ML022880256

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Transcript of Public Meeting to Discuss Firstenergy'S Corrective Action Plan for Management and Human Performance Improvement for Davis-Besse Nuclear Power Plant, on 09/18/2002, Oak Harbor, Oh. Pp 1-143
ML022880256
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Issue date: 09/18/2002
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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 Wednesday, September 18, 2002, at 9:00 a.m. at the Davis-Besse Administration Building, 6 Oak Harbor, Ohio, taken by me Marie B. Fresch, Registered Merit Reporter, and Notary Public in and for the State of 7 Ohio.

8 ---

9 PANEL MEMBERS PRESENT:

10 U. S. NUCLEAR REGULATORY COMMISSION 11 Mr. John Grobe, Chairman, MC 0350 Panel William Dean, Vice Chairman, MC 0350 Panel 12 Anthony Mendiola, Section Chief PDIII-2, NRR 13 Christine Lipa, Projects Branch Chief Douglas Simpkins, NRC Resident Inspector 14 Scott Thomas, Senior Resident Inspector at Davis-Besse 15 Geoff Wright, Region 3 Lead Inspector 16 FIRST ENERGY NUCLEAR OPERATING COMPANY 17 Lew Myers, FENOC Chief Operating Officer Robert W. Schrauder, 18 Director - Support Services L. William Pearce 19 Vice President - FENOC Oversight David T. Gudger 20 Manager - Performance Improvement Corrective Action Process Owner 21 Steve Loehlein Manager - Quality Assessment 22 David Eshelman Director - Life Cycle Management 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

2 1 MS. LIPA: Good morning.

2 Hi. Im Christine Lipa with the NRC, and welcome to our 3 public meeting today. Im a Branch Chief in NRCs Region 3 4 Office near Chicago, and I have overall responsibility for 5 the inspection program here at Davis-Besse.

6 Over on the right here, youll see we have an 7 agenda today. There was also a stack of them on the table 8 before you came in the room.

9 The purpose of todays meeting is to discuss 10 FirstEnergys Corrective Action Plan to address the Root 11 Cause Evaluation of the nontechnical issues that resulted 12 in the severe degradation of reactor pressure vessel at 13 Davis-Besse. Well go through the rest of the 14 introductions in a few moments.

15 That Root Cause Evaluation was performed by 16 FirstEnergy and was presented to us, the NRC, at public 17 meeting on August 15th. And as background for that 18 meeting, the transcript is available on our website and the 19 Licensees handout from that meeting is available on our 20 website.

21 Also, the Licensee has submitted their Root Cause 22 Evaluation, and that Root Cause Analysis is available in 23 ADAMS and on our website. And the slides that are being 24 used today by the Licensee are available on our website, so 25 that folks that are on the phonelines will be able to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

3 1 follow along.

2 This meeting is open to the public and the public 3 will have an opportunity before the end of the meeting to 4 ask questions of the NRC. This is considered a Category 5 One Meeting in accordance with NRCs policy in conducting 6 meetings. We have arranged for a hundred phonelines for 7 participants to call in and listen to the meeting. Before 8 the meeting is adjourned, there will be opportunities for 9 members of the public here in the meeting room and on the 10 phonelines to ask questions.

11 And then to assure that people participate, 12 participating by phone can hear our conversations, its 13 important that all speakers use the microphone when 14 talking, like I am.

15 Were also having this meeting transcribed today to 16 maintain a record of the meeting. And weve got Marie 17 Fresch here; and this transcription will be available on 18 our web page in about three weeks.

19 For todays meetings, there is agendas and handouts 20 available on the table outside the room. And also on NRCs 21 website. And, we also have feedback forms on the table 22 outside the room that you can use to provide feedback to us 23 on how this meeting goes. Were trying to improve these 24 meetings as we do them and make sure were meeting the 25 needs of the public.

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

4 1 Also, were planning on handing out a monthly 2 newsletter, which is not here yet. When it arrives, well 3 hand that out in the room.

4 Okay. Next, well go on to the rest of the 5 introductions. Well introduce the folks here at the 6 table. Ill start to my far left is Scott Thomas. Hes 7 the Senior Resident Inspector here at Davis-Besse.

8 Next to him is Tony Mendiola, and hes the Section 9 Chief at NRR for projects.

10 Next to him is Bill Dean, and hes the Vice Chairman 11 of the panel.

12 Next to him is Jack Grobe, and Jack Grobe is the 13 Chairman of this Oversight Panel.

14 And then to my right is Geoff Wright, and hes a 15 Lead Inspector in the Region, and hell be doing a very 16 important inspection that Geoff will talk about in a few 17 moments.

18 I also wanted to introduce Marie Fresch, our 19 transcriber.

20 And, do we have any representatives of public 21 officials in the room? I saw at least one.

22 MR. KOEBEL: Carl Koebel, 23 Ottawa County Commissioner.

24 MR. ARNDT: Steve Arndt, 25 County Commissioner.

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

5 1 MR. PAPCUN: John Papcun, 2 Ottawa County Commissioner.

3 MR. WITT: Jere Witt, County 4 Administrator.

5 MS. LIPA: Great. Thank 6 you.

7 Okay, I would like to turn over to Lew to introduce 8 your staff, and then I have a few more comments.

9 MR. MYERS: Good. Thank 10 you. Okay?

11 Okay. To our left, we have Dave Eshelman. Dave is 12 an, is an employee of the Davis-Besse Plant. Hes, hes 13 now the, one of our corporate employees and along with me 14 now as my staff assistant, helping us with Management/Human 15 Performance Plans that were going to be talking about 16 today. So, Dave is going to be a major speaker here today 17 on some of the actions were going to take.

18 Beside him is Steve Loehlein. Steve Loehlein, for 19 the audience, is from our Beaver Valley Plant. Is a long 20 term employee there. Was the person that was my staff 21 assistant at Beaver Valley before I left, and was the 22 person that came here to head up the Technical Root Cause 23 Team. Is very involved in that.

24 And he was also the, the lead for the 25 Management/Human Performance Root Cause that we did, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

6 1 independent team there, and was the lead for that. So, he 2 did such a good job, we brought him over here and made him 3 our Quality Manager. So, its hard getting him out of 4 Pennsylvania. Hes now an Ohio native.

5 Over on the far right is Dave Gudger. Dave was a 6 previous employee of our, was a previous employee of our 7 Perry Plant. Daves been a long-term employee there, 8 involved with our licensing organization, corrective 9 actions at our other plant. He has now joined our team 10 here and is the Manager of Corrective Actions. So, well 11 be talking a lot about our Corrective Action Program 12 today.

13 The reason thats so important is, you know, one of 14 the mainstay of a nuclear plant is the Corrective Action 15 Program, in finding and fixing problems. Its one of the 16 basic management tools. And to make sure that program is 17 working properly, will be a key part in terms of service.

18 Next to him is Bill Pearce. Bill Pearce has a broad 19 background, as NRC knows. Worked at power plant, Excelon; 20 was a Manager of Beaver Valley Plant. Hes now the VP of 21 Oversight. And so, Bill has an extremely strong background 22 in operations and management. What hes going to talk 23 about is the safety culture of the plant.

24 And Im Lew Myers. Im the site VP and also the 25 Chief Operating Officer of FirstEnergy Nuclear Operating MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

7 1 Company.

2 MS. LIPA: Okay, thank you, 3 Lew.

4 I would also like to introduce a few other NRC folks 5 that are in the room. Jan Strasma is our Public Affairs 6 Officer. Jan is out in the hall. There is Jan.

7 Then we have Rolland Lickus. He is responsible for 8 state and governmental affairs.

9 And we have Nancy Keller, she is the secretary at 10 the site here.

11 And Doug Simpkins is the Resident Inspector.

12 Also the, we just handed out the monthly newsletter, 13 and in the back there is phone numbers that you can reach 14 NRC folks, if you have more questions.

15 The next item on the agenda --

16 MR. MYERS: Christine, we 17 also have some people with us, I would like to introduce 18 them, behind us here.

19 MS. LIPA: Go ahead.

20 MR. MYERS: Lynn Cavalier is 21 our Vice President of Human Resources at your corporate 22 office. She has been very involved in some of the 23 management, helping us with our management action plans.

24 So, shes here with us today.

25 Mike Ross, Ive introduced before. Mike is the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

8 1 previous Plant Manager of GPU Plants. And, Mike, as a 2 proven manager, brought him over to help us out in the 3 operations area. And so, as we return the plant to service 4 operations and those things, will be a key ingredient; Mike 5 is here to help us in that area. And theyll help field 6 some questions today, as we go forward. Okay.

7 MS. LIPA: Okay, thank you.

8 The next item on the agenda, is a brief discussion 9 of the August 15th meeting. And that meeting was held in 10 our Region 3 Office near Chicago. And that was where 11 FirstEnergy came in and presented the results of their Root 12 Cause. And that Root Cause is on the web page and the 13 transcript of that meeting is on the web page.

14 Let me just summarize, the Licensee presented to us 15 that the root causes were in four specific areas and Ill 16 briefly describe those.

17 The first one was Management Oversight, and they 18 described that as a less than adequate nuclear safety 19 focus, and a production focus combined with minimum actions 20 to meet regulatory requirements.

21 The second area was an inadequate implementation of 22 their Corrective Action Program. Lew just described to you 23 why the Corrective Action Program is so important, and they 24 found that they had inadequately implemented that over some 25 period of time.

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

9 1 Third area was Technical Rigor, described as a 2 failure to integrate and apply key industry information and 3 site knowledge to compare that new information to the 4 knowledge that the engineers here at the site already had.

5 And then the fourth area was Program Compliance.

6 There was some steps and especially the Boric Acid Control 7 Program there were not followed.

8 So, these were the four areas that we focused on in 9 Root Cause discussion. Today, were hoping to hear what 10 theyre planning to do about these areas.

11 That concludes my summary of the August 15th 12 meeting, and Ill turn it over to you.

13 The next thing were going to do is have Geoff 14 describe the inspection hes doing.

15 MR. WRIGHT: As Christine 16 indicated, I am Geoff Wright. I am the team lead for a 17 group of individuals comprising of regional technical 18 staff, headquarters experts in human factors and 19 inspection, and a consultant who is an expert in root cause 20 analysis. We have been tasked to look into the analysis 21 that the Licensee has performed in the Management and Human 22 Performance area.

23 We have taken this and broken it into three pieces.

24 I call them three phases, if you like. The first is 25 looking at the technique that they use to develop their MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

10 1 root causes. That inspection is ongoing. It started at 2 the beginning of this month and will end October 4th. The 3 second two phases are the implementation and the final 4 phase then is the effectiveness review. The last two 5 phases have not been scheduled at this time.

6 Christine.

7 MS. LIPA: Okay, thank you.

8 Well turn it over to you then.

9 MR. MYERS: Thank you. Were 10 here today to discuss the Management/Human Performance 11 Improvement Plan. Thats our desired outcome. And explain 12 to you how we came up with that plan.

13 We want to discuss our plan for improving the 14 implementation of our Corrective Action Program. Once 15 again, that program is the management program that we use 16 to identify and fix and track our problems with, before 17 they become safety, safety concerns.

18 And then, finally, well talk to you about the 19 safety conscious work environment at our site, and our 20 plan, our plans to improve that environment, if you will.

21 Just a quick summary, to talk a little about, I did 22 that last night, I talked a little about FirstEnergy 23 Nuclear Operating Company; its vision, mission and goals, 24 if you will, values.

25 The vision of FirstEnergy Nuclear Operating Company MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

11 1 is operational excellence. And this event, and I said that 2 last night, it did not help us in that area. Operational 3 excellence is something that we should, that you never 4 reach, is something we should be striving to improve the 5 plants performance and the personnel performance all the 6 time.

7 And to do that and the only two assets we have, is 8 one the plant itself, and two is the people that work for 9 us. And our mission is people providing safe, reliable and 10 cost effective nuclear generation.

11 Now, you do that through a process of incorporating 12 your values and your standards. And, if you go look at our 13 root cause, our root cause talks about safety focus. Our 14 first value is safety. And its having the right safety 15 conscious at your plant; consciousness safety culture, 16 asking the hard questions, understanding the material 17 condition of your plant.

18 And then you, in order to get there, youre going to 19 have your other asset, the work force. The work force has 20 to be technically competent; you have to have good 21 management skills, good leadership skills. We do that 22 through our training programs, and our leadership and 23 action program for our managers and supervisors.

24 And if you go look right now and you ask what really 25 failed throughout this event, you know thats a key MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

12 1 ingredient, I think, of the failure.

2 Next area is accountability and ownership of your 3 programs, your processes and mature condition of your 4 facility. And you also have to be focused on that. And 5 thats when you really get into the asset of the plant 6 itself. And you accomplish goals and objectives to keep 7 that plant in very good material condition, and constantly 8 upgrading it. And that creates reliable generation, which 9 is value creation for the company.

10 So, if you go around that circle, thats the way we 11 sort of see our values at FirstEnergy Nuclear Operating 12 Company; and, how it all fits together.

13 If you look at our Root Cause here, we would say 14 that there is, the two first Building Blocks did not meet 15 our expectations.

16 One of the things, I dont have a slide for, that 17 you see on our, you see on our walls now, right in the 18 meeting room; is that we went back as Senior Management 19 Team of this site, and we expect every group to do that, 20 and rebaseline our standards.

21 So as a Senior Management Team of this site, what do 22 we have to be about? And that changes from time to time.

23 Now, weve posted these standards on our wall, and 24 were sharing standards with the NRC and sharing standards 25 with the public. Now, were expecting our employees to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

13 1 hold us accountable as Senior Management Team, to these 2 standards.

3 We expect them to go to us if we fail; we expect 4 them to go to Bill and his oversite group, to go to my 5 boss; and if necessary, go to the regulator. We have set 6 down and we rebaseline the standards and were meeting with 7 our employees every day now, large groups. Posted the 8 standards on the wall. This is what we need to be about as 9 a senior team when we start the plant back up.

10 Thats committing ourselves to the FENOC mission, 11 vision and values. Were going to live those every day.

12 Were going to demonstrate our commitment to 13 safety. Demonstrate our leadership courage by making hard 14 decisions when we have to, to either shut the plant down, 15 reduce power or go fix problems.

16 We will recognize the value of our asset of our 17 people. And, we dropped some of our training programs to 18 develop managers at this site over the years, and as a 19 reflection of that, what you see us doing is bringing 20 managers in from the outside. That tells you something is 21 broken.

22 We pledge to uphold the leadership and action 23 principles. Thats a group of principles thats also on 24 the wall; how were supposed to work with our employees.

25 And then well earn the right to lead this site through our MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

14 1 behaviors. Those are the basic standards weve asked our 2 employees to hold us to.

3 Several months ago, when we first set out on this 4 mission of returning the plant to service, we developed a 5 plan called the Restart Action Plan; consisting of seven 6 Building Blocks, if you will.

7 The first is recover the head. We made a lot of 8 decisions, a lot of technical decisions of repair or 9 replace. We decided to take a hard step and ensure our 10 standards right then, and go rather than repair the head, 11 go replace the head. That was hard decision, but it set us 12 the right standards. And, it was not the cheapest 13 decision.

14 We, we built this plan, if you would, not for a 15 short-term action, but sort of like a 350 process, that 16 were into now. The 350 process does not change or go away 17 after we start the plant up.

