 a sense and give feedback on our view of the adequacy of 2 the review, as well as the adequacy of the oversight by the 3 panel.

4 MR. PRICE: We did provide, 5 Jack, we did provide a schedule that has all the projects 6 laid out in detail and represent what shows up on the 7 performance indicators. So, well make sure you understand 8 that schedule you receive, that will identify the systems.

9 Any additional questions on this? Okay.

10 Okay, the last one that we have to measure progress, 11 that we got as a sample today is on our phase and program 12 reviews. And as you can see in this particular slide, 13 were a little bit behind schedule on some of those 14 reviews.

15 Weve gone through a learning process on a number of 16 these Phase 2 Program Reviews and, however what we feel, 17 even though were a little behind schedule, well have much 18 better progress as a result of incorporating what weve 19 learned to date through that process.

20 We did have early on inspection visit by Ken 21 OBrien. He provided a lot of insight on review of a 22 couple of programs. And weve taken those comments and 23 incorporated them into our plans.

24 If there is no additional questions on those, the 25 last two charts I have; this one is on Root Cause Quality.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

79 1 These are more performance indicators, are looking at 2 performance improvements. And, as we rebaseline our 3 standards and improve on our programs, we have some 4 performance measures here that are trying to measure our 5 progress where were at and where we want to be.

6 This particular performance indicator looks at Root 7 Cause Quality, our significant condition reports. We have 8 a Corrective Action Review Board, as we discussed earlier, 9 Randy is the Chairman of the that. And that committee, 10 that board has established new standards for approval of 11 Root Causes to assure that the quality is there, to assure 12 that the corrective actions will prevent repeat efforts.

13 And as you can see right now, the raising of the 14 bar, the standard, we have a long way to go yet to get the 15 root causes through the Corrective Action Review Board the 16 first time. This is measuring basically what is approved 17 the first time through and what requires rework, before 18 its going to come back and get rereviewed and approved.

19 So, right now were averaging around 40 percent and 20 our goal is to be at 90 percent approval rate. So, we have 21 a long way to go here.

22 Randy, any additional comments?

23 MR. FAST: I was going to 24 say, as part of the change in the standards, we review the 25 specific conditions adverse to quality, and if we dont see MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

80 1 them; one of the typical problems we see is, if we have a 2 good story, tells what happened, doesnt say why it 3 happened. And we want to see why things happen.

4 We also look to see was there a direct correlation 5 between the root causes and the corrective actions. There 6 should be a one-to-one correlation for every root cause for 7 corrective action.

8 As well, the teams that have done the root causes 9 have identified or provided supporting documentation. What 10 type of root cause was performed; we have tap root as an 11 example of more or some other process. That wasnt 12 identified nor was that documentation provided, so were 13 asking that documentation be provided.

14 So, weve got lots of room for improvement, but 15 were actually enforcing high standards to ensure that 16 significant conditions adverse to quality meet those 17 expectations. So, its been a learning experience for all 18 of us. I believe it will help our program moving forward.

19 MR. PRICE: The last 20 performance indicator we have today is on the Engineering 21 Quality. We have an Engineering Assessment Board thats 22 chartered to review the products that come out of the 23 engineering organization in the areas of design, safety 24 evaluations and conditional report evaluations, for 25 example.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

81 1 The Engineering Assessment Board has a process by 2 which they grade the products that come out of engineering 3 on a zero to four scale. And we have a goal to be at a 4 scale of 1. Zero being the best score, 4 being the worst 5 score.

6 And as you can see here, through the first four 7 weeks of really tracking this, were not meeting the goal; 8 however, we have seen it oscillate a little bit. It 9 depends on the population of the products coming through 10 the board at any one time.

11 The Engineering Assessment Board is challenged with 12 again raising the standards and changing, rebaselining the 13 standards for the engineering organization.

14 Jim, do you have any comment?

15 MR. POWERS: I think theyve 16 done a good job and found a number of issues through and 17 brought change of quality of products depending on the 18 individual preparing it. And what were finding, for a 19 large part, is how the staff integrates together when it 20 produced for example a design, how they integrated to get 21 all the various aspects of that design cap purchased as 22 part of the review and what stage does that happen.

23 And, the design modification process that has been 24 in place at the plant rests on the interdiscipline review 25 at the end of the preparation of the design product; and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

82 1 consequently, they prepare at the end and have missed an 2 element that really should be in it.

3 And were changing that process. Actually, its in 4 the process of being changed this month. Were going to 5 have a common process modification process with FENOC.

6 Its in place with the other two plants, at Perry and 7 Beaver Valley. And were going to be adopting it at 8 Davis-Besse.

9 That calls for an interim interdiscipline review to 10 get those comments by the various specialists and experts 11 that reside at the plant or are available in the industry 12 to us, to get their input to a product before the end.

13 So, some of the comments that are asked by the 14 Engineering Assessment Board will find weaknesses in the 15 technical areas on specifics. And thats not a surprise to 16 us. I think its good. It shows its good probing going 17 on and good learning going on by the staff at the station.

18 MR. GROBE: Jim, could you 19 describe in a little more detail what an item is, like 20 calculation item?

21 MR. POWERS: Pardon me, Jack?

22 MR. GROBE: If the, it says 23 Engineering Items Reviewed. Im trying to understand what 24 an item is.

25 MR. POWERS: An item could be MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

83 1 an operability determination or it could be a modification 2 package, it could be corrective action investigation 3 report. So, an item is an engineering product. It can be 4 a calculation also.

5 And weve got four subcommittees that are reviewing 6 the Building Blocks. We have one for Programs, one for 7 Systems Health, one for the Containment Health and then one 8 for Modifications Operability Determination Calculations, 9 and the balance of engineering products. So, we have 10 special subcommittees focused on those areas.

11 MR. GROBE: Do each of those 12 subcommittees include site staff as well as independent 13 experts from other parts of the industry?

14 MR. POWERS: What weve, thus 15 far weve got industry expertise. We have an individual 16 from site staff thats on the board. And we also when we 17 do review such programs, we bring in all the site staff 18 owner, but also his peer owners from the other two 19 stations. We can share experiences and drive a higher 20 standard within FENOC and use it as a beneficial tool to 21 us.

22 We plan to integrate more of the line staff in that 23 process as we go on with time, but were not fully engaged 24 with all line staff as far as we want to go yet.

25 MR. GROBE: I found it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

84 1 interesting that you chose that your engineering staff are 2 aspiring to be zeros.

3 MR. PRICE: Are there any 4 additional questions?

5 Christine, I know you have additional questions that 6 you mentioned earlier.

7 MS. LIPA: I spent a lot of 8 time reviewing the plant and this helps, combined with your 9 discussions.

10 MR. PRICE: If there is no 11 other questions, I would like to turn this over to Bill 12 Pearce, who will talk Nuclear Quality.

13 MR. PEARCE: Thank you, 14 Clark.

15 Good afternoon, Im Bill Pearce. Im the Vice 16 President of Oversight for FENOC.

17 Since this is the first time Ive attended this 18 public meeting this afternoon, I thought Id give you a 19 little background about myself. Ive worked in this 20 industry for many years, primarily in the area of Plant 21 Operations. And Ive been a Senior Line Management 22 position for a long time, many years, but this is the first 23 time Ive ever been in Quality Assurance Organization.

24 And I guess to tell you what my expectation is, I 25 believe I can bring something to improve the Quality MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

85 1 Assurance Organization. I think I can help us get to more 2 of an operational focus. So, enough introduction about 3 myself.

4 First thing I want to go over is the root, weve 5 done a Root Cause Evaluation of Quality Assurance and its 6 performance; and we did this, because we acknowledge our 7 failure to identify the reactor head issue, just like the 8 line organization. So, we like the line organization did a 9 Root Cause Evaluation.

10 The evaluation was performed by a team, and the team 11 was made up, we brought in an outside team leader, because 12 it was well experienced in quality assurance. The team 13 also consisted of Perry and Beaver Valley folks from our 14 other two sites.

15 And we did an independent root cause of missed 16 opportunities; where could we have failed issues or brought 17 issues forward and gotten them resolved that would have 18 precluded this head issue that we have. Finally, as we did 19 this, we came up with some things that we wanted to get 20 corrected. We started looking at that.

21 Next, lets look at the preliminary results of 22 this. This root cause is not all fully completed yet, but 23 were far enough along to be able to look at some of the 24 preliminary conclusions.

25 Here is the Root Cause. FENOC Nuclear Safety MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

86 1 Values; behaviors and expectations were inadequate to 2 enable oversight to effect needed positive change in 3 station operations.

4 Now, I know thats a complex statement. Let me 5 explain it in a different way to try to, for you to gain 6 some understanding. What its really saying is there is no 7 differentiation between standards of the QA Organization 8 and standards of the rest of the site organization. This 9 was caused by a lack of independence.

10 The QA Organization reported into the management of 11 the plant, and then forward to where the standards of the 12 plant went, QA went with it. And this is what its trying 13 to explain, there should have been an oversight group.

14 So, thus QA was not holding itself to a higher set 15 of standards; and really, this is one of the reasons I am 16 here now, is this gives me independence. I report directly 17 to the President of FENOC, and I dont report to the line 18 organization of the plant.