18 To make the changes that we need to make, we have to 19 have sustained performance. Weve got to build products 20 that ensure sustained performance.

21 So, weve created two Building Blocks; one, the 22 Program Compliance Plan and the System Health Plan. Those 23 two plans have us do, have us perform systematic 24 evaluations of our programs on a routine basis, and 25 systematic walkdowns of our systems.

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

15 1 Those programs dont go away after restart. They 2 need to be ingrained in our culture every day. And if they 3 had been in place here, we probably would not be sitting 4 here today.

5 The Containment Health Plan. We started off, and 6 that plan has changed somewhat, with a plan to just address 7 the boric acid, but as we looked at the containment a 8 little harder, we expanded -- another example of setting 9 standards, we decided to expand that plan into a 10 Containment Health Plan.

11 Last night, we talked about a lot of upgrades.

12 Millions of dollars of upgrades that were spending on this 13 plant today to improve the material condition and quality 14 of the asset. And thats through the Containment Health 15 Plan.

16 Were installing new, were improving the quality of 17 our containment sump. Were improving the quality of a pit 18 called the decay heat pit. Its been a long term, nagging 19 maintenance issue at this plant. And were also installing 20 a permanent cavity reactor seal around our reactor vessel.

21 If that had been installed, more honestly the questions 22 weve been asking about these technical evaluations about 23 Boron thats running down the side of the vessel, it 24 wouldnt be there. It wouldnt be there.

25 And thats a several million dollar commitment that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

16 1 weve made to ensure that were setting the right standards 2 of the material condition, the asset of the plant.

3 The next building block would be the Restart Test 4 Plan. As we start up and return the plant to service, 5 were going to find problems. I mean, this is not -- when 6 you have equipment, you have problems. When you have 7 people, you have problems. Its how we solve those 8 problems in our decision-making to support them.

9 So, as we start this plant up, weve got to have not 10 only a good start up integrated plan that we discussed last 11 night, but compensatory measures to stop and address our 12 problems as we find them and fix them. And necessary to 13 come back down to the startup; make sure our systems and 14 materials and the people and procedures are working 15 properly.

16 And then finally is the Management and Human 17 Performance Plan. That plan was designed not to be just 18 the root cause that we gave to the NRC of this event. If 19 you go to look, we gained a lot of knowledge, if you will, 20 just by all the Building Blocks and all the system 21 walkdowns and program reviews that were done. So, there is 22 additional information that comes out of that.

23 So, we had the root cause that we presented to the 24 NRC, we had the plan itself that weve been finding and 25 fixing problems with. And then we had the oversight. And MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

17 1 Bill Pearce today will talk about the oversight process.

2 There is two organizations here; our quality 3 organization and what we call CNRB, which is our Company 4 Nuclear Review Board. And thats a safety review board 5 that failed us. And we need to understand how that failed 6 us, how we can improve it in the future, why we didnt find 7 the Boron on the head with those reviews also.

8 So, weve studied all that, weve done root causes 9 here on those areas too, and what weve done then is weve 10 put together a plan that well talk about today, Dave 11 Eshelman will talk about, thats called the 12 Management/Human Performance Excellence Plan.

13 It would be very easy for us each one of us to take 14 our root causes, run out and do things, but that would 15 probably not be constructive. We have to have a consistent 16 plan that were addressing specific issues and have the 17 building blocks to address those issues, a tool bag, if you 18 will, for each and every issue.

19 So, today, weve actually broken that area down I 20 think into five areas, and well discuss those areas today, 21 and the actions. Were talking about people. So, you 22 know, its hard to measure people. So, well be talking 23 about the actions that were taking, like our standards and 24 our values and goals, and departmental meetings and 25 everything that were going to do to improve the safety MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

18 1 culture of the plant, to address the root cause issues, all 2 the reports and improve the oversight programs and make 3 sure that were not only ready for restart; for the long 4 term, we put a culture, people in place and training 5 programs into place, that ensure sustained performance for 6 the long term.

7 With that, Ill turn it over to Steve Loehlein.

8 Hell discuss the root cause somewhat. Thank you.

9 MR. LOEHLEIN: Thank you, Lew.

10 Ill see how this microphone -- maybe its better if I put 11 it on the left. Maybe it doesnt work that way. I think 12 we have it taped down.

13 What we want to do here is just briefly provide some 14 context as to how the root cause investigations developed 15 into supplying information to the Management and Human 16 Performance Improvement Plan that Dave will be talking 17 about.

18 So, the first slide that I have here is a flow chart 19 on the process that developed over time. And as you look 20 at this, well be starting in the upper left hand corner.

21 Clearly, when the damage to the head was first found 22 in early March, the first permanent question was, how did 23 this happen from a technical prospective, because potential 24 implications to other operating plants was a big issue 25 right away to have something new or important to be MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

19 1 concerned about at the other plants in the country.

2 So, from that original root cause investigation that 3 was done and issued in April, there were two things that 4 came out of that root cause that clearly were open question 5 areas. One was the management was being called management 6 and human performance aspects. The initial root cause 7 issue in April really pointed at several key areas of 8 management issues, if you want to term them that. One was 9 questions about management involvement, particularly in the 10 field; issues surrounding technical standards; oversight of 11 the plant activities, and they also pointed at programming 12 implementation problems with the ISI, Boric Acid Programs.

13 Also, the technical root cause, which is how we 14 termed that report for clarity now, also identified five 15 particular condition reports that represented opportunities 16 for the plant to have recognized conditions that properly 17 resolved that the root cause team felt would have allowed 18 the identification of the damage to the head at an earlier 19 time.

20 What happened next as we move across there, is 21 quality assessment at that time assigned a team to 22 investigate the particular five condition reports that were 23 identified, I think on page 46 of the Root Cause Report; 24 and they went off and did a detailed investigation, 25 including additional interviews and so forth.

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

20 1 They came out with some conclusions along with some, 2 they also added some investigative work they had done on 3 pressurized spray valve that happened in 1988 and 1989; 4 and they concluded that there were issues in terms of lack 5 of involvement by operations in helping to prevent the 6 event, and a lack of effectiveness of the Quality 7 Assessment Organization.

8 So, while that was going on, senior management was 9 also seeking input on the management issues side from 10 industry executives, from IMPO, and a number of experts; 11 and what they got was a lot of input, both from the 12 technical root cause and from these experts, at issues in 13 many attributes, is how I termed them. These are the 14 things like ownership, accountability, attention to 15 detail. The kinds of phrases you hear describing how good 16 operating plants, the kind of attributes they have. That 17 all went into the Management/Human Performance Plan at the 18 time.

19 It was at that time that it became clear to senior 20 management at the site that a rigorous root cause 21 investigation of management and human performance was in 22 order. Thats when Lew convened a separate Root Cause 23 Team, and the specific goal of that team was to -- make 24 sure I read this here, so I dont get any words missing.

25 The goal was really to understand why over a period MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

21 1 of years the organization failed to identify the 2 degradation of RPV head. That was the mission of the 3 Nontechnical Root Cause Group.

4 And the NRC mentioned earlier what root causes we 5 determined out of that investigation. They appear on the 6 next slide.

7 The less than adequate nuclear safety focus, which 8 was mentioned as the production focus with an approach to 9 minimal compliance of meeting standards. That was the 10 overarching concern or reason that we found for what 11 happened at the plant.

12 The breakdown of these other root causes, the less 13 than adequate implementation of the Corrective Action 14 Program; there were five sub areas. What we did when we 15 investigated that, we broke the process down into its key 16 elements, because it has natural steps in identification, 17 prioritization and resolution. Then you go through the 18 steps of doing a cause analysis and so forth.

19 So, the subheadings under there are, that the plant 20 was addressing symptoms rather than causes. The 21 categorization of the conditions tend to be low, which 22 meant the process was being handled at lower levels of 23 management by and large, and was not required to have rigor 24 in the analysis. This resulted in relatively weak cause 25 determinations, and then that of course would allow for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

22 1 inadequate corrective actions.

2 The inadequate training is identified there, is 3 particularly related to equipment trending weaknesses. The 4 process doesnt really do a good job at all of evaluating 5 equipment trending issues.

6 The other two that were mentioned earlier were 7 failure to integrate and apply key industry information.

8 Again, for clarity what that refers to, is the 9 organization, individuals, and so forth, had the 10 information necessary to have handled this situation 11 correctly; however, it was not properly integrated into the 12 programs and processes, so that when the time came to use 13 that information correctly, it wasnt, it didnt happen.

14 And finally then, the noncompliance with the Boric 15 Acid Corrosion Control Procedure and Inservice Inspection 16 Programs. This is, the actual key thing there, is the 17 processes required for removal of the boric acid from the 18 head in order to, to be certain of what the source of the 19 boric acid was and that step was never completely 20 successful because Boron was allowed to be left on the top 21 of the head where it was so difficult to get off.

22 One other point of clarity for, just for root 23 cause. As we did the nontechnical root cause, and I 24 mentioned early that the Quality Assessment Group had found 25 issues with QA effectiveness and lack of operation MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

23 1 involvement. There were three areas in the nontechnical 2 root cause that we were able to obtain information that 3 allow us to make observations within the root cause report; 4 that was the Company Nuclear Review Board, the operations 5 lack of involvement and the quality assessment. Each of 6 those, we did not have the information in our report to 7 draw firm root cause conclusions.

8 How each of those was handled is, Bill Pearce early 9 on, we talked about it and we decided that the best way to 10 handle the Quality Assessment portion was to do a separate 11 independent root cause investigation and they have issued 12 their own report.

13 The quality, or the Company Nuclear Review Board, 14 Bill Pearce had a separate review done and we have been 15 discussing preliminarily results with Geoff Wrights team 16 last week. I dont know if that was actually issued yet; 17 is it?

18 MR. PEARCE: No, its not.

19 MR. LOEHLEIN: And the third one 20 was in the operations area; and in that case also, 21 Operations Management and we agree in Root Cause Team that 22 they would conduct their own separate root cause 23 investigation into their lack of presence in helping to 24 resolve or being involved in preventing the damage to the 25 head.

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

24 1 So, all those things in terms of root cause 2 basically feed into the Management and Human Performance 3 Improvement Plan.

4 The only slide we have left is a photo of the team.

5 I dont think we need to -- I think weve seen this 6 before.

7 MR. GROBE: Steve, before you 8 go on. Lew and other managers have indicated -- can you 9 folks hear me? Is that better?

10 Lew and other senior managers at the site have 11 indicated that supervisors and managers werent getting out 12 into the field to observe actual conditions and observe 13 work in progress, to have confidence that things were going 14 correctly and have direct observation of activities.

15 So, the only opportunity that the folks like 16 Corrective Action Review Board and the management had to 17 understand the outcomes of activities in the plant were the 18 normal review of records. And, in the case of the 19 Corrective Action Program and work orders associated with 20 the head, the cleaning of the boric acid, the inspection of 21 the head, many of those records contained inaccurate 22 information, indicating that boric acid had been removed, 23 the head had been completely inspected.

24 What role did the fact that there was inaccurate 25 information documented by your staff and internal records MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

25 1 play in decision-making processes and awareness of the 2 management team at Davis-Besse? What role did the 3 inaccurate records have and contribution to the root cause?

4 MR. LOEHLEIN: Well, the records 5 themselves -- Im trying to make sure I understand the 6 question correctly. I think what youre saying is right, 7 Mr. Grobe. These Corrective Action Review Boards and so 8 forth, yes, they would see these things and even the 9 Company Nuclear Review Board got some review opportunities 10 on some of the issues, but they were quite after the fact.

11 They werent really in process. They werent valuable at 12 all in terms of any process decision-making it appears.

13 The Root Cause Team basically found that as well.

14 What we really found by tracking the condition 15 reports, the progress of the condition reports, involved in 16 all these events was that they, being at low level 17 categories and being at, what I would call, really 18 symptom-based cause analysis, meant that they, they just 19 progressed through the system without any management 20 cognizance of any level to where you would expect to see 21 collective significance questioned.

22 So, as far as in process goes, that was really the 23 issue. Not just management involved in the field, the 24 other problem that happened was that because of the low 25 categorization and the way that the process handles it, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

26 1 there was a tendency for these things to get fewer 2 opportunities for management to have in-process review.

3 There were a lot of these things were handled at a 4 supervisor level only; and, so that, in terms of in 5 process, that really was the problem.

6 The other problem for the review boards is that many 7 of the indicators were set up to look at things based on 8 what was coded as significant, high level significance, 9 which meant that even the review boards only saw a few of 10 the issues, because very few of them were coded at the 11 level that they would have seen. So, they had few 12 opportunities as well as a review board to have certainly 13 very few to ascertain any kind of collective significance 14 in those venues.

15 MR. PEARCE: However, the 16 issues were used to develop the root cause, right?

17 MR. LOEHLEIN: Oh, yeah.

18 MR. GROBE: During the first 19 response to the agency after this was identified in early 20 March, was to charter a special inspection, we call the 21 Augmented Inspection Team. That was a fact-finding 22 inspection.

23 And, during the course of that inspection, the 24 inspectors spoke with operators. For example, through the 25 years 2000 and 2001, there was a concern about the level of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

27 1 unidentified leakage, and operators were touring 2 containment and trying to identify where this leakage was 3 coming from.

4 And, in speaking with the operators, the team 5 identified that, that they had no concern about the head, 6 because they had spoken with system engineers that were 7 involved in the head inspections, and reviewed the work 8 orders and corrective action documents, and they were told 9 and read the records, that the head was cleaned, inspected 10 and there was no leakage.

11 So, how can that not be a significant contributor to 12 the root cause; the fact that your records, your internal 13 records were inaccurate. I understand your comments 14 regarding in-process activities, but after the fact reviews 15 were impacted by that.

16 MR. LOEHLEIN: I think the answer 17 to that really is, the standards had gotten to the point 18 where Boron was left on the head. In other words, cleaning 19 the head, meant to many people that it was cleaned as best 20 it could be done. That was really the standard. And, at 21 each outage, the boric acid had been left on the head.

22 Now, there seems to be at 12 RFO, which is the 2000 23 time frame. This is when the plant made a significant 24 attempt to clean the head as best it could. There was 25 about one I think 1800 milligram, expended 280 staff hours MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

28 1 involved in cleaning.

2 And that was declared a success in terms of 3 cleaning, but even though that was so declared by many 4 people that were involved, the standard was such that that 5 boric acid left at the very center and top of the head 6 didnt come up in any of the, in any of the things we can 7 see as; oh, we cleaned it except for. That was never 8 stated. It was so much better than had ever been done 9 before, that was the standard of, yeah, its clean.

10 Thats what we were able to determine with the folks 11 that we talked to and so forth. I dont have a good 12 explanation for why that standard would exist, other than 13 the standards had become low and thats clearly in the root 14 cause.

15 Its not just in the area of the head. What we 16 found is in explaining the operations reviews, operations 17 reviews of the condition reports as they came through as 18 related to these boric acid issues tended to not recognize 19 their potential significance, even on the initiation and, 20 as well. So, there was a question of those standards there 21 of not being what we would want them to be.

22 MR. MYERS: If you go, go 23 look, you know, the B & W plants, there is flanges up on 24 top of control rod drives above the head. And, when we 25 first built the plants, there was some, the gasket type had MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

29 1 some minor leakage over an operator site. Were talking 2 about little drops over time. But those drops through a 3 cycle would build up. And, and we didnt take what I think 4 was aggressive action to go find and fix those leaks.

5 What that did was left a standard in place that 6 having Boron on the head was acceptable, as long as it was 7 dry, and it was coming from, it was coming from the 8 flanges. So, even after we fixed the flanges over the 9 years, and we went to a new type gasket, and very few 10 flange leaks, we were still attributing the Boron on the 11 head to the flanges that were no longer leaking.

12 Its like youre going down this path and thats the 13 solution. It may have been the solution years ago, but now 14 after you fix these leaks, its not the case anymore, but 15 were still attributing that Boron to the flange leakage.

16 It became the standard to have Boron on the head.

17 MR. LOEHLEIN: I might clarify in 18 summary; in one of the particular containment entries that 19 was made in more recent times between the 12th refueling 20 and 13th refueling, there was some elevated contamination 21 levels found near the exhaust area of the ventilation 22 system that comes off the head region. And there was an 23 erroneous conclusion made that if, if elevated, if the 24 contamination levels were elevated there, that was proof 25 that there might be a flange leaking or it would be a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

30 1 flange leaking, because nozzle leakage would not result in 2 contamination at that location, because the thing that was 3 erroneous about it was that the air being drawn across the 4 head would not come through that pathway.

5 And that turned out to not be true. Thats not 6 correct. Thats not a correct conclusion. But it was one 7 that the people involved in that particular entry and the 8 follow-up discussions, we thought that was the conclusion 9 they had, that they concluded they must have a flange 10 leaking and would have to fix it coming on the 13th 11 refueling outage.

12 MR. PEARCE: Did we answer your 13 question, Jack? Im not sure if we got to your question.

14 MR. GROBE: Not yet. For 15 example, at the conclusion of the 96 outage; and, through 16 the conclusion of the 2000 outage, engineers that 17 documented that the head was cleaned, penetrations were 18 inspected, and there was no leakage, yet there was 19 substantial amounts of boric acid left on the head.

20 Its not physically possible to conclude that there 21 is not leakage from the penetrations if there is boric acid 22 surrounding the penetration. How could that documentation 23 that the head was inspected and there is no leakage, how 24 could that have not influenced the organization in its 25 conclusions going forward?

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

31 1 MR. PEARCE: I think I can 2 answer your question; is that the Corrective Action 3 Program, although there was some information that was 4 disinformation, misinformation, however you would like to 5 categorize it, there was other information that should have 6 been adequate for us to understand what was going on.

7 There was condition reports written on the fact that 8 there was boric acid on the containment coolers. You know 9 all the ones as well as I, that there was iron in the 10 filters for the radiation monitors; those type of things.

11 There was other fairly obvious information that we should 12 have been able, if we had correctly used the Corrective 13 Action Program to come to that conclusion.

14 And thats the real linkage and the root cause in my 15 mind, is that there was some misinformation, but there was 16 plenty of other evidence, had we used the Corrective Action 17 Program properly, to have lead us to the right conclusion.

18 And the second root cause is what really I think gets at 19 the issue that youre asking there.

20 MR. GROBE: Okay. Bill, let 21 me ask; you werent in this position at the time, but the 22 quality organization after the 2000 outage, did an audit of 23 the effectiveness of the engineering organization during 24 the outage. And in that audit report, there is glowing 25 conclusions regarding the high level of quality of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

32 1 engineering organization and a laudatory, very laudatory 2 comments about the efforts to clean and inspect the head; 3 yet there was substantial boric acid left on the head and 4 the inspections could not have been effective.

5 How did that come to be? What were they depending 6 upon to make those conclusions?

7 MR. PEARCE: Its as you imply, 8 Jack, it was the evidence of time spent, of effort 9 expended, and the thought that this is the best its ever 10 been. And that was the, and the conclusion, as you stated 11 earlier, that there was some evidence based on what was 12 written in the reports, if you just looked at the written 13 information, that the head was clean.

14 So, the Quality Assurance Organization concluded 15 that this was a great effort that had been made. Finally, 16 we had gone to enough effort to get the head clean. They 17 had not gone and looked at the physical plant to come to an 18 independent conclusion, but rather took the information 19 they were given that the head was clean, and came to the 20 conclusion that you described there.

21 So, misinformation did lead them to come to the 22 wrong conclusion; however, as I said, there was plenty of 23 other evidence and physical evidence, if we had just gone 24 and looked at it. And thats some of the symptomatic 25 issues that Lew described about the need for management MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

33 1 folks, for quality assurance folks, for all of us to be out 2 in the plant, coming to our own conclusions and not 3 trusting only what we hear second or third hand or even 4 firsthand information back.

5 MR. MYERS: We have a 6 document that we use to troubleshoot the problem-solving 7 from a management standpoint. At Beaver Valley and at 8 Perry, we recently turned that into a nuclear operating 9 procedure; and just applied the principles as a management 10 team, thats in that document, you would have concluded 11 that the points didnt add up. The points just dont add 12 up.

13 And the first thing you sit down and do is, a 14 systematic approach, what all do we know. With all the 15 facts that you know now; leakage rate again higher and 16 never coming back to normal, with the containment air 17 coolers, Im going to say CACs, containment air coolers 18 having to be cleaned as often as they were. For the past 19 twenty years, they werent being cleaned like this. The 20 radiation monitors clogging up. Whats changed? What do 21 you know? Even with the misleading information, you would 22 have still came up with, with something is not right.

23 MR. GROBE: You could have, 24 but Geoffs team is going to take a look at the root cause 25 and I think thats one of the areas were going to be MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

34 1 focusing on, whether or not this misinformation, plant 2 records was a contributor to decisions that were made.

3 Steve, you brought up the containment spray valve 4 issue in the 99 time frame.

5 MR. LOEHLEIN: Right.

6 MR. GROBE: In that situation, 7 there was boric acid corrosion on the upper components of 8 that valve because of leakage. And, the NRC took what we 9 call Escalated Enforcement Action, civil penalty to the 10 company, and you folks took fairly extensive corrective 11 actions, including a broad training program on what boric 12 acid corrosion looks like and what are the indicators of 13 corrosion.

14 Its my understanding that the engineers that were 15 involved in examining the head attended that training. How 16 did it come to be that the clear indicators of boric acid 17 corrosion on the head following that training in an outage, 18 within a year following that training, was not identified 19 as corrosion?

20 MR. LOEHLEIN: Clearly we 21 concluded -- heres really on kind of an upper level we 22 concluded. We would have expected from an event like that, 23 that the corrective actions taken would have been 24 effective, exactly as you described it. Come the year 25 2000, and this boric acid coming off the head, people MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

35 1 involved would have recognized it. And thats why we were 2 very concerned when we did the root cause, to understand, 3 well, why wasnt that effective. Because it was handled at 4 a level of root cause that you normally would.

5 So, we had issues with knowledge and provided some 6 training. What we found is that this overarching root 7 cause, which is this, you might -- we talk about the idea 8 that issues are not problems, theyre perceived to not be 9 problems until proven so; that there is an alternate, 10 alternate explanation for an issue that is more favorable, 11 that is a tendency to accept that.

12 So, couple that tendency along with history on the 13 head, which it had rust-colored boric acid years before on 14 the head that really was generated by the flange leakage 15 that had run along the structural steel of the, you know, 16 of the insulation. And so they had some rust-colored boric 17 acid in their history before. Couple that historical 18 issue, the continuation of flange leakage, the willingness, 19 or you might say tendency to blame all boric acid on the 20 head on these flanges.

21 The old knowledge base of, that must be old boric 22 acid, seemed to creep right back into the consciousness of 23 the people making the decisions, and the training did not 24 take. Because what really didnt happen in 98 and 99, 25 was there was not a recognition that the way problems are MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

36 1 approached for resolution was really what went wrong in 98 2 and 99 on the pressurizer spray valve, was not recognized 3 as the underlying root cause, which at that time was 4 approached at somewhat higher level.

5 We have issue with knowledge. We have issues with 6 specific areas, and a significant number of corrective 7 actions were entered at that level. And thats why we are 8 really careful in this root cause to ask, well, why wasnt 9 that effective when it should have been.

10 MR. GROBE: Other questions 11 before we go on?

12 MR. PEARCE: I would like to 13 make one point before we go on, about the root cause, and 14 how we went about doing it.

15 We had a lot of discussion about how to do the root 16 cause. I think its important for the audience to hear our 17 thought process in that regard.

18 What we intended to do, to do the root cause, was to 19 use a known methodology, an accepted methodology, not only 20 in our industry, but used across a lot of different types 21 of investigations of events. And, we brought in what we 22 perceived to be the, the best system approach that there is 23 available to us. And, with that, we brought not only the 24 team that we assigned, which was a team purposely lead by 25 someone outside of Davis-Besse, and not because any problem MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

37 1 with the people at Davis-Besse, but so that they could have 2 a more objective look at it.

3 We assembled a team of people that, that we thought 4 would be objective and look at the issues that were there, 5 using a system that gets known results through the 6 industry, and we even brought the two people that invented 7 the system in to make sure that we had used it properly.

8 We were very, very careful to keep any management influence 9 out of it, because its important to us, for us to be able 10 to stand behind this root cause. And for, for the root 11 cause to be correct, and not to have some influence on it 12 that would lead it to being influenced by some, some 13 intention other than getting to exactly the root cause.

14 So, I think its important for all of you to 15 understand that we tried to use the very best system, to 16 bring the people that knew how to use the system the best, 17 to leave it alone from a management perspective, to let the 18 team work and get to the root cause.

19 And these are the conclusions that the team came to, 20 and I personally believe that they are, they are the right 21 conclusions, and that we can stand behind them without, 22 without thinking that theyve had some influence that they 23 should not have had.

24 MR. MYERS: Bill made two 25 points, and I think thats important too. You know, it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

38 1 takes management courage that you have to demonstrate, to 2 bring a team of independent people, industry experts in, 3 and really make them independent to tell you what youre 4 doing wrong.

5 I mean, thats difficult to do. Its difficult for 6 our corporate organization. Its difficult for FENOC 7 organizations. Its difficult for the management team to 8 do. But if youre going to really understand how you can 9 improve, thats what you have to do. You have to 10 demonstrate that management courage.

11 So, Bob Saunders sponsored this team and I guess Im 12 the owner. I mean, we really worked hard in bringing that 13 qualified team in and then leaving them alone without our 14 influence or any other management influence to show us what 15 we thought the root cause was, and the actions we could 16 take to improve the overall safety culture of our plant and 17 the decision-making.

18 Our excellence plan is going to share some of that 19 stuff with you, how we go forward. And, but you know, I 20 think any one on that team, Id tell the regulators or 21 anyone else to talk to the people on that team; they were 22 independent. Okay.

23 MR. GROBE: Christine?

24 MS. LIPA: The question that 25 I had, we talked earlier about the difficulties over the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

39 1 years in cleaning the head. Did your team look at the 2 basis for deferral of that modification that would have 3 installed the improved access ports to facilitate the 4 cleaning of the head and how that would fit into one of 5 these root causes?

6 MR. LOEHLEIN: Yes. We did look 7 into the modification deferral, but that really was found 8 in the early root cause and showed up as a contributing 9 cause of the first report.

10 And really, what we were able to gain in the way of 11 further understanding in the Management/Human Performance 12 area when we looked at that, was the evidence suggests what 13 happened in the early days when it was flange leakage, the 14 boric acid being loose, had a tendency to run down the 15 head, and was easier to clean off.

16 So, we had concluded that most likely, we were 17 having a fair amount of success getting it, the boric acid 18 from the flange leaks at that time. And that was part of 19 the reason why in the early 90s, people felt that they 20 didnt need the mod.

21 Soon thereafter, only about a year later, people 22 concluded again that maybe we do need the mod to get to the 23 center of the head. So, we werent able to get to the real 24 specifics, but clearly when the boric acid was running down 25 the head, it was kind of like, you know, small clumps that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

40 1 can come, can develop like that. And thats what would be 2 indicative of small leaks from above, just drips on the 3 head.

4 When that changed in the mid 90s, thats when the 5 deferral of the head became an important thing, and really 6 wasnt recognized how important that was to be able to get 7 better access. The standards changed in the late 90s, to 8 where leaving boric acid on the head was accepted.

9 And so, but there, Ill just say that thats really 10 what we learned from it, why wasnt the mod deferred. It 11 was always a consideration given us, what will be gained 12 from it, and it was looked at a standards perspective later 13 that it wasnt really necessary.

14 Then I think in the last days what we got was, going 15 to replace the head shortly anyway; maybe the mod isnt the 16 sensible thing to do. I think that was in forming the 13 17 mod, I think, was the thinking that it maybe wasnt going 18 to be a cost-effective thing to do because it had to be 19 replaced.

20 So, it has a history of coming up and being deferred 21 again. I dont remember all the details, but they do 22 appear better in the report that was issued in April, with 23 revision of that information at least, and it gives a 24 history of that, I just dont completely recall now all of 25 it.

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

41 1 MS. LIPA: Okay, thank you.

2 MR. MYERS: As we go forward 3 right now, you know, I was saying that some of the major 4 mods that were putting in containment is sort of unique 5 right now. I was talking this morning that the mods and 6 things we are going to do here, we have like 109 7 modifications that were addressing right now. So, you 8 know, thats, thats the standards that we need to get mods 9 done.

10 You know, if we would just spend a little more time 11 trying to implement that mod than we did trying to figure 12 out why we didnt need it, wed probably be better off 13 today, probably be more cost effective too.

14 MR. PEARCE: A little bit.

15 MR. MYERS: Are you ready to 16 move on to talk about the next part of the plan?

17 MR. GROBE: Yep.

18 MR. ESHELMAN: Go on to the next 19 slide. It gives another visual of the plant.

20 Steve talked about the Root Causes, how that was 21 developed, some of the inputs to it from the Technical Root 22 Cause, identifying several areas of further review, getting 23 into the Business Plan, the Building Block Plan, Excellence 24 Plan, the Nontechnical or Management Performance Root Cause 25 and how that factored into the Management/Human Performance MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

42 1 Plan, as well as he mentioned some of the other information 2 that came in.

3 And this shows two things. First of all, it shows 4 some of that other information; the input into the 5 Management/Human Performance Improvement Plan.

6 At the top left and top right is the Root Causes 7 that Steve talked about. The Technical Root cause on the 8 left and the Management Failure to Detect Degradation on 9 the right. We already talked about those and how they fit 10 into that. But as he also mentioned, there was a spin-off 11 condition report, thats Root Cause for Quality Assessment 12 Effectiveness. Again, that spun off from this root cause.

13 It wasnt contained in the technical or nontechnical root 14 cause. That was a separate item. And what were doing is 15 feeding that back into the Management/Human Performance 16 Improvement Plan.

17 On the right, there is other Management/Human 18 Performance issues. There is other root causes. There is 19 other investigations going on right now that are 20 identifying some management issues. We talked about the 21 Company Nuclear Review Board. Bill Pearce has a look at 22 that. Hes developed a plan and there is some initiatives 23 we need to take from that.

24 As mentioned, the one on top is Operations Role in 25 Safety Focus. From the quality assessment review of those MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

43 1 five condition reports, the leadership of operations and 2 their role is questioned. That drove a condition report, 3 the root cause, thats being factored into it.

4 Some of the other areas were looking at; the 5 modification process. Were looking at the implementation 6 of that process. Dave Gudger has a couple condition 7 reports, couple root causes on the root cause 8 implementation and program, and the implementation is going 9 to find some other Management/Human Performance issues.