19 So, the Quality Assessment Group can look at the 20 plant and not be affected by the things that affect the 21 rest of the plant and have an opportunity to raise issues 22 or elevate issues outside the plant if it becomes necessary 23 to get those resolved. Thats kind of what the Root Cause 24 was about.

25 There are also in the preliminary conclusions some MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

87 1 contributing causes. Ineffective training of the Quality 2 Assurance Group for a previous event we had that had, it 3 had boric acid involved in it. It was involved with the 4 Reactor Coolant System. It involved some unexpected 5 degradation.

6 And we did a root cause, training our folk on the 7 causes of that degradation and how it should be treated, 8 but obviously this was ineffective, because we saw some of 9 those same issues on the head. We were ineffective at 10 recognizing those and the importance of those issues in 11 getting the issue brought up and resolved.

12 The second one kind of, sounds kind of odd. The 13 process for providing oversight of the oversight function.

14 For every group, including us, we provide oversight to the 15 line organization, but there are organizations that provide 16 oversight of us, such as the companys Nuclear Review 17 Board; Joint Utility Management Assessment, which is all 18 the nuclear utilities participate and we go assess each 19 other.

20 Its a Quality Assurance Organization and gives a 21 report on how we stand; a self-assessment that we do of 22 ourselves; and then of course management oversight of 23 ourselves. What this is, what this is telling us is those 24 two failed too recognize that our performance was 25 inadequate to recognize this type of issue and get it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

88 1 resolved.

2 The third one is an interesting one. For a period 3 of time the management of the audit/evaluation process was 4 not independent from the management of the corrective 5 action process.

6 What it really means is the person that was in 7 charge of the oversight function actually had other 8 responsibilities in the organization that would not let the 9 Quality Assessment Organization be independent of the line 10 organization, which kind of gets back to the first part 11 again of it. The fact that the standards in quality 12 assessment were the same as the rest of the site, so 13 therefore where we stand on the site, so went the quality 14 assessment.

15 With that said, thats enough about the conclusion 16 or the causes. I would like to talk a minute about what 17 are some actions that were taking going forward.

18 First of all, we want to elevate standards. I 19 believe this is extremely important. We hold the Quality 20 Assurance Organization to a higher standard. And then we 21 can hold the Line Organization accountable to a higher 22 standard, but first we have to get our own standards raised 23 to where they need to be.

24 Increased intrusiveness. Weve got to put a lot 25 more attention in making sure that the Quality Assessment MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

89 1 Group is out in the plant being intrusive, looking at 2 things that are happening in the plant, and being involved 3 in seeing whats going on.

4 In fact, I just got this today. I had name tags 5 made for all the Quality Assurance folks. I had a little 6 thing put on it, says, "I know, because I looked." I think 7 that that says a lot. And its about standards, you know, 8 its the standard of we dont accept just what we read in 9 reports. We go out and look and we know whats going on in 10 the plant.

11 We need to raise tough issues, make sure we bring 12 issues forward that are not comfortable to deal with, and 13 we get them on the table, so that we can make sure we get 14 the things resolved that need to be resolved.

15 We need a method to escalate unresolved issues to 16 higher management and we have that now. Were formalized, 17 but were putting that in place, so that finally if we 18 cant resolve things between the line management at the 19 plant, myself, we can escalate it to the President of FENOC 20 and even to the Nuclear Board, if necessary, for 21 resolution.

22 Now, that was about the Root Cause. The next thing 23 I want to do is examine where quality assurance is involved 24 in the recovery process. I want to talk about the next few 25 slides about that.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

90 1 First of all, we are assessing key activities that 2 are going on. When you heard them talk of the line guys 3 talking about the boards that are meeting, we sit in 4 independent oversight of that and overview whats going on 5 in the boards and the right kind of things being talked 6 about. There are things that we know of that are not being 7 brought forward.

8 We do in-depth technical reviews, independent of the 9 engineering organization for engineering products. So, 10 were looking at the engineering products coming out and 11 making sure that we believe that the products are of 12 quality that are being brought forward.

13 Field verification of actual conditions. This is 14 our participation in the field activities, the walkdowns.

15 We do parallel walkdowns, and also independent walkdowns.

16 Then independent parallel reviews.

17 The next thing Im sure youre asking, what are we 18 finding. On the next page, Im going to show you a big 19 overview of what were finding.

20 These are numbers of condition reports. When we in 21 Quality Assurance find something, we write a condition 22 report about it to ensure it gets in our Corrective Action 23 Program and gets resolved. And you can see these are the 24 number of condition reports written by the Quality 25 Assurance Organization per month. And you can see, this is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

91 1 a twelve-month period, or actually 13 months. You can see 2 how the numbers have increased as weve tried to become 3 more intrusive.

4 But lets, but now let me tell you about some things 5 that weve really found. In the area of increased 6 intrusiveness, the most recent assessment, we identified 77 7 issues. Now, all of these are not huge issues, but they 8 are nevertheless issues and are recorded in the Corrective 9 Action Program.

10 Were doing real time assessments. Were out 11 looking at operational performance or real time performance 12 in the plant and not just reviewing paper. I think this is 13 important, because we are reviewing to not just minimum 14 regulatory requirements, but were trying to hold the site 15 to a set of standards that are above that.

16 I know that sounds kind of negative about the 17 regulatory requirements, but just meeting the regulatory 18 requirements doesnt get us to where we want to be as a 19 station. Weve got to focus on real nuclear safety and 20 things that are not required in the regulation, like 21 peoples behaviors, how they think, are they thinking about 22 the right things. The requirements are there. Theyve got 23 to be met, no question about that. But beyond that, there 24 are other things that we need to focus on as an 25 organization.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

92 1 Next slide is, heres some examples of real time 2 issues weve identified. First one is operations group 3 failure to request engineering rigor for operability 4 determinations. This is an example of prestandards that 5 were pushing in the organization. I think you heard some 6 of the rest of them talk about it. Weve been effective at 7 moving the standard within the organization, and getting a 8 change in the behaviors for improvement in that area.

9 Another one we found was failure of the Line 10 Organization to recognize containment painting as a design 11 change. That was something else that weve done in Quality 12 Assurance Organization.

13 Under the area of Ensuring Product Quality, vendor 14 errors with implementation of the feedwater flow 15 modification. Heres an example of finding something in 16 the engineering area, looking at their product.

17 The second one there is failure to comply with 18 quality program requirements during overhaul of the decay 19 heat pump, which is a safety related pump and the issue was 20 how we dealt and the oversight we provided in a vendor that 21 was not a quality vendor, and the issues around that.

22 The next one is under the area of Elevating 23 Standards. Posting and protection of protected train 24 equipment. For those of you dont know what that is, for 25 our safety equipment, almost always at nuclear power plant MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

93 1 there are two trains. So, if you take one out to work on 2 it, beyond it being an amount of time sometimes, it limits 3 how long both of them, or one of them can be out.

4 We also try to protect it, so that somebody doesnt 5 go in the area and work on the remaining train, so we end 6 up with no safety trains available. While that doesnt, 7 does not meet the regulatory minimum requirements on no 8 trains, we want to do something beyond that to make sure we 9 protect the remaining train.

10 So, we do that by installing barriers and signs and 11 making sure something inadvertently doesnt happen.

12 Raising the standard of how we protect that remaining train 13 is what this is about and what was being brought forward by 14 the Quality Assurance Organization.

15 Documentation standards for unit log keeping. This 16 is documentation of like, what constitutes operability when 17 an operability determination is being made. What are the 18 specific issues that the equipment is called operable based 19 upon, making sure that those type of details are in the log 20 and well documented, so oncoming shifts will know exactly 21 what those kind of issues are, so if they are affected by 22 what goes on in the future, the folks that are coming on 23 will know what the issue is.

24 Potential corrosion of the containment vessel.

25 Quality Assurance Organization brought up the microbe MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

94 1 induced corrosion issue for the containment vessel, and 2 documented that earlier in the containment inspection.

3 Untimely corrective actions for previously 4 identified Corrective Action Program weaknesses. Youve 5 heard Lew talk about the Corrective Action Program and what 6 they found during the program review. This was actually 7 documented well before that. Quality Assurance 8 Organization had written condition reports demonstrating 9 some of the same weaknesses found in the condition, in the 10 Program Action Reviews.

11 Heres some examples I think of being tough, or 12 raising the standards. In our second quarter assessment, 13 which is the overall assessment of all the departments at 14 the site, we found that five of the eleven areas had 15 marginal performance. I think if you look back in time, 16 you would see that thats almost a step increase in how 17 weve been looking at things prior to that. And we found 18 two unacceptable performance issues in our last quarterly 19 assessment. So, I think thats an example of us raising 20 standards in the organization.

21 MR. GROBE: Bill, do you 22 recall what those were?

23 MR. PEARCE: Which ones?

24 MR. GROBE: The two 25 unacceptable performances?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

95 1 MR. PEARCE: Yes, sir.

2 Within the engineering functional area, the plant 3 modification process was identified as unacceptable. It 4 did not meet all the required items for Appendix B an ANSI 5 Standard November 45.2.11 requirements. It says, Nuclear 6 Quality Assessment would have exercised a stop work 7 authority if the line organization had not implemented 8 acceptable interim compensatory measures.

9 Then it says, additionally, the area of radiation 10 protection, the implementation of Corrective Action Program 11 was rated as unacceptable. Those were the areas.