10 So, what were doing is essentially using various 11 sources, not just the initial technical root cause and 12 nontechnical. Were using all these sources to make sure 13 we have our arms around the proper actions. Each one of 14 these sources are going to be driving actions, creating 15 actions to fix the problems identified.

16 The second thing this shows, is that were also 17 looking at the root causes. Weve identified, as Steve 18 said, four primary root causes from the Management/Human 19 Performance Root Cause. Were also looking at each of the 20 other condition reports, looking at those root causes and 21 looking to see whether there is similarities or differences 22 in there, because it is important, as Steve mentioned, he 23 looks specifically at that head degradation, the effect of 24 management on the head degradation, but there is other 25 issues out there that are also leading into management MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

44 1 issues. We want to make sure we have our arms around the 2 causes, so we have a good aggregate look at causes and 3 corrective actions.

4 So, that also is going on. The information is 5 coming in, various root causes are still in progress, but 6 when it gets issued or when it gets communicated, we start 7 looking at those causes to see if we can find some 8 similarities; and the good news is we are. That, I think, 9 leads credence to the Root Cause Report, Nontechnical Root 10 Cause Report, because we are finding the same issues in the 11 other areas.

12 From this Management/Human Performance Plan, we had, 13 as I mentioned, a whole lot of actions, activities, 14 causes. And we took a look at it and decided to put it in 15 manageable bins. So, these are the five areas we decided 16 we are going to pursue and what makes up, I guess, the 17 foundation of the improvement plan.

18 The first is Nuclear Safety Culture. We talked 19 about the primary root cause was the lack of nuclear safety 20 focus. Well, thats one item in there were going after, 21 as well as the safety conscious work environment. Bill 22 Pearce will you be talking on that later.

23 To the right, Management Personal Development. What 24 were looking here, we have the right leaders, the right 25 behaviors, good evaluation tools, monitoring of management MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

45 1 out in the field, understanding, looking, seeing whats 2 going on; and then feedback and coaching; something very 3 vital.

4 Standards and Decision-making. Were looking at the 5 leadership standards, as Lew mentioned. Senior Management 6 Team came up with standards, something the whole site can 7 hold the leadership accountable to. So thats a start. It 8 starts at the top and it works its way down.

9 The technical standards; our rigor, our questioning 10 attitudes, our decision-making.

11 Departmental standards. How operations is going to 12 behalf, how maintenance is going to behave at departmental 13 level.

14 Plant and equipment standards. This is important.

15 Were doing a lot of activities right now that really dont 16 need to be done. Were showing, demonstrating visually, 17 which is the easiest way to show improvements in the asset 18 of the plant. Were doing painting. Were doing 19 cleaning. Conditions that were for years accepted and 20 tolerated, were fixing them; and were showing our people 21 that we mean business, and there is a demonstration of our 22 increasing standards.

23 Then we talk about the safety focus and 24 decision-making. That part of the decision-making process; 25 how we go where we are. Making sure we use the right MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

46 1 rigor, understand all the information and move in an 2 engineering logical fashion through that.

3 Programs/Corrective Action/Procedure Compliance.

4 Corrective Action is a program that was called out in Root 5 Cause fairly significantly, so we let that be a stand 6 alone. So, were talking about program improvements 7 overall on all our programs. Were doing various reviews, 8 another building block is taking care of that, the Program 9 Review Building Block.

10 Implementation Improvements, and thats important.

11 That fits into this plan. We could have great, great 12 program, great plan, but if its not implemented properly, 13 youre not going to get the good results out of it. So, we 14 need to identify the area that lead to poor implementation 15 of some of our programs.

16 The Corrective Action Process, Dave is doing a 17 pretty much top to bottom check on that and thats going to 18 be a significant undertaking to revise that.

19 And Procedure Adherence is the other area weve 20 identified. In a lot of cases the programs procedures we 21 had were determined to be adequate. Not necessary the 22 best, but adequate. Such that they were implemented 23 properly, followed properly, we would not have had the 24 results we had. So, procedure adherence is another key; 25 not just having a procedure in hand, going step-by-step, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

47 1 but for administrative program procedures, making sure 2 there is a complete understanding and follow through for 3 those actions.

4 Then finally the Oversights and Assessments. And 5 were talking from independent external oversight, for 6 instance, Company Nuclear Review Board. The FENOC level 7 oversight, Bill Pearces organization, internal oversight; 8 this is Steves organization now; quality assessment, 9 management oversight. Now that all kind of feeds into the 10 management personnel development, we are watching, 11 monitoring, understanding whats going on; not just 12 reading, but going out and looking.

13 Then, Review Board Oversight, examples would be 14 Engineering Assessment Board, working on the standards and 15 some of the company corrective action review boards to make 16 sure there is proper oversight of the processes, how 17 theyre being implemented.

18 So, that in a nutshell is pretty much the plan.

19 Next slide, please.

20 MR. MYERS: Lets stop here 21 for a second.

22 From a public standpoint, and I think its important 23 that what we do, is we start out with the root causes and 24 then we built these tool boxes from all the various root 25 causes, and the corrective actions that were trying to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

48 1 take as a management team focused in these toolbox, right?

2 MR. ESHELMAN: Thats correct.

3 MR. MYERS: So, rather than 4 each group going off, maybe because operations did a root 5 cause, and theyre going out to take actions, that may be a 6 negative action to the whole. So, were trying to focus 7 everything through these toolboxes. And so, as we, as we 8 go forward in our implementation plan, of correct safety 9 culture or behaviors or standards, you know, its important 10 that we focus it through this process.

11 And you find that, for instance, our standards 12 should be aligned from a senior management team level and 13 their values, then below in the health physics area or the 14 operations area, should be verbal alignment throughout the 15 organization. So, well be looking for that.

16 Okay.

17 MR. ESHELMAN: Part of this 18 review is also to take a step back from this nuclear safety 19 culture, we have an owner for that. Hes looking at all 20 the causes, all the actions were taking; and his job is to 21 look at it and say, are we really getting what we want out 22 of it or are we just doing a whole bunch of individual 23 actions or really getting a benefit out of it. Thats part 24 of the review also, the aggregate look, to make sure were 25 resolving these issues.

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

49 1 As Lew mentioned earlier from the top, Senior 2 Management Standards were created. Do you want to talk any 3 more on that, Lew?

4 MR. MYERS: I mentioned those 5 standards earlier. These are the standards that will be.

6 If you look around this room, you know, we have a mission 7 vision, the basic leadership strategies that we have under 8 leadership action program for managers, how were supposed 9 to deal with people, and then management standards.

10 Our intention at this plant is to have these hanging 11 on every wall in our major meeting rooms, and in our major 12 buildings, so that we can look at them every day.

13 What we found was misalignment. What I personally 14 have found is some policies in the ways of doing business 15 in misalignment from the FENOC Organization to 16 Davis-Besse. When you have that misalignment, you have 17 confusion, because youre getting mixed messages.

18 What weve got to do is give a consistent message to 19 our employees. And its gets back to, for instance, is 20 Boron okay on the head. Its that simple. It became 21 culturally acceptable to have Boron on the head.

22 So, we can not be giving those mixed messages. Its 23 a group of behaviors thats a reflection of us as a 24 management team.

25 Okay. Go ahead.

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

50 1 MR. ESHELMAN: Next slide.

2 This plan really has a few objectives. First of 3 all, we have at lot of actions. Geoff, youll be looking 4 at the actions, as well as the second one is verification 5 of effectiveness; what are they doing, are they working for 6 us.

7 The plan is a living document. As we speak, there 8 is information coming in relative to human performance, 9 management issues that are going to be factored into it.

10 And essentially, well be having a leadership plan that 11 takes us well past startup.

12 Next slide.

13 For safety culture, each of these we have an 14 objective. And the safety culture, were talking nuclear, 15 radiological and personnel safety is always important to 16 us, but understanding it needs to take precedence over 17 other objectives. And from a safety conscious work 18 environment, make sure there is no fear of retaliation and 19 people will willingly bring up issues.

20 Some of the initiatives were taking. First of all, 21 FENOC Safety Policy. This again is starting at the top.

22 From the very top, here is the standards, heres the 23 expectations that well hold each other accountable for.

24 Safety Conscious Work Environment Improvement Plan; 25 Bill will be talking on that later.

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

51 1 New management in the FENOC level; Lew, Bill, Gary 2 Leidich, as far as their new positions in the FENOC 3 Organization, as well as the leadership team at 4 Davis-Besse. High standards have been brought in with that 5 new management team.

6 Training on Safety Focus. Thats going to continue 7 for a long time. In the sense we have training for 8 supervisors for our people, were going to make sure it 9 contains the right elements of the safety focus.

10 The People Team. What were looking at is when 11 issues come up, when people have issues, they can go to 12 the, to the People Team and provide the issues. So, they 13 will be anonymous, almost like an ombudsman, but a few more 14 people out there will help resolve the issues and get quick 15 action, so the people will recognize when issues are 16 raised, they will be listened to and they will get actions 17 from them.

18 And another issue came up just to make sure that the 19 Business Plan, FENOCs Business Plan, or Davis-Besses 20 Business Plan, that incentives are aligned with the plan to 21 make safety important. So we need to make sure that we 22 incentivize safety.

23 Next slide.

24 MR. GROBE: Dave, I know 25 that Ive peeked ahead at some of your slides and youre MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

52 1 going to go into some of this in detail. Are you going 2 into which of these initiatives are going to be complete 3 prior to restart, and how youre going to measure the 4 effectiveness of these initiatives?

5 MR. ESHELMAN: I can cover some 6 of that. The plan itself will list specifically whats 7 going to be complete before startup and we were going to go 8 into some of the indicators, but well spend as much time 9 as you want on that.

10 The safety policy, the management, the people team 11 and business plan, theyre some of the restart issues. The 12 safety focus training will continue. There is a lot of 13 initiatives that will start now and continue for many 14 years, if not forever.

15 MR. MYERS: For example, you 16 know, some of the key ingredients is, you know, we talked 17 about the program reviews, system reviews, you know.

18 Those, weve done a lot of those before we start the plant 19 up. Weve looked at all of our system phase one; about 20 five systems, Latent Issues Reviews. Weve got system 21 reviews laid out for the next couple years now, you know, 22 and well be doing a few a year. Same way with program 23 reviews.

24 From a corrective action standpoint, weve brought 25 some of the ways of doing business here with our Corrective MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

53 1 Action Review Board, been sponsored by our plant manager 2 and were grading those corrective actions as they come 3 in. Weve already been doing that at the plant.

4 Engineering Assessment Board. We have that up 5 here. And we have that at Beaver Valley, so were bringing 6 that over here.

7 If thats in the Building Blocks, but it becomes 8 part of the internalization of the organization for a long 9 time. Those are management structures that we think should 10 have been in place. Is that fair?

11 MR. ESHELMAN: Thats fair.

12 Next slide.

13 Heres some more areas that were also doing. Very 14 importantly is the Employee Communication Opportunities.

15 Whether its Lew, some of the other directors or in Restart 16 Overview Panel, essentially an independent panel; going 17 out, talking to the people, understanding the issues, 18 listening and then taking action. Thats really important, 19 it will help to spur more openness in the organization.

20 Case Study Training is a major contributor. This 21 will go through how we got where we are, the errors 22 involved, mistakes that were made. Then, thats going to 23 spur the discussion of the standards; what are our 24 standards, how are we going to behave in the future.

25 Thats going to be completed before startup, given to all MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

54 1 site employees, Davis-Besse employees.

2 MR. GROBE: Dave, could you 3 explain what 4Cs meeting are and what the ROP is?

4 MR. ESHELMAN: Okay. The ROP, 5 thats the Restart Overview Panel. Thats a panel made up 6 of essentially very highly experienced individuals, as well 7 as community leaders. Jere Witt, County Administrator is 8 on it, Lou Storz is on it, Chris Bakken; some people that 9 have involvement in plants, turning plants around. Buzz 10 Galbraith is the Chair of that panel. And their job is to 11 review all these Building Block activities and give us 12 feedback; if not assess, give us feedback, let us know if 13 were not going where we need to go. So, they are 14 essentially our critic.

15 MR. MYERS: Excuse me. They 16 are also, we sponsored that group with having employee 17 meetings. Theyre going to have to recommend restart 18 before we come to you all. Okay. So, first, we as the 19 management team have to have meetings to discuss, do we 20 believe were ready for restart. We go to the ROP, and 21 theyve got to make that recommendation. Then we will come 22 to you guys. You know, so weve asked them to start 23 meeting with our employees.

24 Jere is here today. Do you have anything you want 25 to add? I know Im putting you on the spot. Do you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

55 1 know.

2 MR. WITT: Yes. Thank you. As 3 part of the Restart Oversight Panel, we did meet with, I 4 think, somewhere in the neighborhood of a hundred employees 5 about a week and a half ago, and provided that feedback to 6 management. Have been even part of some meetings since 7 then with management and the employees, trying to make sure 8 that all of the concerns of the employees are addressed in 9 some manner, and that more importantly probably the 10 communications between management and employees is a 11 two-way street.

12 And I think, you know, that has started and it is 13 something that the Restart Oversight Panel will continue to 14 monitor, and be concerned with as we go down this path.

15 Its not completed yet, but I think we have a good start in 16 getting that done.

17 MR. GROBE: Could you also 18 explain what the four Cs means?

19 MR. ESHELMAN: Thats another 20 meeting, initially its facilitated by one of our 21 organizational development folks. Its groups of 22 employees, and the idea is to get all the issues on the 23 table, what are we doing, what arent we doing; what kind 24 of issues are out there; compliments.

25 MR. MYERS: Complaints, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

56 1 concerns and criticisms.

2 MR. ESHELMAN: Yeah, so. And, 3 from this, you get results; a lot of information, good 4 information. Since its lead by an organizational 5 development person and there is no leadership people or 6 management folks in there, you get good open feedback.

7 That is tabulated and then Lew takes action on that.

8 He goes back and addresses the team and talks about what 9 were doing, what were doing to address these issues, what 10 were doing to go forward.

11 MR. MYERS: So, from 12 objective evidence standpoint, you know, we keep records of 13 the meetings and each meeting and the actions weve taken; 14 and we would be able to provide those to you guys. And 15 then, for example, I was just giving feedback here to some 16 of the complaints that we had a few weeks ago and are now 17 compliments.

18 So, from a safety culture standpoint, you know, the 19 openness of our employees is very important. And this is 20 designed to strengthen that, will they bring an issue 21 forward, safety culture.

22 MR. ESHELMAN: So, besides the 23 openness of employees, we also make sure management is 24 doing our job; make sure were out in the field, make sure 25 were observing, make sure were doing great things, make MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

57 1 sure were reinforcing proper behaviors. So, we have an 2 observation scheduling, people will be scheduled for 3 certain activities. We have a monitoring program, for 4 making sure that people meet those expectations. So, 5 essentially, its going to make it into an indicator that 6 we can see, make sure that we know whose doing their job 7 and who is not.

8 Now, some of the measurements poles. The next 9 slide, please.

10 Measuring Safety Culture is difficult. You 11 mentioned behaviors. Some items, as far as Lew mentioned, 12 shutting the plant down. Lets shut down and fix 13 something. Some of the decisions, hard decisions that are 14 made; that demonstrates behaviors.

15 So, you can look at behaviors, but we also have some 16 self-identification of adverse action, of adverse 17 conditions. Are our people willing to write condition 18 reports rather than oversight organization or someone 19 else. That gives you a sense or you feel that people feel 20 free to identify conditions.

21 And when action is taken, that will promote, rather 22 than if no action is taken, it will stop. So, that would 23 be another indication for us.

24 Safety Conscious Work Environment. Well be doing 25 several assessments of that, measuring our improvement MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

58 1 throughout the years. And management observations, well 2 be looking at specific attributes, making sure were 3 complying with procedures, making sure we are exhibiting 4 the proper behaviors.

5 So, thats some of the areas that well be 6 monitoring, as well as self assessments for each group.

7 Well also have indicators to demonstrate the health of 8 whether its programs or groups or processes.

9 MR. MYERS: Let me talk a 10 moment about our Management Observation Program. Were 11 getting ready to install our Computerized Management 12 Observation Program at this station. And its our 13 intention between now and startup into the future to 14 schedule management observations every week of key jobs.

15 If we had scheduled a management observation at the 16 head containment, and if we had had, one of the things 17 were supposed to do is a good Prejob Agreement. And the 18 Prejob Agreement has some very good information. Its not 19 policies and procedures. Policies and procedures is 20 important. Its understanding though what youre supposed 21 to do, what youre supposed to see, and making sure that 22 you know the compensatory measures you need to take if you 23 dont get what you expect. Its all the right questions.

24 You know, I dont understand if you were going to do 25 a head inspection, how a prejob briefing, a good thorough MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

59 1 job briefing, you know, what is the desire outcome; what 2 are you trying to accomplish; what do you expect to see?

3 You know, it would probably raise this concern at the 4 management level. I just cant imagine them not having a 5 good prejob approval. So, thats going to be an important 6 part of that management observation of our process.

7 Go ahead, Christine.

8 MS. LIPA: I have a question 9 about the self-identification rate for condition reports.

10 You have a goal of 80 percent.

11 MR. ESHELMAN: We got feedback 12 from Restart Oversight Panel; were revisiting that.

13 MS. LIPA: Okay. Well, my 14 question is, youre in a unique situation now where youre 15 doing a lot of reviews and identifying a lot of issues and 16 they are all being counted as self-identifying, so that 17 could tend to skew that data and make it look like a higher 18 percentage and not a valid indicator of safety conscious 19 work environment.

20 MR. MYERS: We dont 21 believe the data is correct now, but over the next five or 22 six week period, as we get more into, out of discovery and 23 into getting physical work done, that I think thats going 24 to be a turning point, its going to be harder to reach 25 that goal.

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

60 1 My belief is having it skewed the way it is right 2 now is going to make it, were going to really have to try 3 hard to keep it there.

4 MR. PEARCE: Well, another 5 point is, youre going to have a lot of teams here thats 6 going to tend to skew it back the other way if it doesnt 7 go properly; right?

8 MS. LIPA: Thats right.

9 MR. PEARCE: We should be 10 seeing a balance there.

11 MR. GUDGER: Christine, we did 12 in fact recognize that data was skewed and I am taking a 13 look at it from a different point of view, making sure 14 were measuring things in a qualitative manner.

15 MS. LIPA: Thank you.

16 MR. MYERS: Okay. Next 17 slide.

18 MR. GROBE: Excuse me. The 19 self-identification PI can be a valuable performance 20 indicator, if its structured properly. And well make 21 sure that we have confidence that its structured 22 properly.

23 Lew, you mentioned management observations. You 24 talked in the context of work activities. Are they going 25 to be management observations of human performance as MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

61 1 well?

2 MR. MYERS: Thats one of 3 the, I think its another area in our observation program, 4 I think Christine youre pretty familiar with the 5 computerized data base that we use to track at Perry and 6 Beaver Valley. With the correct tools, correct behavior, 7 there is sections in there for good prejob briefings.

8 You know, what I did is, I went through that a 9 couple weeks ago; the Management Observation Program. I 10 picked the key parameters that I thought would be important 11 for us to measure going forward to make sure we seek the 12 performance in the fields that we expect.

13 I dont remember what those were right now, but I 14 went through that whole observation program. Were going 15 to be pulling performances out of those management 16 observations to look for those type issues, human 17 performance issues.

18 MR. GROBE: So, youll have a 19 performance indicator that comes out of management?

20 MR. MYERS: Absolutely.

21 MR. GROBE: Thats not 22 developed yet?

23 MR. MYERS: Yes, it is. I 24 mean, we have it already at our other plants, so its not 25 hard.

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

62 1 MR. GROBE: But its not in 2 place here right now?

3 MR. MYERS: No. We put, that 4 computer system, Computerized Management Observation System 5 will be in place at the end of this month.

6 MR. GROBE: That will be part 7 of the performance indicator package we get on a weekly 8 basis?

9 MR. MYERS: Right. It will 10 be something you can look at throughout your 350 process, 11 even after restart.

12 MR. GROBE: You talk about, 13 in the safety conscious work environment assessments area, 14 you talk about periodic assessments. What does periodic 15 mean? Is that annual?

16 MR. PEARCE: He havent decided 17 that yet, Jack. We know that were going to do some more.

18 Were trying to figure out what the right time of going 19 forward with that is. For us to understand, what the 20 training, what were going to do with training, Ill talk 21 about that later, some of the stuff were going to do. And 22 at what time we do another evaluation of where we are and 23 expect to see some change as a result of what weve done.

24 MR. MYERS: Its certainly 25 not annual, its more like monthly and stuff like that.

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

63 1 MR. GROBE: Are those 2 assessments going to be primarily interview basis?

3 MR. PEARCE: Theyre survey 4 basis is what they are. And Ill show you, later on Ill 5 show you the results of the survey that weve done so far.

6 MR. ESHELMAN: Any more questions 7 on the culture?

8 Next is Management Leadership. So, were talking 9 about experience, high safety standards and theyre 10 directly involved, some of the key issues that we already 11 mentioned.

12 Next slide.

13 First of all, New Management Team. Standards for 14 Management. So, we have the team, we understand the 15 standards, so now we can go implement.

16 Operations has the improvement of leadership plan.

17 There are supervisory evaluations, were using RHR 18 Consultants to help us with some of the evaluations in 19 personnel.

20 Leadership in Action Training and Foundations for 21 Leadership is our Supervisory Development Plan. If you 22 want to become a supervisor, you start off in the 23 Foundations for Leadership. Were going to make sure that 24 that training has the right focus, so were looking back at 25 the causes, looking at actions; and were going to make MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

64 1 sure that those training programs have the right elements 2 in them to get the right safety focus and train our folks 3 the way they should be trained.

4 Ownership for Excellence is our performance 5 monitor. Thats the key. You set standards. You set 6 expectations. You monitor to make sure the standards and 7 expectations are the same. Then, this is the feedback 8 part. If people are not meeting expectations, you need to 9 tell them; otherwise theyll continue not to meet 10 expectations. Thats what the Ownership for Excellence 11 Program is about.

12 As we mentioned before, Management Monitoring also 13 gets us involved, directly involved with plant activities.

14 MR. GROBE: Dave, could you 15 talk a little bit more about supervisory evaluations, what 16 that means?

17 MR. ESHELMAN: Working with Human 18 Resources in corporate, Lynn Cavalier as a matter of fact, 19 were developing, were actually modifying competency; 20 what we expect our people to be able to do, our 21 supervisors, our managers, even individual contributors.

22 What are the competencies we expect from them.

23 The evaluations are done to monitor against those 24 competencies. Using the behavioral base, or experience 25 base interview to understand how each individual fits or MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

65 1 doesnt fit those areas. So, we can identify areas for 2 improvement; make sure there is a clear alignment between 3 what we expect, the competence we put out and behaviors 4 exhibited. Similar to what was used at Byron Station; they 5 also used RHR.

6 MR. GROBE: Is there going to 7 be baseline evaluation done and then a continuing 8 evaluation in your Management Oversight Monitoring Process?

9 MR. ESHELMAN: Right, we do have 10 baseline. Its going to be starting next week. And from 11 that, well have further evaluations. Use that as a tool 12 to make sure were maintaining the proper focus and our 13 people are not losing it. We havent decided yet on the 14 frequency of that, but that is going to be one of the long 15 goal plans.

16 MR. GROBE: When will the 17 baseline be done?

18 MR. MYERS: Before restart.

19 MR. ESHELMAN: Before restart for 20 the key groups of supervisors identified.

21 MR. MENDIOLA: Quick question.

22 Your leadership in Action Training, and I guess your 23 Foundation for Leadership Training; how is that, or who is 24 doing that, and how is it going to be done?

25 MR. ESHELMAN: We have MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

66 1 essentially a FENOC group that does the training. Its a 2 FENOC wide program; and we have trainers, facilitators that 3 are responsible for that. Right now its being done in our 4 training organization. One of the facilitators has the 5 ownership of that. Hes reviewing it, hes going to make 6 changes. We will do refreshers as needed and incorporate 7 it into the ongoing programs. So, thats in process right 8 now.

9 MR. MENDIOLA: So, its done 10 in-house by your own folks?

11 MR. MYERS: We do use some 12 contractors along the way. We use, some mods have been 13 talked about using contractors in the past, and we may do 14 that from time to time. Generally, its our program, yes.

15 MR. MENDIOLA: You mentioned it 16 was FENOC wide. I assume it has been in use at your other 17 plants?

18 MR. MYERS: We think, let me 19 give you my personal thoughts on this.

20 Leadership in Action is, I think, a building block 21 for your supervisors and managers and your culture. In my 22 mind, at our other two plants, were using that program 23 pretty effectively to develop our future supervisors and 24 leaders, you know.

25 I think it sets the standard of our people, and you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

67 1 see the, the basic leadership principles, the strategies 2 being used in meetings and the way we do business. The 3 decision-making models we use and everything consistently.

4 When we come over here and we look at D-B, you see a 5 lot of people had been trained, but it was more like a 6 checksheet mentality. We got it done, but were not, you 7 know, we were forced to get it done, we got it done, but we 8 havent internalized it.

9 Part of what were trying to do, include leadership 10 strategies and behaviors on the boards in our room and all, 11 start demonstrating that were really as a senior team 12 support that program.

13 I dont sense that it got the leadership support 14 that we thought it was, but its not a new program, there 15 is some enhance many times now that well go make, now that 16 its been, I really looked at it very closely, and there is 17 some enhancements well make, and we have that being done.

18 Were going to go back and refresh every one on that 19 program and really start utilizing it at this site.

20 MR. ESHELMAN: Next slide.

21 Some of the indicators, again, more matrix for 22 management. The monitoring process is going to give us a 23 lot of information. Weve talked about that. Well be 24 able to access that and cut and slice it any way to get 25 some good information. Just a few examples; quality of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

68 1 briefs, safety practices, supervisory behaviors. Well be 2 able to assess those and focus on corrective actions in 3 those places.

4 Individual Error Rate, Human Performance.

5 Condition Reports. The quality, initial quality of 6 those.

7 Next slide.

8 Some of the assessments. Were going to be using 9 the Institute of Nuclear Power Operation as part of our 10 ongoing evaluation process, as well as some focus assist in 11 this area. They have some people in the Management/Human 12 Performance area that were involved initially. They gave 13 us feedback and were going to use them to kind of give us 14 another measurement once we have been in process awhile.

15 And the Restart Overview Panel. Theyre our critic, 16 and theyre going to make sure we are effective before we 17 go forward.

18 MS. LIPA: Dave.

19 MR. ESHELMAN: Yes.

20 MS. LIPA: Before we go on to 21 the next section, were going to take a break. So, well 22 take a break for ten minutes; be back at 10:45 and start 23 again. Thank you.

24 MR. MYERS: Youre a lot 25 better than Jack. He only gives us five.

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

69 1 (Off the record.)

2 MR. ESHELMAN: Well get 3 started. When we last left off, we were talking about some 4 of the initiatives in monitoring. In sake of time, there 5 is a lot more important issues. Ill try to go quickly 6 through this. Knowing first of all, the information is in 7 front of you. It will be on the NRC web page as well as 8 Geoff Wright himself will be personally validating, 9 verifying and giving us feedback on that.

10 Standards and Decision-making was the only other 11 area. Go ahead, Linda.

12 And, Lew already talked about one of the primary 13 elements was the Decision-Making Nuclear Operating 14 Procedure. Essentially, thats going to be our road map to 15 make sure we go through the technical process.

16 Go ahead, Linda. Wherever you stop, Ill start 17 talking.

18 Again, a lot of the monitoring were going to be 19 doing again is in the management monitoring. We had that 20 data base being built that will capture a lot of these 21 areas. And we have external oversight also.

22 Programs, Corrective Action. Dave has a project for 23 himself, thats the Corrective Action, but weve talking 24 about improvements in the programs themselves, the 25 procedures, et cetera, which is the program we use, but MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

70 1 also the implementation, and that factors into discipline; 2 how well were following our procedures, our demonstration 3 of ownership, our understanding of it.

4 So, we have actions in that area to address the 5 programs; and as well, some building block plans, 6 reinforcing standards.

7 Go ahead.

8 Now, if you see a corrective action, there is a long 9 list of items; from initial categorization to the root 10 causes and actions. Thats all in Daves house, Dave 11 Gudger has that activity were working on.

12 We have Oversight Boards, Corrective Action Review 13 Board, which again has the plant manager now as the 14 Chairman in Oversight.

15 Go ahead, Linda.

16 MR. MYERS: I think its 17 important to say, thats another one of those areas that in 18 my mind, that should have been the way we do business here 19 all along. And its something weve done in the Building 20 Blocks, but it will become part of the normal way of doing 21 business; performance indicators we have on the Corrective 22 Action Review Board and having the plant manager chair that 23 board, rather than some lower level subcommittee.

24 MR. ESHELMAN: And, again, well 25 have various indicators, performance matrix set up for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

71 1 them. What we did skip is the oversight, and as we 2 mentioned earlier, we have some programs right now; the 3 Program Review Process, the System Review Process; that 4 will continue. These will be permanentized as you would 5 say, institutionalized in our system so well continue to 6 do that.

7 Bill and his group are going to make sure we have 8 right oversight, the right standards for the oversight, 9 and at various levels. So, that was a part we skipped.

10 And again, there is a lot of indicators of what were 11 using. A lot of them kind of inferred behaviors, and 12 Geoff, youll have the opportunity to look at some of 13 those. Im sure well get feedback from you. We 14 appreciate that.

15 MR. MYERS: Let me stop 16 here. I know we want to move. But for example, the 17 Management Oversight Program and Weekend Duty Coverage.

18 What we found here, is that it was not an expectation that 19 the Weekend Duty Manager was in the plant. And at our 20 other two plants, Weekend Duty Manager is in the plant 21 working with shift supervisors, making sure were 22 monitoring weekend activities, that were getting feedback 23 from our operating crews; and then on Monday would go over 24 what we saw on the weekends.

25 That wasnt in place here. So, well strengthen MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

72 1 that some. Once again, management involvement and 2 management standards is a big part of this.

3 MR. ESHELMAN: Ill finish by 4 saying that, in review of the various condition reports, 5 not just head related, but pretty much all of them so far, 6 there is two common threads. Has to do with understanding 7 standards or clarification of standards and the other is 8 management monitoring.