12 Well, my conclusion, I guess, is that the Quality 13 Assurance Organization is already improving our standards.

14 We are not yet where we need or want to be, but we have 15 identified our weaknesses and are formulating an 16 improvement plan to get us where we want to be.

17 I thank you for your attention. Are there any 18 questions that you have?

19 MR. DEAN: I have a couple of 20 questions. One is, earlier we talked about the efforts to 21 try and move Davis-Besse towards an operations focus 22 organization. We talked about benchmarking and some of the 23 results of that.

24 Have you done a similar effort relative to the QA 25 organization and how it was performing previously and what MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

96 1 your approach is now; how does that benchmark against other 2 high performing organizations?

3 MR. PEARCE: As we did the Root 4 Cause, we brought one outside person in. And then at the 5 end, we actually brought a person from, well, from Florida 6 Power and Light and one from Intergy in and went through 7 all the facts to narrow down the conclusion.

8 We intend to continue to do that. In fact, last 9 week, for instance, the Quality Assurance Manager was on 10 vacation last week, and to fill in for him while he was 11 gone, I brought the Quality Assurance Manager from Perry 12 over and he filled in for him. Just to give a different 13 set of eyes in the actual management position. Its a lot 14 easier to see things if you havent been in the middle of 15 them for some period of time. That gives us some outside 16 view.

17 We intend going forward not only views of Perry and 18 Beaver Valley people a lot, and in fact I believe that 19 either last week or this week, we had eight folks from 20 Perry and Beaver Valley at Davis-Besse helping us go look 21 at these programs. And there is a lot of advantage to 22 that. Not only does it give them some help and go out and 23 look at what were doing, they take those standards back 24 with them.

25 You know, I really believe that a lot of times the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

97 1 cutting edge for standards in our industry is produced at 2 the plants coming out of trouble. I think we can get a lot 3 of learning for the other two sites by making sure that the 4 quality assurance folks from the other two plants get over 5 here and be involved, so that they get the learning that 6 were getting out of this and take it back to the other two 7 sites.

8 And, we intend to bring in some folks at times from 9 other companies within in the industry.

10 MR. DEAN: How about the, 11 pertaining to the line, you talked about raising the QA 12 standards above what regulatory is required, organizations 13 like INPO, which is intended to promote excellence 14 throughout industry. Have you gone to them and sought any 15 assistance from them?

16 MR. PEARCE: In fact, on our 17 Restart Oversight Panel yesterday, we had two members of 18 INPO. One is a member and the other was a visitor, who I 19 guess now hes in charge of all -- what is he in charge of?

20 Its a help --

21 MR. MYERS: Assistance.

22 MR. PEARCE: But, hes in 23 charge of all the systems for INPO, and he was at our 24 Restart Oversight. And thats in fact why he is here, to 25 make sure if we need some assistance that were getting the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

98 1 help that we need from the rest of the industry and, you 2 know, I think thats an example of how were getting help 3 by INPO, not only from the plant, but from the Quality 4 Assurance Organization.

5 MR. DEAN: Second question I 6 wanted to raise relative to reorganizing and restandarding 7 the QA Organization. For a period of time, went along, you 8 were part of the staff, essentially; you were in the 9 staff. And so, a certain line stayed true to form between 10 your QA staff and their relationships. Whats being done 11 in bringing fresh blood or different talent or different 12 mind set into the organization?

13 MR. PEARCE: I think were 14 doing a lot, like I said, were trying to bring in people 15 from Perry and Beaver Valley and a lot of them, instead of 16 totally supplementing our needs here with contractors from 17 outside, what we decided to do is use those, those folks 18 from Beaver Valley and Perry to supplement, but that is 19 outside, an outside look. I mean, we have not ever spent a 20 lot of time together like that in looking at those 21 standards.

22 In addition, we have got, we have gotten some 23 engineering people that have come out to some of the more 24 recent trouble plants and seen what standards are in those 25 areas and theyre in working supplementing our organization MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

99 1 now, looking at some of the engineering products, for 2 instance; and using that to help build the standards up.

3 And personally, myself, Im a line person, my whole 4 life, and now in quality assurance, and Ive got a 5 background in operations; and I can help us raise our focus 6 on operational performance and not just meeting program 7 requirements.

8 MR. DEAN: Has there been an 9 effort to go to other parts of the organization, say Im 10 looking for somebody thats a top notch engineering or top 11 notch operations person to come over to QA and give me some 12 discussions?

13 MR. PEARCE: Surprisingly 14 enough, I didnt do this. This happened before I got 15 there. Thats been done recently at this site. I think we 16 have, I think we have a real good set of folks. And, I 17 invite you to come down. I would be glad to let you meet 18 them, but I think youll think so too.

19 And they are, weve got a good mixture of people who 20 have had responsible positions within the organization, a 21 lot of places in the organization and then some 22 professional QA folks. We have got a pretty good mixture, 23 I think, at Davis-Besse.

24 MR. MYERS: We have. And, I 25 was asking, do we have plans to do some permanent cross MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

100 1 pollenization from people of other sites to the Davis-Besse 2 Plant?

3 MR. PEARCE: Yes, we do.

4 MR. MYERS: And thats sort of 5 what you asked awhile ago. We intend to do some of that; 6 we have some ideas in mind.

7 MR. DEAN: Well ask more 8 about that later.

9 MR. MYERS: Okay.

10 MR. MENDIOLA: I know you dont 11 like to be here.

12 MR. MYERS: Pretty much be a 13 good time to look at a new job (laughter) public meetings.

14 MR. MENDIOLA: Okay. Knowing 15 that Quality Assurance Programs are often incorporated, 16 corporately across all the plants associated with the 17 company. For example, yourself and First Energy; is there, 18 well, I guess, to summarize your presentation basically, I 19 would understand that the Quality Assurance Program is 20 implemented more appropriately across First Energy, but had 21 gaps at Davis-Besse.

22 Is there a corporate oversight function here that 23 needs to be discussed or revealed or possibly brought anew?

24 MR. PEARCE: That was the Root 25 Cause; wasnt it?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

101 1 MR. MENDIOLA: Im talking about 2 outside of Davis-Besse. Im talking about First Energy, 3 down toward the plant.

4 MR. PEARCE: Well, you did say 5 First Energy, what we said was FENOC. And the root cause 6 says, FENOC nuclear safety values, behaviors and 7 expectations, which I believe is exactly what youre 8 asking, right, about where the right values, and this is --

9 MR. MENDIOLA: No, Im a little 10 more global, to tell you the truth. Obviously, youve 11 assured yourself that Beaver Valley and Perry Quality 12 Assurance Organizations are functioning at the level that 13 they need to, and youre using them to go bolster and 14 augment Davis-Besse.

15 And, my question is, what oversight previous to this 16 entire occurrence was out there to, say hey, look, these 17 two plants are operating at a high level and this one is 18 not?

19 MR. PEARCE: We have the 20 Nuclear Review Board, looks at that, and has some input 21 there. The Joint Utility Management Assessment called 22 JUMA, which is a utility group that goes, looks at the 23 assessment function; does that very thing. We did 24 self-assessments at all the sites. And I guess there was 25 no higher level of management viewed on quality assurance MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

102 1 by itself and how it might be different between the three 2 sites.

3 But, it was, it was something that we were missing.

4 Thats why, I think maybe we intuitively knew that, even 5 before this root cause was done. Thats for instance why 6 we, we put me in my job, and made a corporate function to 7 provide that oversight for all the plants.

8 Maybe I missed the question. Did I miss it?

9 MR. MYERS: I think one of the 10 things that were seeing from the corporate standpoint is 11 this whole corporate organization, FENOC did not exist with 12 the oversight, and Gary Leidich; he was strictly involved 13 by himself. We have some additional items, our common 14 processes and those kind of qualities, to look at the 15 standards and oversights.

16 A couple of things that went through the mind as we 17 went through this, I know, that at our other sites, we used 18 INPO for instance very effectively. And we particularly 19 have a need both ways and really try to use the industry.

20 Also know that our Davis-Besse was an outliner, and 21 did not really enjoy dealing with the Institute of Nuclear 22 Power. They would openly tell me that.

23 I also know that, Bill brought up the issue recently 24 in his presentation about a tag and safety training. We 25 lived through a very significant experience at our Beaver MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

103 1 Valley Plant. As difficult as that was, you would think 2 that we would just really internalize that over at FENOC 3 and have new standards at tag and safety trainings at each 4 one of our plants. Well, guess what? It didnt happen.

5 But Ill tell you what, its happening now. And Bill is 6 running through safety training; I am too.

7 After we went through the significant emotion of 8 being at the Beaver Valley Plant and as much as we 9 discussed, it didnt seem to take. That gets back to the 10 complacency issue, you know, everything we did is okay. We 11 dont make any changes. Thats, thats a major change in 12 the way were doing business.

13 I think our oversight, Corporate Oversight Group we 14 have now, puts us in good standard between Gary and myself, 15 and Bill, to make sure we drive that, learn from each 16 organization and drive those standards through each and 17 every site. So, we know thats what happened before.

18 So, thats the way Ill answer that question. Was 19 there something amiss? Yes, there was.

20 MR. MENDIOLA: You answered the 21 question. Clearly, I was after whether there had been some 22 institutionalizing the approach across the plants, since 23 you obviously have had two good performers and one needed 24 performance enhancement. So, I was just trying to 25 ascertain whether there had been a corporate level MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

104 1 understanding of this, and reaction.

2 MR. MYERS: Thank you.

3 MR. PEARCE: If there is no 4 more questions, our next speaker is Bob Schrauder, who 5 would discuss the Head Resolution Plan.

6 MR. GROBE: Lew, excuse me, 7 before we go on, I would like to go for about another 15 8 minutes, and then take another break. Perhaps take another 9 break, and then move into the public comment part. So, if 10 there is something -- you would just like to continue on, 11 thats fine, but if there is some specific portion you 12 would rather have.

13 MR. MYERS: I think the 14 Reactor Head Plan is the major, major accomplishment since 15 the last meeting. Lets do that and see if we can get 16 through the containment very promptly. I think both of 17 those things we should know about.

18 With that, Bob Schrauder.

19 MR. SCHRAUDER: Okay, thank 20 you, Bill and Lew.

21 As Lew indicated, we are pleased with the progress 22 thats being made on the new replacement head. And I have 23 the senior management oversight for that, but I feel its 24 only right to put the credit where the credit is due.

25 The success of the project weve had so far relies MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

105 1 heavily to our partners back in Grand Stone. In particular 2 to our project managers on the site; Dave Baker, Steve Fox, 3 Rich Chesko, Mark Wymer, Theo Swim provided oversight to 4 this project.

5 Its really taken a step forward and met the 6 challenge. We are on schedule. The bottom line, we 7 continue towards moving towards completion of this project 8 to support a safe, reliable return this year.

9 Up at Midland, the activities up there, our head 10 arrived, I believe it was, two days after our last 11 meeting. It was a two-day trip for the head to come down 12 from Midland, Michigan. And that trip really provided some 13 interesting sightseeing, I think, for some people along the 14 route to see that reactor vessel head on a 180-foot long 15 truck coming down the highway, it was interesting to say 16 the least.

17 In fact, one of the radio stations I was listening 18 to had a "Follow the reactor head" play-by-play throughout 19 the day. Got a lot of attention on the way down.

20 But the bottom line, we got it on site, and it was a 21 major milestone for us. It was something that we could 22 visibly celebrate at the site, which we did. We took time 23 out, served lunch for the entire organization at the whole 24 site, so they could see, have an opportunity to see that 25 the head had arrived and kind of get that sense that we are MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

106 1 making progress toward returning this plant to safe and 2 reliable operation.

3 So, it was a big momentous occasion for us to get 4 that reactor vessel head on site.

5 With that, all of our activities at Midland are 6 complete. We have closed up that containment. Weve 7 exited the site and I think we left it in better shape than 8 when we got there.

9 Framatone has completed for us a composite co-data 10 package, code reconciliation package and our design 11 reconciliation package. Those have been submitted to FENOC 12 for NRC approval.

13 And as your slide indicated earlier, we have 14 provided all of the information we believe is necessary to 15 the NRC, so they can complete their reviews as this new 16 reactor vessel head will meet all the necessary 17 requirements for its use.

18 Just real quickly, give you some pictures. Thats 19 the head being loaded at Midland. The next one is the head 20 as it arrives at the Davis-Besse site.

21 And, particularly the Davis-Besse site, lets talk 22 about progress there. Our reactor vessel head in the 23 containment has been prepared for removal from the 24 containment. The service structure preparations have been 25 complete. All the modifications have been made to that.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

107 1 The temporary openings that were made in the service 2 structure have been restored and all thats left to be done 3 on that, were going to put a new coat of paint on it and 4 well be ready to service our new reactor head.

5 As Clark indicated earlier, our shield building 6 opening has been complete and that was a marvel in itself 7 to watch the hydrodemolition of that, using high pressure 8 water to wash the concrete off. And it was a technical 9 operation by way of what the vendor had shown us and what 10 was demonstrated; very reliable source of getting the 11 containment open.

12 And thats where we sit with that. Were about 13 ready to cut the actual containment pressure vessel. We 14 are resolving some final conflicts with the NRC on the 15 desire to get a couple more samples out of the existing 16 reactor vessel head. We believe that we achieved 17 resolution on that today. And formal approval, were still 18 waiting on that. So, were moving forward very quickly.

19 Thats the reactor vessel head as currently inside 20 our containment ready to be taken out of its containment.

21 Heres the target area we had to open the containment. We 22 had to protect our startup transformer, which sits right 23 outside of that area. We did that very effectively. I 24 believe we had no impact on that startup transformer.

25 Next slide shows preparation for the opening. We MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

108 1 had to erect a large platform there. Had to put a vacuum 2 plate on the containment.

3 Next slide. To make sure we didnt get water inside 4 the annulus while we were putting 20,000 pounds of pressure 5 on the outside of the containment.

6 This is a really good shot of washing the concrete 7 right off of the rebar. Not damaging or impacting the 8 rebar at all. Exposed one layer of rebar at a time and cut 9 that rebar out, tag it, and it will go right back in place 10 where it came from once we have the reactor vessel head 11 swapped out of there.

12 Finally, thats what the hole in the containment 13 looks like. The vacuum plate is obviously still on there, 14 all the rebar is gone, all the concrete is gone. And that 15 took us about six or seven days, I believe, to complete 16 that activity. So, again, very pleased with the activity 17 we have here.

18 The last shot that I have is our preparations for 19 the actual setting of the steel pressure vessel and the 20 rewelding of it. This is a mockup we had of the training 21 of people in the cutting activities, welding activities, 22 as we prepare to restore the containment to its design 23 intent.

24 Thats where the head replacement has come to.

25 MR. MYERS: Lets move on to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

109 1 containment if its okay. Randy.

2 MR. FAST: I understand, five 3 minutes or less.

4 Well, Im pleased to meet with you today to update 5 us on progress were making on containment health. And the 6 first item I want to talk about is containment air 7 coolers. We have three containment air coolers. Were 8 doing complete refurbishment of those.

9 By way of a personal note, Im kind of a car nut.

10 This is like body off restoration. Weve got all of the 11 cooling coils completely removed, drop out registers are 12 being removed and the complete plenum is being replaced.

13 So, this is a significant level of effort.

14 Well be replacing two of the motors on the fans, 15 and one refurbished. This is going to be a complete 16 refurbishment.

17 Got a picture of some of the workers. This has 18 really been as well good teamwork, and exercising good 19 safety practices, really meeting the challenges. And 20 samples we have here of the photographs of the crew 21 actually removing each one of the containment air coolers, 22 have twelve cooling coils, a total of 36. There is one of 23 them thats getting removed there.

24 Another item that we talked about the last time we 25 met, were the Containment Under Vessel; the vessel MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

110 1 examinations that we need to do. And as we had a 2 significant degradation of the reactor pressure vessel 3 head, we additionally had performed under vessel 4 inspections using a crawlup, but there was some areas that 5 were inaccessible.

6 Subsequently, weve put in a modification that 7 allowed us to put the incore instruments up in the vessel.

8 Weve drained down. Were at 8 inches in the vessel, with 9 the index fixture in place.

10 Weve removed the seal plates.

11 We have removed the insulation of 15 restricted 12 uses. Thats first time revolution. And subsequently, 13 were able to use the refueling machine with a camera to 14 fully identify the areas on top of the hot leg and cold leg 15 nozzles as well as the core flood tank nozzles.

16 Those inspections have been videographed. I believe 17 Mel youve had an opportunity to look at some of those.

18 Bottom line is we dont see significant degradation. It 19 seems to support our conclusion that weve had some 20 washdown of the vessel. So, those are, Ill say it, a good 21 news story.

22 Additionally, as Mel had talked about, the 23 inspections; we did complete the training of our new group 24 of inspectors, very experienced inspectors, using a new 25 procedure for training.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

111 1 We have deployed those individuals and right now are 2 60 percent or so complete with the reinspections, very 3 detailed inspections.

4 And some of the things we talked about last time, or 5 some things we see different than what we saw before. If 6 we go back, the original thrust was boric acid program, 7 really looking at degradation mechanisms. This is a 8 complete containment health program, and weve seen a 9 significant amount of detail in the inspections performed.

10 Most notably, if you look at what is the difference, 11 we excluded a group of valves, the root isolation valves on 12 instrumentation systems. The original inspections had that 13 transition point and were not picked up through the new 14 inspection programs. Those were identified and we do have 15 minor leaking. So, those are in the population of areas to 16 be corrected. But overall, aside from the fact we have 17 very good detail on the inspections, we did not find 18 anything significant that was missed on the first time.

19 Next slide please. This is the decay heat valve 20 pit. Although this does not really represent a technical 21 issue or technical specification requirement issue, this is 22 a low standards issue. Systematically coming out of a 23 refueling outage, we have sealed this decay heat valve pit 24 used in red RTV.

25 Thats what you see on the floor here. That does MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

112 1 not meet our expectations. And we have a team of folks 2 that are looking at several options that will really 3 improve this.

4 Bottom line is, there is two valves, decaying heat 5 valves that need to be maintained in an operable condition 6 during a large break LOCA accident in a flooded condition 7 and were looking at options that are going to permanently 8 seal that valve head to improve our standards.