9 So, throughout this discussion, pretty much you 10 heard a lot of repeat. First of all, set the expectation.

11 Okay, make sure it is clearly communicated. So the 12 expectation is what we communicate and we want to make sure 13 its in writing for all people to understand. The standard 14 is what we accept. And if we accept a lower standard than 15 our expectation, if that doesnt match, there is the 16 confusion. Thats why people dont understand the 17 standard, because its a moving target. A batter needs to 18 know where the strike zone is.

19 So, its important that we give our people the 20 understanding of whats acceptable, and then more 21 importantly as management we go out and monitor it.

22 Because again, if you do nothing, its slowly able to fade 23 away. You need to be out there as management, need to be 24 looking for behaviors, making sure youre reinforcing 25 proper behaviors and correcting ones that arent right.

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

73 1 Throughout this program, I say that is the key, and 2 thats why we have the standards in new management and make 3 sure were clearly communicating; and then more 4 importantly, were out there reinforcing it and holding 5 people to it.

6 That would end my presentation. If there is any 7 questions. Otherwise, well head on to Dave Gudger, 8 Corrective Action.

9 MS. LIPA: What page are you 10 on?

11 MR. GUDGER: Im on page 33, 12 for my presentation.

13 MR. DEAN: Dave, I have one, 14 kind of overarching question for you; and this really is 15 for the whole management team. But, in going through this 16 Management Improvement Plan, Human Performance, 17 Organizational Effectiveness; you outlined a lot of 18 different things that youre doing, lot of areas youre 19 focusing on. I guess I would like to get a sense from you 20 all as to what you believe are vertical elements here where 21 you believe you need to see meaningful change, meaningful 22 improvement before you think that restart is a viable 23 evolution for this organization.

24 Weve gone through a lot of stuff. I understand you 25 cant have all that stuff in place at a certain level, but MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

74 1 theres got to be some things that youre really focusing 2 on that you think provide the undercurrent for you to 3 recognize that things are moving in the proper direction 4 and safety culture is at the level you want before you move 5 forward.

6 MR. MYERS: Let me answer 7 that. I went back last week and we put in our 350 Building 8 Blocks, we think, what that acceptance criteria is.

9 In general though, let me go through it. I think 10 that we have to have our Engineering Review Board in place, 11 and prove that engineering documentation got good rigor. I 12 think that we have to have our Corrective Action Boards in 13 place, and proving that we are properly classifying our 14 products, and that in a Corrective Action Program, and 15 that, that our root causes and basic causes are in good 16 stead.

17 I think that we have to have our Management 18 Observation Program showing that our managers are in the 19 field finding and fixing problems. I think that we have to 20 have a positive improvement, vertical alignment in safety 21 culture of the station.

22 MR. GROBE: Along that same 23 line, along that same line, I looked at page 41 and page 24 42, which are your overall performance indicators to 25 measure improvement, pretty much summarizes a lot of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

75 1 performance indicators that are through the first 40 2 slides.

3 You speak of vertical alignment. I think thats 4 absolutely critical. And by vertical alignment, I think 5 what you mean is that everybody throughout the organization 6 vertically from the senior managers to the folks in the 7 field doing the work have a common understanding of 8 expectations and standards.

9 I dont see any of these performance indicators to 10 measure improvement, including the assessment of that 11 alignment. Most of it is counting issues.

12 MR. MYERS: I think the 13 Safety Culture Work Environment Survey did that, Jack.

14 MR. GROBE: Thats not on 15 here. And your management observations is not on here.

16 MR. MYERS: Okay.

17 MR. ESHELMAN: Ill write that, 18 thank you.

19 MR. MYERS: Certainly our 20 intent.

21 MR. GROBE: Okay.

22 MR. GUDGER: Are we ready to 23 move on? Okay.

24 For the benefit of the board here and the public, 25 Im Dave Gudger. Lews introduction with my experience MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

76 1 goes further back than the Perry Plant. I spent 15 years 2 at the H. B. Robinson Plant, at the Carolina Power and 3 Light Company. I did receive a NSR certification at the 4 Perry Plant and my background did involve bringing the 5 Corrective Action Program off the ground at the H. B.

6 Robinson Plant.

7 I come to this group as a new manager and my focus 8 is the Corrective Action Process, and I am the owner. I 9 accepted the position with the full understanding of how 10 much lies ahead with correcting this program, as far as the 11 problems that we have identified.

12 The purpose for what Im trying to discuss today is 13 to discuss the Corrective Action Program Improvement Plan 14 that addresses the following items; Corrective Action 15 Program Issue, as we understand it; the Interim and 16 Compensatory Measures established for assurance of the 17 program integrity as we move forward, and lastly, the 18 Approach to the Long Term Improvement Plan, which Im 19 involved.

20 All our assessments show all program elements are in 21 place. The issue lies within the implementation of the 22 Corrective Action Program that was less than adequate as 23 identified by the Nontechnical Root Cause.

24 I wont read through the bullets, but this is just a 25 restatement of the cause as we know it. The process or MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

77 1 program elements have been determined to be adequate. We 2 have two other nuclear facilities that use the present 3 program and are successful and do not have the 4 implementation problems that we have at the Davis-Besse 5 Plant.

6 The first order of business for me when I came into 7 position was to look at the staff and look at the 8 organization to move forward. I have added the center leg 9 to address the step Improvement Changes Necessary, under 10 Tony Sillakoski.

11 I also took a look at the third leg to the right, 12 under the Self-Evaluations Program, which I believe is the 13 key to strengthening the implementation of our program.

14 I am presently looking for individuals that have the 15 skills in change management and communications to 16 strengthen the implementation. I am building a bridge.

17 This bridge will encompass half the river, and I have to 18 facilitate and support the other half of the bridge from 19 the organization to take the ownership and accountability 20 to meet me halfway.

21 The interim compensatory measures that Ive 22 completed so far, and Im not finished, based on the first 23 one; I performed a Barrier Analysis to look at the program 24 and the flow, how the program works. I have identified 25 areas that compensatory measures need to be added as well MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

78 1 as validating compensatory measures Ive taken so far.

2 Some of these more important ones are Corrective 3 Action Program Owners, which is my organization, are now 4 directly involved with the management of categorization of 5 condition reports, each and every day. I have director 6 level support in this effort and we will continue until we 7 strengthen the management teams approach to 8 categorization.

9 The Standards Enhanced for Senior Reactor 10 Operators. I work closely with the operations organization 11 during their root cause effort to help in strengthening 12 their standards and whats acceptable in their reviews; 13 including timeliness.

14 Causal Analysis Review Group, which we refer to as 15 the CARG for the acronym, has been established. Its a 16 springboard from what Lew mentioned that was previously 17 established at the other two sites. This is a very key 18 action that were taking to strengthen the implementation 19 of the organization. Ill speak more to this in the 20 following slide.

21 The Corrective Action Review Board is now chaired by 22 the Plant Manager, which youve already heard. The 23 Corrective Action Expert Facilitation has been 24 established. We have an outside industry expert that is 25 helping with the CARG and the Corrective Action Review MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

79 1 Board as well as myself in the mentoring.

2 And lastly, the Corrective Action Program Closure 3 Review is another place where Ive injected my staff to be 4 an in-line review for closure of condition reports to 5 ensure quality exists. So, Ive injected myself on the 6 front end and on the back end of the program.

7 MS. LIPA: I have a question 8 for you, Dave.

9 MR. GUDGER: Yes.

10 MS. LIPA: The question I 11 have, are these compensatory measures being proceduralized?

12 MR. GUDGER: Not at this 13 time. As I get further in my presentation, Im going to 14 show you how my improvement plan will pull all this 15 together.

16 MS. LIPA: Thank you.

17 MR. GUDGER: What I want to 18 discuss a little bit, because it is what I think is a key 19 comp measure, and more importantly it will be here to stay, 20 is the new Cause Analysis Review Group, as I refer to as 21 the CARG.

22 Review of basic cause evaluations and selected 23 conditions adverse to quality is their charter. Ensuring 24 cause quality and programmitic requirements are being 25 adhered to. Provide peer review feedback to the evaluator MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

80 1 and approve long term quality behaviors is key.

2 They use it as Corrective Action Program users 3 group. And lastly, more importantly, is the development of 4 individual department corrective action improvement plans 5 will be a responsibility of each member.

6 I can put together an improvement plan in a generic 7 sense for the site; however, its more important that each 8 of these coordinators look to themselves for their specific 9 needs. I think this will strengthen the overall 10 implementation improvements of my efforts.

11 MR. THOMAS: What are the, 12 whats the background training and evaluation techniques 13 for this group?

14 MR. GUDGER: 12 out of 14 have 15 received Root Cause Training, and the two remaining are 16 scheduled to receive the new Root Cause Training to occur 17 next month, the middle of next month. We also performed 18 familiar, refamiliarization training with our expert 19 industry leader, Tony Sillakoski.

20 MR. GROBE: It might be 21 helpful for those on the phone, if you would just indicate 22 what slide number youre on.

23 MR. GUDGER: Okay, Im on 24 slide 49.

25 What I would like to talk to which has been the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

81 1 subject of interest this morning is our new Corrective 2 Action Program, Performance Indicators.

3 The purpose of the indicators is to monitor 4 transition, to improve the quality and ownership.

5 Establishing performance category measures for each program 6 attribute is to be in place by September 30th. It will 7 measure productivity, timeliness, efficiency, quality and 8 effectiveness. And more importantly, I am focusing on some 9 of the qualitative aspects of what we believe a healthy 10 implementated Corrective Action Program is.

11 MR. MYERS: Let me stop you 12 there.

13 One of the things thats key is we talked about a 14 performance indicators to improve the quality and 15 ownership, I guess. You know, Im familiar with our 16 Corrective Action Program. Im not used to a tremendous 17 amount of performance indicators. Typically, at our Beaver 18 Valley Plant and when I was at Perry, we looked every week 19 at all the corrective actions that were coming up, and made 20 sure we didnt have any late ones. There was not an 21 expectation that we have latent corrective action.

22 We looked at our backlogs and we didnt have 23 significant backlogs. And we looked at our implementation 24 and our Corrective Action Review Boards. I personally 25 approved every, every root cause that we did at our sites.

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

82 1 I really didnt need a lot of performance indicators.

2 At my staff meetings, after we approved a root 3 cause, which is a significant issue, we routinely brought 4 it back in, made sure were following through on the 5 corrective actions. But for where were at now, and the 6 numbers and what were going through, were going to need 7 these performance indicators to help drive the culture that 8 Im talking about.

9 I think for that to work for us at the startup, it 10 needs to get to where we meet those kind of criteria in the 11 future; that Corrective Action Program.

12 Im just, we throw a lot of CRs now, you know, that 13 were shut down. We probably need this. In the future, I 14 will expect that backlog to go down and us not to have, our 15 corrective action to be timely, more timely than that.

16 Okay.

17 MR. GUDGER: And Ill expand on 18 the performance indicators with regard to the qualitative 19 statement I made. A couple of examples, Im looking at the 20 CARG membership and assessing each individual member of the 21 CARG and report back to their management. Additionally, I 22 am looking at the managements miscategorization of 23 condition reports each morning. This is just a couple 24 examples of how Im trying to look at our behaviors and 25 whether were meeting the ownership and accountability MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

83 1 expectation, as Lew discussed in our mission and vision 2 statement.

3 Next slide.

4 MR. GROBE: Dave, are those 5 performance indicators going to be included in your weekly 6 report?

7 MR. GUDGER: Yes. They are, 8 Jack.

9 So, how am I going about my long term improvement 10 plan? This is a graphic depiction of what all I have to 11 consider in order to create a plan.

12 The first block there is CR, a condition report, 13 02-891. This is the Nontechnical Root Cause and 16 14 corrective actions Ive received. The Open Corrective 15 Action Program Condition Reports, which came from various 16 areas of the organization. And lastly, the Program 17 Compliance Review, which includes significant condition 18 reports.

19 Ive established two Root Cause Teams. And, I also 20 want to stress their focus self-assessment. The first time 21 is Human Performance and Implementation Team, which is the 22 larger of the two groups. And the second one is the 23 Infrastructure or the Program Team. These teams are 24 comprised of outside experts in each of the three 25 facilities program owners.

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

84 1 The output of this effort will be a Restart Action 2 Plan for items to be performed prior to restart, items of 3 significance that will be performed post-restart, and 4 thirdly, a three-year business plan outlook.

5 In conclusion, we believe we understand what the 6 Corrective Action Program issues are. We have interim 7 measures to address them, and were developing a long-term 8 improvement plan to ensure continuous improvement and 9 sustained performance.

10 I am the owner of the Corrective Action Program, and 11 I will set the example and the leadership role for 12 accountability and ownership for the site.

13 MR. DEAN: Dave, can you give 14 us a sense as to when you expect to have your Restart 15 Action Plan available?

16 MR. GUDGER: Yes, by the end of 17 October.

18 No other questions?

19 Ill start on slide 52. Ill turn it over to Bill 20 Pearce.

21 MR. PEARCE: Good morning.

22 MR. MYERS: Lets go back to 23 that. The end of October is very close to startup. We 24 already got a lot of our correction actions in place.

25 The problems that we had were not write -- we were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

85 1 writing CRs, it was classification of CRs; and I think we 2 can measure now that our CRs are being properly classified 3 today. So, I think thats in place.

4 The other thing was timeliness of corrective 5 actions. I think were going to have that in place too, 6 because we want to have all of our CRs as we speak right 7 now, system reviews and program reviews, and we have --

8 whats that CR review board?

9 MR. GUDGER: CARG?

10 MR. MYERS: No, the ones where 11 we go through each CR for startup.

12 MR. GUDGER: Restart Station 13 Review Board.

14 MR. MYERS: So, Bob Schrauder 15 leads that board and hes going through every CR, has gone 16 back and gone through every CR since the shutdown.

17 So, a lot of our corrective actions for startup are 18 in place. Weve got to validate that we properly 19 classified and taking actions on the CRs important to this 20 plant prior to startup. Our Building Blocks take us 21 there. Okay.

22 MR. GUDGER: Not withstanding, 23 were working through the condition reports.

24 MR. DEAN: Then what would be 25 the expected use of the output of the Restart Action Plan?

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

86 1 MR. GUDGER: My Restart Action 2 Plan, it is to formulate a program that will increase 3 performance in a sustained way beyond restart.

4 MR. DEAN: So, that sounds 5 like something you would want to have in place as a 6 framework before you did restart?

7 MR. MYERS: Oh, yes.

8 MR. GUDGER: Yes.

9 MR. PEARCE: Absolutely.

10 MR. MYERS: Absolutely. But 11 were not waiting until October to take actions.

12 MR. DEAN: All right.

13 MR. GROBE: I guess Im not 14 clear then. Could you explain once again, whats the 15 difference between a Restart Action Plan and a Post-Restart 16 Action Plan?

17 MR. GUDGER: Our process and 18 our procedures, Im required to make up an Implementation 19 Plan in response to this Program Compliance Review, and all 20 the RSRV decisions for the condition reports that they 21 coded.

22 In addition to that, I want to bring to your 23 attention was, Im pulling this all together. There are 24 management discretion items that need to be done after 25 restart, in addition to a long range three-year business MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

87 1 plan. Thats the sustained performance aspect of my 2 planning actions. Does that answer your question, Jack?