9 Okay. The next Containment Pressure Vessel, we 10 talked about this at the last public meeting. We had a 11 couple of items that came up. One is the MIC. And we have 12 done an evaluation analysis, and do not have MIC. So, 13 thats a good thing as well.

14 Corrosion. We learned some things from some experts 15 in the caustic conditions that exist with seal adjacent to 16 concrete is an environment where the pH is 12.6 plus, very 17 caustic environment that will not allow corrosion to 18 exist. So, the areas that we were concerned about where 19 metal is coming in direct contact with concrete, it would 20 be very difficult to assess, based on the pH would not have 21 corrosion.

22 Additionally, we have expanded the scope to include 23 equipment qualifications, things like motor operating 24 valves and other equipment default issues and those 25 walkdowns are in progress as well. We expect to complete MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

113 1 our walkdowns this week.

2 The next picture is, this is an area, look at the 3 very bottom of the picture, is our Containment Emergency 4 Sump. And this is an industry focus. Its, the Nuclear 5 Regulatory Commission is working advising the industry 6 about standards. This is an area of focus for us and we 7 are clearly dedicated to improving margin there. So, we 8 have a team of folks that are looking at several options 9 but we believe that you can gain pretty significant margin 10 by improving the containment sump area.

11 Containment coatings. Weve got about 40,000 square 12 feet of dome. The dome has coatings that are peeling. And 13 were in the progress of, weve got a company, Canon Sline, 14 partnership with them, 60 or so painters.

15 Scaffolding is now suspended in the overhead. You 16 can see the pictures. Its really a remarkable 17 achievement, because our polar crane is not in service.

18 So, we suspended the platforms up into the top of the 19 containment and we have painters removing the top coat 20 using needle guns. Thats a very time exhaustive process, 21 but it will yield good results in removing that top coat 22 and going back with carbon units, qualified for the life of 23 the plant.

24 Heres another example where the scaffold is 25 actually underneath whats called the bull ring, which is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

114 1 the support mechanism for the polar ring.

2 Some additional pictures. We did decontaminate from 3 the 653 foot elevation. On the 603, all of the exterior 4 walls of containment, thats really a brightened 5 containment. Made it visually much more appealing. We got 6 some additional work to do there on the concrete walls and 7 things, in the B rooms.

8 I think that concludes our pictures. So, you see, 9 we have a significant amount of activity inside of 10 containment. At any one time, youll see well over a 11 hundred workers engaged in containment activities. So, we 12 feel good about the progress were making in improving the 13 conditions in our containment.

14 Any questions?

15 MR. MYERS: Did you get on 16 the scaffold, Randy?

17 MR. FAST: I didnt get on 18 that scaffold. I would like to.

19 Just a side note. I think there is an interesting 20 perspective with the Restart Oversight Panel. We have 21 twelve individuals that took a fairly comprehensive tour of 22 the containment yesterday. And so that our Restart 23 Oversight Panel would have a good appreciation for, what 24 are the conditions in the containment and what work do we 25 have going on.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

115 1 So, I did get valuable feedback from those folks and 2 they have an appreciation for the work going on, but thats 3 an example of dedication that our Restart Oversight Panel 4 has in really understanding the problems that we face, as 5 well as adding value in our input to the Containment Health 6 Plan.

7 MR. MYERS: Okay.

8 MR. GROBE: Lew?

9 MR. MYERS: Were ready to 10 go.

11 MR. GROBE: Yes.

12 MR. MYERS: I listen to every 13 thing we say and take notes. I said the other day, that we 14 are, myself personally, technically embarrassed about the 15 reactor vessel head issue, and our complacency on the 16 missed opportunities. Ill say that again. Were just 17 technically embarrassed there. We were complacent.

18 Today, as was indicated, that often though, the 19 cutting edge for improvement for the plants is coming out 20 of trouble. This is 350 process. Thats where were at.

21 As John Kennedy once said, "Great crisis produce 22 great people and great deeds of courage." We have 23 confidence in our people. The plant is their livelihood 24 and they stress that at meetings. They are well educated, 25 technically sound, hard working and proud members of this MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

116 1 community.

2 We will continue to be committed to comprehensive 3 approach here, to ensure that the Davis-Besse Plants 4 restart, and is ready for safe and reliable operations and 5 sustainable performance in the future.

6 Thats all I have to say. Thank you.

7 MR. GROBE: Any other 8 questions from the panel? Okay. Okay, very good.

9 Before we adjourn the business portion of this 10 meeting, I want to invite Jon Johnson to give us his 11 observations on this.

12 MR. JOHNSON: I just want to 13 say a few things. I was glad to get the opportunity to get 14 out of Washington and visit the plant today. I wanted to 15 come out and see what our team, the NRC team, is doing 16 here. I guess theyve had several meetings, but I guess 17 what I would like to say is theyre just getting started.

18 I asked, do we have an inspection schedule? The 19 answer is no. Were planning a lot of inspections.

20 I asked if you have a schedule that they can believe 21 in? The answer is no. You have a schedule that you 22 produce, and you know, I get questions when are you going 23 to do things, when are inspection teams going to do things, 24 but we need to know when youre going to do things, because 25 were going to need to borrow inspectors from other MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

117 1 facilities or other regions and get some help. So, were 2 going to need to plan. So, I think one thing that would 3 be helpful is if you had a schedule that we could count 4 on.

5 The other thing I would like to say is that youve 6 got a lot of work to do. And I dont think you probably 7 need me to tell you that. You already know that. But I 8 did get a chance to talk to some of your employees today, 9 and I did get to tour the plant, so Ill tell Mr. Pearce 10 the reason I know youve got a lot of work is because I saw 11 it.

12 MR. PEARCE: Good, were glad 13 you saw it.

14 MR. JOHNSON: You can give me 15 one of your a little cards.

16 So, what I think youve got to do is youve got to 17 get the trust back of your employees. I asked them, you 18 know, we talk about appraisals and you appraise managers 19 and appraise employees, but you know, how often do the 20 employees get to appraise the managers. Not that often.

21 And, I asked them, you know, what they thought of 22 the management team, the management team is going to get 23 them out of this problem here. And, guess what they said?

24 What do you think they said, Mr. Myers?

25 MR. MYERS: I think they MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

118 1 believe we will get them out of the problem.

2 MR. JOHNSON: They said, actions 3 speak louder than words.

4 MR. MYERS: I believe that.

5 MR. JOHNSON: That was a pretty 6 good saying. I think, like you said at the end, that you 7 have some skilled staff, very skilled staff, and I think 8 they have the will to do the work. And I think what we 9 need to do is provide them the access to be able to do 10 that.

11 Youve got to provide them the expectations and the 12 values of -- your slide here, I guess Mr. Pearce said, 13 FENOC nuclear safety values and behaviors and expectations 14 were inadequate. So, I guess my question is what are your 15 values? I couldnt tell. I couldnt tell from visiting 16 the plant today.

17 MR. MYERS: No, our values are 18 safety, communication, teamwork, customer focus. You know, 19 thats the FENOC values.

20 MR. JOHNSON: I think probably 21 what would help maybe is if you just continue to 22 communicate that to the staff, and to everyone else.

23 I think one of the things weve been criticized for, 24 were getting criticized for not being able to do this 25 oversight. We need somebody else other than the NRC.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

119 1 Im confident in our staff. Weve got a lot of 2 dedicated and experienced people on this team here.

3 Christine has been a Senior Resident Inspector. Weve got 4 all kinds of engineering and inspection and licensing 5 experience on our Oversight Panel as well as our 6 inspectors. So, I think the NRC is confident in our staff 7 to oversee this.

8 One of the things I had a question about your 9 oversight team; you mentioned Mr. Karns provided you some 10 recommendations to go benchmarking. You had indicated you 11 had gone to benchmark some other facilities to get some 12 ideas from them. I didnt hear where you went to. Could 13 you let me know where you went?

14 MR. MYERS: Weve been to 15 Byron, weve been to Salem, Cook. Cook a lot. Those three 16 in particular.

17 MR. JOHNSON: Do you know if any 18 of the operators got a chance to visit these sites?

19 MR. MYERS: Yes.

20 MR. JOHNSON: That to me, I 21 think, will go a long way for you to provide opportunities 22 for the operators to get out and see other places too.

23 One thing I wanted to ask about was the use of 24 risk. I didnt hear anybody talk about your PRA, use of 25 your PRA or safety significance, or types of walkdowns MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

120 1 youre doing. Maybe Mr. Powers can discuss that.

2 MR. POWERS: Sure.

3 MR. JOHNSON: Are you focusing 4 on systems that are important to safety?

5 MR. POWERS: Absolutely. The 6 criteria for selection of population systems was 7 Maintenance Rule Risk Significant Systems. That population 8 was 31 Systems Health Readiness Review. The latent issues 9 review or some of the key systems we feel are on that risk 10 significant, for example, Aux. Feedwater System and 11 Emergency Diesel Generator, but the Reactor Coolant System 12 was involved in the head degradation issue and service 13 water and component cooling water, which are not only, 14 theyre risk significant, but theyre also areas where 15 there are problems, plus tend to manifest themselves there.

16 So, we can think that population of deep slice latent 17 issues were used and give us a good health check.

18 MR. MYERS: In other words, we 19 didnt take primary watch.

20 MR. JOHNSON: When I was in the 21 control room, I noticed there is a lot of green stickers 22 all over the panels. And I guess my question is, are you 23 going to have any green stickers when you restart the plant 24 in the control room?

25 MR. FAST: Our plant includes MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

121 1 completing all of the control room activities and all of 2 the deficiencies.

3 MR. JOHNSON: I guess thats 4 something in terms of operator workarounds or the problems 5 with instrumentation, things that dont work right and 6 automatic. Whatever the case is, I think that will go a 7 long way to demonstrating to the people that you have 8 operating the plant that you intend to focus on safety and 9 the plant equipment.

10 When they say actions speak louder than words, I 11 think those type of things will send a strong message.

12 MR. FAST: We absolutely 13 agree.

14 MR. MYERS: We have control 15 board instrumentation, we have operator workarounds and we 16 have temporary mods on our list.

17 MR. PRICE: Those are all 18 currently part of the restart matrix that we have, not ones 19 that I presented today, but those are in our report.

20 MR. JOHNSON: I appreciate the 21 opportunity to tour. And I guess the last thing Ill end 22 with is, I know I got asked by one of the news media here 23 if they could visit the plant. I know in this day and age 24 of security increases, I think the increased concern for 25 certain types of visitors in the plant is a little MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

122 1 strengthened in background checks, but I know that you 2 would provide opportunities for local officials or elected 3 officials to visit the plant, and I guess maybe I would 4 just like to hear what you have to say about that in terms 5 of bringing in some of the people that live in the area to 6 show them what youre doing.

7 MR. MYERS: We would be more 8 than happy to do that. You know, its hard, at our other 9 plants, weve actually taken tour groups inside the 10 protected area before and done that here. Cant do that 11 now after September 11. On a case by case basis, you know, 12 we more than welcome the press or some outside people to 13 come in and look at our plant.

14 In fact, weve got on Restart Oversight Panel, weve 15 got Jere Witt is a commissioner, or business manager for 16 the county, so that would not be a problem.

17 MR. JOHNSON: I think that also 18 goes a long way to generate trust and confidence in the 19 local people that live around the area.

20 MR. FAST: Jere was on our 21 tour of containment.

22 MR. MYERS: Jere was on our 23 tour of containment. We had him in the containment.

24 MR. JOHNSON: Okay, thank you 25 very much.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

123 1 MR. MYERS: Thank you for your 2 kind comments and coming today.

3 MR. GROBE: Thank you. Jon.

4 At this time I would like to adjourn the business 5 portion of the meeting and take a five minute break. Well 6 reconfigure the stage a bit and take public comments and 7 questions.

8 So, thank you very much. Be back at 5:15.

9 (Off the record.)

10 MR. GROBE: Okay, thank you 11 very much. Appreciate those of you that had the staying 12 power to get through the meeting, and those are very 13 formative meetings for us. I hope you found them 14 informative also.

15 What I would like to do is ask if there is anyone 16 here, this is the first meeting that theyve come to 17 regarding Davis-Besse. Just raise your hand. Do we have 18 any newcomers. Excellent. Oh, Jon. Very good, very 19 good.

20 What Im going to do in this segment is to give a 21 little background information, respective to Davis-Besse, 22 and Doug will. And then what Im going to do is open it up 23 to first questions from representatives of local officials, 24 and then from local community here around the Davis-Besse 25 Facility, and if there is other members, concerned members MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

124 1 of the public, well entertain questions from them.

2 Our primary focus, were interested in any questions 3 or comments regarding the meeting or regarding Davis-Besse 4 or any other topic in our area for you that youre 5 interested in talking about.

6 MR. SIMPKINS: Well, what you 7 see up here, was actually taken off the NRC Website. If 8 you would like to go to that, its www.nrc.gov. They 9 actually have an isolated viewing area. We took a slide 10 from that and put it up here for those of you arent 11 familiar with how major power plants work.

12 Starting off with inside of what we call the 13 containment structure, we have the place where there is 14 actually the nuclear reaction going on. The nuclear 15 reaction is just used to generate heat energy to make the 16 water inside the primary system hot. That water then 17 circulates in a continuous loop.

18 Once it goes into the steam generator, it doesnt 19 mix with the other water, but instead it transfers heat 20 energy like a radiator in a car transfers the heat out and 21 it turns to water inside the steam generator to steam, 22 which then comes out the top, goes through a series of 23 pipes, and then goes through a turbine.

24 The turbine spins at a high rate of speed, which 25 turns a generator. That generator then makes electricity.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

125 1 The water continues down into a condenser, which is then 2 circulated back into the system generator.

3 Off to the side, which you cant see here, the water 4 from the cooling tower, which everybody assumes is the 5 containment vessel. The cooling tower is the 493 foot 6 structure on the site; comes into the condenser, condenses 7 the steam back into water and goes back out to the cooling 8 tower.

9 Next slide.

10 On top of the reactor itself; is the head unit.

11 Its like if you have a pressure cooker, you have a sealed 12 unit on top. The water inside the primary system is 13 pressurized to keep it from turning to steam. And its 14 held, the pressure is held in by this head structure.

15 Coming down through the top of the head are the 16 control rod drive mechanisms. Those are used to regulate 17 how much energy is produced in nuclear reaction. Through 18 the head structure, the control rod drive mechanisms go 19 through a nozzle. And those nozzles are what the problem 20 started as.

21 Next slide.

22 These nozzles penetrate the reactor head, which is 23 about a 6-inch structure; and its sealed at the bottom 24 with whats called a J-groove weld. This J-groove weld 25 creates stresses in the nozzle, and as a result of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

126 1 allowing the water to penetrate up through and come through 2 the top of the reactor head area.

3 The water inside the primary system has boric acid 4 in it, which is very, very similar to Borax, like you buy 5 in a store. Thats sodium borate, but they use pure boric 6 acid here.

7 Next slide.

8 This is actually a picture taken on top of the 9 reactor head. And the deposits that you see coming out of 10 these what we call mouse holes or weep holes here are 11 actually boric acid that leaked up past the control drive 12 nozzles and are now on the head. Theyre kind of reddish 13 color, because they actually contain iron oxide.

14 Next slide.

15 This is an artists rendition of the damage to the 16 top of the head. As you can see, the nozzle area had water 17 leak past it and create a cavity because the boric acid 18 dissolved away the metal. The last remaining barrier was 19 indeed the approximately 8th inch seal liner on the bottom 20 side. That was not wasted away, because it was stainless 21 steel, rather than carbon steel like the rest of the head.

22 Okay.

23 MR. GROBE: Okay, thanks 24 Doug.

25 At this time, I would like any local public MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

127 1 officials or representatives of the office to approach the 2 microphone, if you have any questions or comments you want 3 to make. Okay.

4 Members of the community here in Oak Harbor; are 5 there any members of the community that have any question?

6 I didnt mention to put your name on the page, but 7 Howard has done that before.

8 MR. WHITCOMB: Good afternoon.

9 My name is Howard Whitcomb. I have a couple of questions.

10 First, is regarding, I believe its Slide 37, on 11 page 19 of the First Energy handout. There was a lot of 12 discussion regarding the I think obvious indicators on that 13 particular chart.

14 The first questions that pops out in my mind are 15 based on the expansive discussion regarding changes that 16 have occurred in employee culture and that sort of thing at 17 the site. At least thats what has been reported.

18 I guess my first question is, of that number of 19 condition reports that were, I guess its somewhere almost 20 800 to-date; how many of those are by supervisors and how 21 many of those are by employees in the field; how many are 22 by office maintenance, health physics, quality assurance 23 and engineering; how many are by contractors versus on-site 24 personnel?

25 I think that a breakdown of that type of figure MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

128 1 might indicate whether these problems are just now coming 2 out of the woodwork from little books that people have been 3 carrying around for some period of time. I think were 4 being led to believe that there is a more open environment 5 for bringing conditions or adverse conditions to light.

6 It would seem to me that if there is a breakdown in 7 those number of condition reports, it might provide some 8 insight. Have you asked that or has anyone from your staff 9 asked that?

10 MR. GROBE: I dont have that 11 on my fingertips. Thats data thats normally maintained 12 and I havent reviewed it recently, but Im certain First 13 Energy has that data. I believe that they would be glad to 14 share that with you.

15 Is that something that you folks do? Not today at 16 the meeting, but Im sure youll be glad to get that to you 17 Howard.

18 MR. WHITCOMB: All right. The 19 second issue is for you, or your staff, Jack. And, I 20 understand that there is a caveat that you just recently 21 received the Root Cause Analysis Report from the Licensee.

22 But I guess the first question that comes to mind, I think, 23 Mr. Johnson kind of touched on it briefly; regarding, Ill 24 pick on Mr. Pearces root cause that he identified. I 25 guess slide 45, page 23. He identifies that "nuclear MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

129 1 safety values, behavior and expectations were inadequate 2 through oversight."

3 The question is this; does the NRC believe that 4 First Energy has gone far enough in their root cause 5 determination? In other words, it seems to me that part 6 of the exercise of root cause evaluations and analysis is 7 to keep asking the question why. We all did that at a very 8 tender age and we always ask our parents why. Okay. As we 9 get older we become wiser and we become more self-confident 10 and we think we have the answer, but we dont ask the 11 question why.