3 MR. GROBE: I think so.

4 MR. PEARCE: Okay.

5 Good morning. Im Bill Pearce. Im Vice President 6 of Oversight for FENOC. What Im going to talk about this 7 morning is Safety Conscious Work Environment, and Ill try 8 to explain that.

9 First of all, Im going through the assessment 10 structure and methodology that we use, and then Im going 11 to give you the survey results and then the actions to 12 address assessment findings and finally of course the 13 conclusion.

14 All right. First, under structures and methodology, 15 we used a team. We had Ken Woessner from Beaver Valley; 16 we used Stewart Ebneter, an independent consultant; and we 17 use Morgan Lewis, some of the attorneys from Morgan Lewis 18 to help us do that, as they had experience in this area.

19 It is really based on the NRC policy statement on 20 freedom of employees in the nuclear industry to raise 21 concerns without fear of retaliation. Thats the actual 22 basis for this. And this survey instrument that we used is 23 a widely used instrument for the most part of it. We did 24 add some special areas to it, but we wanted, since we had 25 some baseline, used this survey previously, we wanted to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

88 1 see how it had changed with the event that we had.

2 So, Ill go through this. Ill go through the 3 results.

4 The Structure and Methodology. We did a survey and 5 we surveyed essentially all the Davis-Besse personnel on 6 site. Only about one third responded. The survey consists 7 of 26 questions, which the workers were asked to respond 8 whether they strongly agree, they agree, they are 9 uncertain, they disagree or they strongly disagree with 10 statements. So, thats kind of what youre going to see 11 the result of.

12 The performance indicator, indicators that Im going 13 to show you, are the number of condition reports initiated, 14 the number of NRC referred allegations, and the number of 15 concerns brought to the ombudsman.

16 Under personnel interviewed, we interviewed the 17 Ombudsman, the HR Manager, Regulatory Affairs Personnel and 18 the Safe Conscious Work Environment Leads from three 19 primary Davis-Besse contractors. Thats Sergeant and 20 Bechtel and MPS.

21 Then we did an diagnostic quiz. We provided that to 22 20 Davis-Besse supervisors, managers and directors. So, we 23 did a diagnostic of the supervisor level up. And, youll 24 see the results of that.

25 Now, the survey results. The first part of it is, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

89 1 is willingness of workers to raise concerns. What we have 2 here, if you look at the three columns, we have 1999 survey 3 that was completed with these same questions; and then we 4 had a survey that, helpfully enough, we did just prior to 5 knowing we had this issue in the first part of 2002; we did 6 the same survey, and now weve redone it in August of 7 2002. And so, youll see the issues.

8 First one is ability to challenge nonconservative 9 decision by management. You can see actually that issue 10 has improved since 1999. Every one of these, youre going 11 to see a pattern, most of them youll see a pattern.

12 In 1999, the survey results were, I would say poor 13 compared to the industry for the most part. In the first 14 part of 2002, they were actually real good, greatly 15 improved result. And then in August, after we had the 16 event, then they have degraded to some degree again. So, 17 thats what we see here.

18 70 percent is the number that agree or strongly 19 agree with these issues in the first bullet.

20 Feel free to approach management with nuclear 21 quality concerns. 80 percent agreed that they could do 22 that.

23 The willingness to raise nuclear quality concerns 24 without fear of retaliation. You can see in 99 it was 73; 25 and the first part of the year it was 89 percent and now MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

90 1 after the event, its back to where it was in 1999.

2 Under one of the performance indicators, was 3 condition reports initiated, and you can see that in 99, 4 the number; 2000, and then 2001, and this year we have so 5 far, a much larger number, and a lot of that is driven by 6 the event weve had and the issues coming up and what weve 7 done to document those issues.

8 The next one is management wants concerns reported.

9 You can see that there is more doubt now about that issue 10 than there was in 2000, the first part of this year.

11 Management is willing to listen to problems. That has 12 degraded since the first of the year, although its 13 improved from 99.

14 Constructive criticism is encouraged. Again, its 15 improved, but since 99, but degraded since the first of 16 the year.

17 Management cares more about identification and 18 resolution of nuclear quality concerns than cost and 19 schedule. Now, we didnt ask this question before, so we 20 dont have the previous history; however, only 39 percent 21 agreed with that.

22 Now, I didnt realize that, this, when we wrote this 23 survey. When we were going through the survey, we were 24 still, I think doing the management root cause at the 25 time. But that is the management root cause, is, remember MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

91 1 the balance between cost and schedule, and safety was what 2 the issue was. And only 40 percent of the respondents 3 agreed that we cared more about the resolution of nuclear 4 quality concerns than cost and schedule. So, I think in 5 reality, it took me awhile to come to this conclusion, I 6 think this really validates from the employees view the 7 root cause that we did.

8 Next one is the Employee Concern Program. In this 9 particular plant, we call that the Ombudsman Program. This 10 is, when employees have concerns, they go through their 11 management. They have some issues they dont want to take 12 to their management, or theyve already taken to their 13 management, havent gotten it resolved or maybe its about 14 their management, but they need someone else to help them 15 with it. This is how they feel about that program.

16 I can use an employee concern program without fear 17 of reprisal. 85 percent felt they could at the first of 18 the year. And then after we had the event, only 70 percent 19 felt they can do that presently.

20 That the ombudsman will maintain confidentiality; 21 and only 66 percent or two thirds believe that the 22 ombudsman will maintain confidentiality.

23 Upper management supports the Employee Concern 24 Program. Only 60 percent agree that upper management 25 supports that program.

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92 1 And Ill tell you, that the, I think this is an 2 important program in a nuclear power plant. It gives 3 employees a way to bring forward safety concerns, and get 4 those issues elevated. When they try the normal system and 5 it doesnt work, it gives another path or method to elevate 6 those issues and ensure that they get resolved.

7 You can see the strength of that is indicated by the 8 survey is certainly not where we want it to be, and at the 9 end Ill go through some things were doing to correct 10 that.

11 In fact, Dave referred to that, you could see that 12 through our management plan, a lot of the things we are 13 doing is aimed at that issue.

14 Then performance indicator at the bottom is about 15 the ombudsman contacts. And you can see, although there is 16 a lot more this year and lot more investigations, with the 17 amount of issues going through as a plant, I see that as a 18 consequence of the amount of issues that are being brought 19 forward at this plant, and not having a healthy environment 20 or feeling that the management will resolve the issues when 21 theyre brought forward. So, thats kind of how I see 22 that.

23 Effectiveness in resolving issues using normal 24 processes. Again, I want to tell you that I look at these 25 questions; I think they validate what Dave just told you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

93 1 that he and his team have found by looking at the 2 Corrective Action Program; that this is the employees view 3 of the Corrective Action Program.

4 The Corrective Action Program is effected to 5 identify potential and nuclear safety quality issues. Only 6 57 percent agree with that.

7 Free to report concerns using Corrective Action 8 Program without fear of reprisal. 71 percent agree with 9 that, which I think that is pretty good.

10 Issues in Corrective Action Program are prioritized 11 appropriately, investigated thoroughly and timely 12 resolved. Only 41 percent agree with that. And that, in 13 fact, I think validates the issues Dave says are problems 14 in the Corrective Action Program and what we need to get 15 resolved.

16 MR. MYERS: Stop there a 17 second. In the four Cs meetings, we hear over and over 18 again, we write a CR in our process and our job is done, 19 you know. If we write a CR, our job is done. Were not 20 giving good feedback, and we created that culture that once 21 we write the CR, the job is done.

22 The message that we keep saying is, when we have a 23 safety concern, you wrote a CR. There is no job done and 24 there is no organizational structure. You need to continue 25 to drive that to the highest level of our organization MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

94 1 including PO, ombudsman, or you guys.

2 So, were getting some of the same things, and I 3 would say validates it in the 4 Cs meeting and group 4 meetings also. Weve got to fix that.

5 MR. PEARCE: I wrote these 6 other two, Corrective Action Program is effective to timely 7 resolve conditions adverse to quality, was 42 percent agree 8 with that.

9 Corrective Action Program is effective to address 10 root causes and broader implications of nuclear safety 11 quality issues, 45 percent.

12 The performance indicator in this area is NRC 13 allegations. These are issues that the employees have, 14 that they feel the need to not use either the management or 15 the Employee Concern Program, but rather the need to go to 16 the NRC to ensure that the issues get resolved.

17 And you can see so far this year, weve had 25.

18 Ill tell you, based on the industry experience, thats a 19 fairly large number so far this year. And I guess I would 20 say, that there is a lot going on at the plant and some 21 elevated numbers normally associated with a plant thats 22 going through some type of event.

23 So, Im not trying, I hope Im not trying to 24 rationalize that its okay for that to happen, but rather 25 tell you that we have a need to do some of the things that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

95 1 were doing to strengthen that program.

2 The next area is management effectiveness in 3 detecting and preventing retaliation. Another important 4 issue. And, none of these issues have been previously 5 surveyed at this site. These were ones we wanted to look 6 at and see where we were and what we needed to do. There 7 is not a lot of industry experience about what would be a 8 normal amount or bad normal amount, so Ill go through 9 them.

10 I have been adequately trained on the various 11 processes for reporting and documenting nuclear quality 12 concerns. 72 percent agree that they have had that 13 training.

14 My supervisors/managers have been adequately trained 15 on various processes for reporting and documenting nuclear 16 quality concerns. 61 percent agree with that.

17 I have been subject to, the term here is H I R D; it 18 stands for harassment, intimidation, retaliation, or 19 discrimination; for raising nuclear quality concerns. We 20 had 7 percent of the respondents said that they agreed that 21 they had been subject to that.

22 Now, let me tell you, Ive read every survey result 23 that came back; and there is a long time period, as we all 24 have, if we ever feel like weve been treated in that 25 regard, it lasts for a long time in our minds; and a lot of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

96 1 the issues are several years over there.

2 In fact, I could only think of one of them that I 3 saw was around the issue that we had on the head. So, our 4 next survey will give us some update in that regard.

5 Then the last bullet is, I know of instances in 6 which workers in my work group have been subject to the 7 harassment, intimidation, retaliation or discrimination for 8 raising nuclear quality concerns. And those, some people 9 wrote in what they are. They generally corresponded to the 10 folks that have said that they had, had some issue with 11 that.

12 So, what do you take from that? What I take from 13 that is, that the management team has not been effective in 14 making folks feel like that they can bring issues up and 15 have confidence that theyre going to get resolved; and 16 preventing even the appearance of retaliation for people 17 bringing issues up. And, so, when we talk about corrective 18 action, well see how we address those.

19 The first thing is the Safety Conscious Work 20 Environment Action Plan; and what we did with that action 21 plan, as a result of this survey, we came up with the 22 action we thought needed to take to resolve those issues.

23 And we then put it in what Dave was talking about 24 earlier, the Management and Human Performance Improvement 25 Plan. And, we also are going to add additional resources MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

97 1 from outside Davis-Besse to assist in implementing the 2 action plan. Were in the process of trying to find those 3 folks now and get them in here.

4 One of the big issues is willingness of workers to 5 raise concerns and management support for raising of 6 concerns. I see here, some of the bullets of some of the 7 things were doing there. We talked, for instance, we 8 talked about the 4 Cs meeting. Part of it is in my mind, 9 is a trust issue with employees; and I think you can 10 generally see some trust issues soon after you bring in a 11 new management team.

12 So, its important for Lew and some of the other 13 folks to get some face time with employees to let the 14 employees see what the values that they have are and gain 15 some trust, so theyre more willing to bring those issues 16 forward.

17 The next thing, go to the next slide.

18 The Employee Concern Program. What weve had in the 19 past is a Ombudsman Program, which kind of is a passive 20 program, that waits for employees to bring issues to them.

21 We intend to go to a proactive model, where were going to 22 go out and solicit issues.

23 Now, Ill make this a little bigger than it is in 24 here. You heard Dave say something about the People Team.

25 Well, the People Team is a piece of the issue and the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

98 1 Ombudsman is a piece of that. That is, to find out what 2 concerns there are out in the plant by employees, to go out 3 and actively solicit those issues, whether theyre brought 4 forward through the, through the Condition Report Program, 5 whether they come through the HR. We have HR themes that 6 boil up; people are concerned about their pay or this or 7 that. Whether they come from a discipline issue, from a 8 performance issue, this people team is going to go look at 9 those issues.

10 A subset of that is Employee Concerns, where 11 employees have concerns that have a, some safety 12 implication or have some concern that needs to be 13 resolved. And a part of that is employee concerns, and of, 14 those, as I said, well have a corrective model. In the 15 past, weve used the management people in the organization 16 to go investigate the issues that came forward. In this 17 program, were going to use some investigators, independent 18 investigators to go dig into those, and make sure that the 19 employees dont have the perception that their issues are 20 not being treated properly, because their own management in 21 some cases do an investigation of the issues that are 22 brought forward.

23 So, thats kind of big picture of how I see we need 24 to change the program.

25 MR. MYERS: One of the things MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

99 1 too, with all the changes weve had in management right 2 now, the issues that weve seen here; what that does, that 3 does monitor the effectiveness of management also.

4 MR. PEARCE: Right, 5 absolutely.

6 MR. MYERS: So, we think 7 thats a necessary additional ingredient that we need here, 8 with the issues that were seeing. So, I think you asked 9 what are some of the key things. Right there is one of 10 them. Investigators, I think, are going to be a key part 11 of seeing how effective has the management been.

12 MR. PEARCE: Next area is 13 management effectiveness in detecting and preventing 14 retaliation. Were using a proven training program used a 15 lot in the industry. And were bringing in, in fact, weve 16 already reviewed it. Were going to have it taught by a 17 group of people that deal with the issue of safety 18 conscious work environment issues. And were going to 19 train the officers, the directors, the managers and 20 supervisor to, how to deal with this kind of issue, so that 21 we avoid having any misperception of retaliation or 22 chilling effect of this kind of issue.

23 And thats one of our problems, is our folks I dont 24 think always understand how, when they respond to issues, 25 its taken sometimes, or perceived to be taken.

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100 1 Talked about the People Team. And the Issue 2 Management Process, the last bullet on that page, just 3 refers to how were going to deal with issues with the 4 People Team or the Employee Concern Program.

5 Rather than go through every one of these bullets 6 thats left, most of them are fairly self-obvious. What 7 overall were going to do going forward, is were going to 8 do another survey. And I fully expect right now at least 9 that were going to do another survey before we restart.

10 But, weve got to time it such that we get some of 11 the things done that we see are actions from this survey 12 before we do the next survey. And thats important, 13 because, I mean, I wouldnt expect that we would see much 14 difference in the results unless we do something about what 15 they told us the first time. So, we have to get some of 16 these actions in place and when the timing looks right, 17 well redo the survey.

18 And I really do believe, as Lew suggested, that 19 were already seeing some effect from the 4 Cs meeting 20 from the All Hands Meetings, from some of the actions weve 21 taken to communicate to the employees. I think were 22 seeing some things changing that are going to effect the 23 survey, but I will wait until we get the training, 24 especially of the managers and supervisors completed, and 25 get that done and the case studies done, because the Safety MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

101 1 Conscious Work Environment is going to be part of the, of 2 the case study training that we do for all the employees.

3 So, I want to get that done and then well be ready 4 to do another survey and see how the results may change.

5 In conclusion, I guess what I would say about this 6 is that I think weve, we had a feeling that we ought to do 7 this survey, even though we knew with the things that had 8 happened at the plant, and people feeling bad about 9 themselves, their job, that survey results were probably 10 going to be less positive than they were before this event 11 happened. Its important for us to get this and get the 12 feedback from the employees.