12 But just in what was stated on slide 45, it appears 13 to me that you could ask the question why. And I dont 14 think the answer comes out. So, Im not so sure that 15 theyve gone as far as they need to go. Is the NRC 16 satisfied that they have?

17 MR. GROBE: We had a several 18 hour meeting last Thursday, and at that time we received a 19 copy of the Root Cause Analysis. There is many different 20 ways to do these types of analysis. I think we chose one 21 thats more management of oversight risk. And it is a very 22 structured approach to asking that exact question, ask 23 why. And it goes through a structured approach of looking 24 at systems and structures within the organization that 25 assure effectiveness, from defining policies to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

130 1 communications, procedures and all sorts of different 2 things.

3 We have not had an opportunity to review that report 4 in detail. Thats part of our inspection area of 5 Management Human Performance, is going to be. The first 6 part is going to be a thorough review of that Root Cause 7 Report.

8 MR. WHITCOMB: The third 9 observation that I would like to make is that several 10 pieces of equipment this afternoon, in addition to the 11 reactor head degradation, such as, if I can remember, 12 diesel generator, one of the damper arm levers was bound up 13 or loose or something of that nature, and the other was the 14 missle shield on the muffler.

15 Those types of issues suggest that either people are 16 not, are actually not walking the systems down or paying 17 attention to the system, or understanding that those 18 conditions exist or ignoring them anyway.

19 In addition to that, weve heard several times this 20 afternoon that there have been some problems with 21 classifying the equipment in certain categories. In other 22 words, the Maintenance Rule 6055, I think is the number, 23 but I dont remember exactly, but the Maintenance Rule Laws 24 that came out in the requirements clearly required 25 Licensees to make those component determinations.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

131 1 Does the NRC have plans to evaluate the 2 effectiveness and adequacy of the Maintenance Rule 3 implementation at Davis-Besse?

4 MR. GROBE: To comment, your 5 first observation I think is correct, that either the 6 equipment, for example, you highlighted the damper, 7 actually the arm that was loose, and missle shield or the 8 tornado shield rather on the vent for exhaust generator. I 9 believe youre correct that either those werent looked at 10 correctly or they werent looked at previously. And Im 11 thinking the systems discussion First Energy presented 12 today, theyre going to have a structured, clearly defined 13 expectation for system walkdowns, regular system walkdowns, 14 that would be part of their System Health Program. I 15 believe that already exists in oversights. For whatever 16 reason, did not exist here.

17 The second comment, I think if I understood your 18 comment correctly, you may have misunderstood, I believe 19 what First Energy was talking about was a failure to 20 properly classify condition reports. That in the, the 21 Davis-Besse Plant has multiple levels of significance 22 condition reports from, you know, the very lowest level, a 23 lightbulb needs changed to the most significant, which is 24 for a significant condition adverse to quality requiring 25 cause.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

132 1 In the past, they did not look in depth sufficiently 2 at the issue to properly characterize within those 3 hierarchical levels of significance, and consequently they 4 may have underevaluated the significance of the issue and 5 not properly corrected it.

6 So, it wasnt the classification of equipment, other 7 than the contents of maintenance workers classification of 8 condition reports within the significant scheme that they 9 have in Corrective Action Program.

10 And your specific question, we do not have as part 11 of the restart plan, an evaluation currently of the 12 Maintenance Rule. Thats not on the agenda. Okay, of 13 course, its part of our routine base inspection, but its 14 not a unique characteristic of restart.

15 MR. WHITCOMB: So, as a result of 16 the report, the NRC is satisfied the equipment has been 17 properly classified.

18 MR. GROBE: I believe thats 19 correct.

20 MR. WHITCOMB: Thank you.

21 MR. GROBE: Okay, other 22 members of the public, that have a question or comment.

23 MR. KEEGAN: My name is Michael 24 Keegan. Im from Monroe, Michigan, just north of here.

25 I believe that the NRC and the utility, First MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

133 1 Energy, are on a collusion course for disaster.

2 Just this week, I see posted by the NRC that theyre 3 considering looking to a third party. If there is need to 4 penalize the utility, they would like for a third party 5 arbitrator to establish what the penalty would be.

6 I see this just yesterday. They announced that 7 theyll be holding a workshop with IMPO on essentially how 8 to further deregulate the regulatory responsibility that 9 the NRC has.

10 In April, I was one of 15 groups led by concerned 11 scientists, which filed for Freedom of Information and 12 requested that information. We have been stonewalled on 13 that information. We have not gotten the information yet.

14 Today I learn that the 206 petition which we have 15 filed asking for immediate independent review has been 16 denied.

17 I have sat through an excruciating four-hour 18 conference call, where Jim Dyer said never, never could 19 this happen again. Never. Never. Never. Never. Wolf.

20 Wolf. Wolf. Wolf. Like the boy who cried wolf.

21 Either you are the regulator or you are not the 22 regulator, and your behaviors surely demonstrate that you 23 are not the regulator and you are not going to stand up on 24 the publics behalf and regulate. Thats my comment.

25 I am concerned about this reactor vessel. I am MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

134 1 concerned about the issue of imbrittlement industry-wide.

2 And I wonder what the level of imbrittlement at this 3 reactor is, the potential for pressurized thermoshock at 4 this reactor. This is clearly a damaged piece of goods. I 5 wonder if you could speak to that.

6 MR. GROBE: There is a unique 7 characteristic at Davis-Besse that makes it different than 8 any other of the operating power plants in the United 9 States with respect to pressurized nuclear shell.

10 MR. KEEGAN: Do you have NSIs 11 of that, the building, the RV factors, the whatever?

12 MR. GROBE: I am not sure we 13 are prepared to respond right now, but what we can do is 14 get you in touch with the right people that can give you 15 more information on pressurized thermoshock.

16 MR. KEEGAN: This has been, 17 weve been stonewalled at the Palisades Plant as well, 18 which has seen beryllium since 1981, and the NRC has 19 rewritten five times the level of imbrittlement that they 20 will tolerate. So, again, my faith in the NRC goes back 21 over 20 years, and I dont have any.

22 MR. GROBE: So does mine.

23 MR. KEEGAN: Okay. On the 24 excruciating call that I sat through, I learned there were 25 700 pieces of data and 120 interviews for a total of a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

135 1 thousand hits of data, 126-page document, which served as 2 the basis for the Root Cause Analysis.

3 I would like to know how I can get this in hand.

4 And I dont want to hear file a Freedom of Information 5 request, because clearly you stonewall everyone who does.

6 And, I need to do my own root cause analysis, because I 7 frankly dont have any faith in the NRC and I have less 8 faith in the utility to come clean with whats going on.

9 So, how did I get that in hand?

10 MR. GROBE: It sounds like you 11 had a fairly good telephone connection, you got a lot of 12 detail out of the meeting last Thursday. During that 13 meeting, Les indicated that they would be submitting it on 14 the docket this week. It would be posted to our Website.

15 MR. KEEGAN: Thats the Root 16 Cause Analysis. Will all thousand bits of data on which to 17 base the Root Cause Analysis be available?

18 MR. GROBE: No.

19 MR. KEEGAN: I want to review 20 that.

21 MR. GROBE: Its not required 22 to be submitted. When we do our inspections of the root 23 cause report, well certainly be evaluating some of that.

24 Its volumes and volumes of information available on site, 25 but its not available to the NRC in our office, and its MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

136 1 not a public document.

2 MR. KEEGAN: But the NRC will 3 be reviewing it on site?

4 MR. GROBE: Yes, just like we 5 have on inspections.

6 MR. KEEGAN: I believe the 7 public needs to have access to that as well.

8 MR. GROBE: I appreciate your 9 point of view.

10 MR. KEEGAN: Well, I will push 11 my point of view, and I want to get that data. So, I will 12 pursue an evidence, be it legal, what have you to get 13 that.

14 MR. GROBE: Okay. Do you have 15 any other questions?

16 MR. KEEGAN: I had a thought, 17 but it escape me at this time, but were watching you very 18 closely, and Im sadly disappointed that youve turned down 19 our request.

20 MR. GROBE: I think you made a 21 number of statements in your preamble to your first 22 question. Several of them are not correct. Your petition 23 was not denied. What was issued this week was a proposed 24 resolution to the petition, and it was requesting your 25 feedback and comments on that proposed resolution.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

137 1 So, this is part of the process of the intensive or 2 .206 review process, and we would look forward to comments 3 from any or all of the petitioners.

4 MR. KEEGAN: I stand corrected, 5 and I will look at that document from you again, and will 6 respond.

7 MR. GROBE: There is a number 8 of other issues you raised. First of all, ultimate dispute 9 resolution as a potential vehicle for addressing the 10 issues.

11 Bill?

12 MR. DEAN: Your issue that 13 you raised initially regarding a third party arbitrator 14 relative to Davis-Besse. I think we were referring to, is 15 that there has been plans for a meeting to discuss the 16 potential of the use of what is called alternate dispute 17 resolution.

18 The NRC has done some assessment of that and is 19 looking to gather feedback on the potential of using that 20 in certain situations. Its not something were looking at 21 in terms of resolving issues with Davis-Besse. This is 22 just being looked at by the agency as a potential 23 methodology for looking at certain types of issues.