13 The good part about it, in my mind, is the results, 14 even from a completely independent means, validated, to me, 15 the Root Cause that the team came up with, using a wholly 16 different process. It validated the second part of the 17 Root Cause, which was the Corrective Action Program, and 18 looked at the results in this survey on the Corrective 19 Action Program; how the employees perceive and feel about 20 the Corrective Action Program, is where the rubber meets 21 the road. And, so, it validates I think the issues that we 22 found and the Corrective Action Program also.

23 So, overall, although we got some negative results, 24 I think that it helps us understand that were headed in 25 the right direction with the corrective actions that were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

102 1 taking to improve a lot of the processes at the plant; I 2 guess is how I see it.

3 Do you have any questions?

4 MR. THOMAS: Bill, what, if 5 anything, will be done to increase participation in the 6 next survey?

7 MR. PEARCE: Well, one of the 8 things I would think were going to do is we talked about 9 it in one of the All Hands Meetings, the results of the 10 survey. And its got to be voluntary. I dont want to 11 make it a requirement for people to respond to the survey.

12 But at one of the All Hands Meetings, we talked 13 about the results. And I think any time that you advertise 14 that you have listened and you understand what folks need, 15 its likely to increase the participation, because they see 16 that were taking actions based on what they told us. So, 17 people that do want us to get things changed are going to 18 be more likely to participate in the survey.

19 MR. MYERS: We had leadership 20 help us.

21 MR. PEARCE: In fact, we had a 22 meeting with the leadership employees the other day, and we 23 asked their help in getting our folks involved. So, were 24 doing a lot of things that will, that will increase the 25 participation.

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103 1 What I rationalize to myself, all Ive talked about 2 are the absolute facts, but what I rationalize to myself, 3 if you only get one third of the people that you surveyed 4 to respond, what does that mean? If I rationalize it, I 5 would say that it would tell me that probably we got a 6 higher percentage of people responding that had some 7 issues.

8 You know, because if you got an employee that has an 9 issue, it gives them a means to get their issue down.

10 Someone who didnt have an issue of any kind, probably 11 dont care enough to respond. So, but thats a 12 rationalization. And these kind of instruments, youve got 13 to look at just the facts that you get and not try to do 14 too much conclusions or drawing conclusions from some of 15 the stuff.

16 MR. MYERS: The answer to 17 your question, were going to get the numbers up.

18 MR. PEARCE: But were not 19 going to arm twist to do that.

20 MR. DEAN: I have a couple 21 questions, and maybe a comment. In looking at the results 22 from 1999 from the survey, there is a dramatic change 23 between 99 and the survey you took in January; were there 24 some positive actions that were taken by management here to 25 address that? And if so, is there some issues here in MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

104 1 terms of sustaining of those?

2 I dont disagree, but Ive seen issues like this 3 before at the other plants, we have a traumatic event, the 4 organization looks at itself in different light and maybe 5 judges itself a little more harshly. So there is some I 6 think reality associated with that. But you know, it just, 7 its kind of like a roller coaster here, it seems to me 8 there should be some positive action statement.

9 MR. PEARCE: Bill, I can tell 10 you that there was a, I think there was some positive 11 changes at Davis-Besse in the years while this event was 12 going on. There was some negative things happened; on the 13 other hand, I think there were some positive things 14 happened in the leadership area too. And that showed in 15 here, is that people did feel like, for the most part, that 16 they could bring issues more easily updated.

17 For some reason, and I think its part of 18 communications that were going on at the time, they felt 19 that they could communicate better with their management.

20 And thats probably just my own personal feeling about what 21 I see was driving that.

22 MR. MYERS: Lot of the 23 management came out of this organization. A lot of 24 management we have now came out of the organization. So, 25 there is, they dont know us. And if you look back in the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

105 1 80s, early 90s, you know, a lot of that management then 2 didnt come out of the organization. So, we went through a 3 roller coaster as a plant in that area.

4 What weve got to do now is get, Ive heard it 5 referred to as suction of the pump, developing our people 6 from a technical skills standpoint and managerial skills, 7 lay that out, so that we get off this roller coaster and 8 get sustained leadership performance to this site, from a 9 management leadership standpoint.

10 MR. PEARCE: Let me add one 11 more thing to that. In January, the plant was, if you 12 take, for face value what the values were at the time, 13 right, from a production standpoint, from a long run 14 standpoint, from a no visible issues standpoint, doing 15 very, very well in January. With a 500 day run at the 16 time. Wasnt a lot of visible problems on the table at 17 that time.

18 The actions that they had taken, seemingly had 19 produced favorable results. That probably had some 20 influence on the survey in January.

21 MR. MYERS: When we bring 22 people in, some of our outside agencies and bring them in 23 to walk around the plant; they walk around this plant and 24 say, this plant is in really good material condition. It 25 really looks pretty good. Probably looks better than our MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

106 1 other two plants from a material condition standpoint.

2 So, you know, theres a lot of things that were 3 going right at that time.

4 MR. PEARCE: At least it was 5 going right in the perception for the values that were 6 being held.

7 MR. MYERS: That is right.

8 MR. MENDIOLA: Clearly, that has 9 some bearing maybe, if you will, on the atmospherics around 10 the January 2000 survey, but what about the atmospherics 11 surrounding the 99 survey, whose results are somewhat 12 closer to currents results you just got in August?

13 MR. PEARCE: I dont have any 14 personal knowledge. Although, Ive discussed that in some 15 regard with the ombudsman. His view was that, he was 16 concerned in 99 when they did the survey, and he was 17 trying to take actions, especially in the area of Employee 18 Concern Program to improve the feeling of trust. He felt 19 that 2001 survey was, was a great victory on the things he 20 had been doing trying to get better feelings about the 21 Employees Concern Program, for instance. But in some of 22 the other areas, I really dont have any personal knowledge 23 of.

24 MR. MYERS: Ive got a little 25 more knowledge there. I went to Beaver Valley in 99. And MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

107 1 right before that time, you remember the year before, was a 2 tornado; the performance of the plant had gone down; we 3 were changing some managers out at that time; a lot of 4 things like that going on. So, prior to 99, 99 based on 5 the 98 performance, was probably not the highlight of this 6 plant.

7 It looked like we had been recognized as an 8 excellent plant by many; I dont know how to say this; many 9 organizations, industry organizations, a lot of plaques on 10 the wall; and that performance decreased in 98 and 99, 11 you know. So, you saw, you saw that beginning to happen 12 then.

13 We, as a management team, at that time took what we 14 thought were some subtle actions to make some corrections.

15 And, you know probably not as strong as we should have 16 been. I dont think we got down to the heart of the issue, 17 you know. So, I understand those results in 99.

18 MR. PEARCE: You speculate.

19 MR. MYERS: Yeah, I think you 20 do. And that was only, I was at Perry and then I was on 21 the Oversight Board. You could tell it was a big letdown 22 in 99, you know. I sensed that when I come over here.

23 MR. DEAN: The only other 24 question I have, Bill, you might have addressed it; I might 25 have missed it, but in terms of looking at the this data.

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108 1 Obviously, its one tool to get a pulse of the staff, and 2 their views on this. Have any of the other activities been 3 ongoing, the 4 Cs, the ROP, the other meetings with the 4 staff; have they touched on similar areas and is there some 5 correlation that youre seeing there from those types of 6 discussions?

7 MR. PEARCE: Yes. I believe 8 that. In fact, Lew and I have talked about that. The 9 conversations that weve had with employees have 10 substantiated, however there is no numerical value you can 11 associate with it to understand what percentage it is or 12 anything. These issues are certainly substantiated, on the 13 individual basis in conversation.

14 Wouldnt you agree with that?

15 MR. MYERS: Absolutely. If 16 you go to look at the corrective action, every issue we 17 have; writing CRs, influence to bring issues forward. One 18 of the things were doing in our 4 Cs meetings, we have an 19 organization effectiveness person that facilitates the 20 need, and groups all the questions together, so its sort 21 of confidential; like you really didnt want to bring your 22 question directly up to me.

23 And then a couple days later, after we group 24 questions together, and they come out with a group team 25 question rather than individual questions, I would go back MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

109 1 and meet with the team. And to a person, your issues 2 about, you know, we want stability of management; we want 3 off the roller coaster, if you will.

4 We want some stabilities of management. We hear 5 that over and over again. We want stability and 6 direction. We work hard, you know. I mean, its not our 7 fault. And Ill be the first one to say this; its not 8 their fault.

9 The behaviors were seeing are a reflection of the 10 senior management team; and you know, so you get what you 11 expect. So, you hear a lot of same issues, exactly the 12 same issues.

13 And I can also tell you that, you know, were taking 14 actions; were demonstrating those actions; communications 15 to employees. Before we had the public meeting with you 16 guys yesterday, we had sort of a mini All Hands Meeting 17 with employees here to tell them first what we were going 18 to say, because they always say they read it first in the 19 newspaper; and thats not right.

20 So, you know, were trying to deal with those 21 issues. I really believe that we will see, weve got to 22 see a good improvement in this area for restart. I know 23 that.

24 But I also think taking a survey now, we thought 25 that was our low point. So, we took it then. You know, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

110 1 when youre struggling like you were, its a good place to 2 benchmark at. We could have waited until we got a lot of 3 things in place. What do you call it, get better 4 performance indicators. This looks pretty nasty. So, we 5 took it at our low point, we think, and we would expect to 6 see improvement at restart, you know.

7 MR. DEAN: Your point about 8 senior management and stability and so on and so forth, I 9 think has some validity in terms of senior management 10 setting the tenor, setting the expectations, but when it 11 comes down to the execution and implementation, the first 12 line supervisors that are the direct influences on assuring 13 that people are comfortable bringing forward issues and so 14 on and so forth.

15 Can you point to those things in terms of your 16 actions where you think the direct focus with your first 17 line supervisors is the key elements?

18 MR. PEARCE: Yes. In fact, Lew 19 pointed those out earlier. Do you remember when he talked 20 about vertical alignment? Thats exactly what hes 21 referring to. The only way to get vertical alignment is to 22 get through the first line supervisors. And thats the 23 most important issue, is to get the organization aligned so 24 that all of you have the same values and follow the same 25 principles and that type of thing. So, all that is aimed MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

111 1 exactly at that, Bill.

2 Now, from a safety conscious work environment 3 specifically, like the training, you can see that we aim 4 the training at the managers, the directors, and the first 5 line supervisors to get through all the supervisors from 6 that specific issue; but thats much too narrow to address 7 this issue overall. Its about the vertical alignment of 8 the organization.

9 And, that whole program, our whole program is set up 10 around that. It is the most important thing that from a 11 people perspective that weve got going right now.

12 MR. MYERS: There is a big, 13 as a manager, if youre not involved; you dont get 14 involved with the jobs, youre not going in containment, 15 not coming in on the weekends; what your relationship with 16 your first line supervisor, you know?

17 Its bad when the President of FENOC says I was in 18 containment more than most of the managers at the last 19 outage. They keep telling me that, so I keep repeating 20 it.

21 MR. WRIGHT: Bill, one thing 22 you alluded to a couple of times in the presentation here, 23 but wasnt expanded on, and one of the hard things about 24 this whole event was not only did we have, you know, the 25 degradation of the head and degradation of programs at the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

112 1 site, but you had just an overall declining expectations 2 and performance of the entire site, which means that, you 3 know, internal assessments by themselves arent going to 4 show anything, because the goals and expectations are 5 riding down the hill with the organization.

6 Can you address a little bit about what youre doing 7 and what youre looking at, to look at the organization as 8 a whole to prevent that from occurring?

9 MR. PEARCE: I sure can. If 10 you remember looking at the, Dave Eshelman talking about 11 your Quality Assurance Program, that is the root cause of 12 the quality assurance issue. It set the standards and 13 behaviors of the Quality Assurance Organization parallel to 14 the line organization, because they reported to them; and 15 as they, as the standards, declined in the line 16 organization, so went the Quality Assurance Organization.

17 Some of the actions that were taken in that regard 18 is, were setting expectations in the line organization.

19 And, you heard us talk about the Operations Group, for 20 instance, doing that. In addition, the Engineering Group 21 has already done that. And the Maintenance Group, I dont 22 know how far they are along, but they are in the process of 23 the same issue.

24 But just as importantly, is the Oversight Function.

25 One of the most important ways to me to raise standards is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

113 1 to use, we can use the Quality Assessment Organization to 2 do that. And what were doing there is, were going to 3 bring a very heavy focus on Appendix B.

4 For the audience, what those are, those are the 5 bedrock standards thats been in our industry for a long 6 number of years, and the focus on those issues clearly is 7 what segregates the nuclear standards from the standards of 8 the other industries. And were all familiar with it, I 9 was just trying to define it for you for those of you who 10 dont understand what it means.

11 But were going to focus our quality assurance on 12 the Appendix B issues and make sure our folks will 13 understand that, what that means to us, make sure that we 14 have it internalized; and if we go out and then look at the 15 organization for their conformance to those standards.

16 In addition, another place we failed, in my opinion, 17 was in the Company Nuclear Review Board. What that is, is 18 an oversight panel of out -- comprised of outside, people 19 outside any of our company organizations that are supposed 20 to oversee not only the Quality Assurance Group, but the 21 operation of the plant overall. And we failed to detect 22 the issues in that organization also.

23 And although I havent completed the actions, and I 24 really am not at liberty to put out some of this stuff yet.

25 One of the things I can tell you is, in that organization, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

114 1 were going to focus on safety issues and not management 2 issues. Thats one of the main findings, is that it got, 3 it started looking at management issues and how were 4 managing the plant and not standing back and staying 5 focused on the safety issues of the plant.

6 Like I said earlier, some of the indications of this 7 issue are almost apparent from those of us that do this a 8 lot for a living. They should have been more apparent.

9 And, the fact that we failed to detect them is hard to 10 understand, but we should have been able to.

11 Had we focused more on what are the safety issues, 12 how do we make sure weve got those well in hand, and now 13 and only then can we start looking at the operational 14 issues and some of the management issues and that kind of 15 thing. That to me, going forward, is what weve got to get 16 fixed.

17 So, I think thats how I see. I think what your 18 question is, right?

19 MR. WRIGHT: Yes.

20 MR. GROBE: Bill, Im a little 21 concerned about, you say, Concept of Safety Conscious Work 22 Environment Survey. Clearly, the surveys to-date, one you 23 did in August, provided you keen insights on this.

24 As Scott mentioned earlier, its a little 25 disappointing that the contribution was at a fairly low MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

115 1 level, but it provided you insights.

2 This area of performance is going to be a key in 3 restarting the plant.

4 MR. PEARCE: No question.

5 MR. GROBE: And my concern is 6 that, recognizing that, people might learn how to answer 7 the questions correctly to give the right answer to get the 8 plant restarted.

9 Have you thought about that, and how are you going 10 to address that as a potential problem?

11 MR. PEARCE: Ive thought about 12 it, Jack, but its a hard question to answer.

13 MR. MYERS: Let me answer 14 that. I dont think you can answer that question from a 15 simple survey. I think youve got to stand back and look 16 at the assessments that well do, the ROP Team will do, the 17 People Teams, the 4 Cs Meetings. I think youve got to 18 look at all that.

19 If