24 MR. GROBE: Just another 25 observation. I think-- Im grateful that you are engaged MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

138 1 in this, because every process is better if it has full 2 engagement, broad spectrum of views and opinions, and Im 3 glad you had the opportunity to listen into and participate 4 in the meeting last Thursday.

5 We have gone to I believe unprecedented lengths to 6 provide that access, and I hope you continue to take the 7 opportunity to participate in the meetings either 8 telephonically, or both telephonic connection, video 9 conferencing links to Washington, as well as come to these 10 meetings here. I am appreciative of your input.

11 MR. KEEGAN: Just came to me 12 what my thought was that escaped me.

13 MR. GROBE: Good. Go ahead.

14 MR. KEEGAN: On the phone call 15 of last week, I asked whats the NRC been doing to review 16 all these walkdowns that the utility had intended to do.

17 And, the response I got was that you would review the 18 paperwork.

19 MR. GROBE: No, thats just 20 not, absolutely not.

21 MR. KEEGAN: Well, thats the 22 response I got on the phone.

23 MR. GROBE: Maybe the 24 telephone connection wasnt as good as I thought.

25 There is a generic approach to all of this work that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

139 1 were going to do. And, Christine refers to many stars in 2 the approach, but the first thing were going to do is 3 review the program or the plan that the Licensee has.

4 Thats a paperwork review.

5 Mel is sitting in the audience. He was the first 6 inspector that had an opportunity to look at the plan, 7 licensee was furthest ahead on the Containment Health 8 Assurance Plan, and provided substantive feedback to 9 Licensee on aspects of that plan that could be improved.

10 The next step is to review the Licensees 11 implementation of that plan. In the case of, for example, 12 Systems Review. That includes observing the Licensees 13 staff in the field doing the work that theyre doing, 14 evaluating how theyre evaluating issues that they come 15 across.

16 The next step is for us to review how the Licensee 17 characterizes its position issue that they have, and 18 finally to perform inspections. And each of our 19 inspections in each of these areas has components, and 20 thats how we will build confidence in the adequacy of 21 licensing activities and we will be communicating the 22 results of those inspections on each of those meetings to 23 the public as well as through our inspection groups.

24 MR. KEEGAN: I recall from 25 previous meetings, you said that you inspected one to two MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

140 1 percent of the systems. Seems that we have a culture of 2 production over safety that permeates First Energy. And I 3 would encourage the NRC to review the entire plant, walk it 4 down.

5 MR. GROBE: When we were 6 referring to, I believe in that previous comment, had to do 7 with our routine baseline program. I guarantee you that 8 First Energy is taking lots of our attention.

9 MR. KEEGAN: As well deserved, 10 as well as the NRC deserves public scrutinization.

11 Thank you.

12 MR. GROBE: Good, thank you.

13 Other members of the public that have a question or 14 comment? You dont?

15 MR. WHITCOMB: I didnt see Mel 16 hiding over here, so I have a question specifically for 17 him.

18 You would, apparently youve done a recent 19 inspection, and you identified two violations. I guess my 20 question is, when did you begin your inspection and when 21 did you conclude it?

22 MR. HOLMBERG: Okay. I heard 23 the question on the way up. The question was, when did I 24 begin the inspection of the Licensee efforts to do their 25 Containment Standard Issue Reviews and when did it end.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

141 1 The inspection began in June, and the total time 2 that we spent on inspection was three full weeks reviewing 3 Licensee activities, and we identified those two findings 4 characterized as violations.

5 MR. WHITCOMB: And --

6 MR. HOLMBERG: It ended on July 7 25th.

8 MR. WHITCOMB: So, three weeks 9 from June to July 25. Well, July 25th, most of July.

10 And you found two violations, one of them being a 11 lack of acceptance criteria in violation of Appendix E 12 Criterion 5, and there was inadequate training, apparently 13 of VT-2 inspectors; is that correct? Were those the 14 essence of the two violations?

15 MR. HOLMBERG: Yes.

16 MR. WHITCOMB: As a result of 17 your findings, how much of the work that had been done 18 during this outage has to be redone?

19 MR. HOLMBERG: Theyre 20 reperforming their effort in its entirety.

21 MR. WHITCOMB: Okay. Do you have 22 any idea how far along they are in the reperformance?

23 MR. HOLMBERG: Their current 24 schedule, I think, this is just, I will probably have to 25 confirm this, is late August.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

142 1 MR. WHITCOMB: Thank you.

2 MR. GROBE: Let me provide a 3 little more context to that.

4 The Licensee initiated a different approach to 5 containment. First off, the initial evaluation was limited 6 to boric acid impact on equipment in containment. And the 7 training was focused on whats referred to as a VT-2 8 qualification. Thats a qualification of the American 9 Society of Mechanical Engineering standards for doing 10 visual inspections of the metal, degradation of metal.

11 Mel did the inspection, found some difficulties with 12 qualification, some problems with qualifications of people, 13 as well as went out in the field and found further issues 14 on equipment that had been inspected by the Licensee staff, 15 that hadnt been disclosed through their inspections. So, 16 Licensee went back to square one.

17 The foundation of the inspection was done. I think 18 you indicated that there werent any, I cant think of the 19 right characterization, substantive issues disclosed, but 20 additional issues that were beyond the scope of the 21 original inspection.

22 Licensee brought in a number of new people to the 23 site, trained them to a much, whats referred to as systems 24 approach to training, much more comprehensive training 25 standard. Both of those were acceptable to us, and is in MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

143 1 the course of reperforming those inspections, and were 2 continuing to inspect.

3 Just one other thing. Are the three weeks of, that 4 Mel referred to, is what we call direct inspection effort.

5 Its set over a period of multiple weeks; and in addition 6 to that, there is quite a bit of time that he spends in the 7 office reviewing documents. And those three weeks were the 8 weeks that he was on site providing direct inspection of 9 the Licensees activities.

10 Did you have another question?

11 MR. WHITCOMB: Well, something 12 you had mentioned to me, or mentioned to the public here.

13 You say they brought in people. Are these contract people 14 that are only here on a temporary basis; is that your 15 understanding; or are these new people, permanent people?

16 MR. HOLMBERG: The new people 17 that are performing the current effort are contractors, 18 primarily. Theyve also brought their own staff on this 19 new training program.

20 The contractors, I know their work histories, 21 extensive backgrounds specifically in examination 22 techniques, many years of experience doing related type of 23 work, such as inspections. And, I hope that answers your 24 question. Theyre primarily contractors that are doing the 25 inspections.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

144 1 MR. WHITCOMB: Well, I guess Im 2 more concerned after the contractors leave, than I am about 3 their current qualifications. Im sure they brought in 4 experts to do these inspections. I guess once they leave, 5 whats left to do further inspections in the future?

6 MR. HOLMBERG: Im not sure.

7 Ill turn it over to Jack. Hes heard about future plans.

8 MR. GROBE: I think thats one 9 of the primary focuses of the meeting today, was to 10 understand in greater detail the initiatives Licensee is 11 taking to address the root cause, which they characterize 12 as a lack of safety focus, putting production over safety.

13 So, they lay out insights they have, their plans on 14 reestablishing that safety focus, standards of technical 15 rigor and discipline in the way work is conducted. And 16 then, how theyre going to provide management oversight of 17 that activity with field observations.

18 And then they have not gotten to us, but theyre 19 planning on developing some sort of matrix performance 20 indicator package in this area that will provide insights.

21 And they did provide some of the, two of the matrixes, I 22 believe. One was Corrective Action Review Board, 23 percentage of time they reject corrective action 24 documents. And the other was Engine Review -- or 25 Engineering Review Assurance Board, I think it was called, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

145 1 and their evaluation of the quality of work product.

2 So, I think its too soon to tell, but I anticipate 3 over the next several meetings, next several months that 4 youll see its coming into clearer focus. This is 5 particularly the area that well be focusing on in our 6 inspections.

7 MR. WHITCOMB: But I am correct 8 in assuming that, my concern is the concern of the NRC as 9 well, and youre expecting that they will have something in 10 place before --

11 MR. GROBE: Its on our 12 checklist, Howard.

13 MR. WHITCOMB: Okay, its on your 14 checklist. I didnt, I didnt see it on the checklist, 15 Jack, but okay. Thank you.

16 MR. GROBE: Other members of 17 the public that have questions or comments?

18 Okay. Very good. Were going to be back here at 19 7:00 this evening, and make an opportunity for feedback 20 from folks that were here this afternoon, want to come 21 back; or folks that were unable to be here this afternoon.

22 Thank you very much.

23 And please, take an opportunity to provide us 24 feedback on our feedback forms. Postage paid. Just fill 25 them out and send them back to us.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

146 1 Thank you very much.

2 (Off the record.)

3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

147 1 CERTIFICATE 2 I, Marie B. Fresch, Registered Merit Reporter and 3 Notary Public in and for the State of Ohio, duly 4 commissioned and qualified therein, do hereby certify that 5 the foregoing is a true and correct transcript of the 6 proceedings as taken by me and that I was present during 7 all of said proceedings.

8 IN WITNESS WHEREOF, I have hereunto set my hand and 9 affixed my seal of office at Norwalk, Ohio, on this 10 28th day of August, 2002.

11 12 13 14 Marie B. Fresch, RMR 15 NOTARY PUBLIC, STATE OF OHIO 16 My Commission Expires 10-9-03.

17 18 19 20 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO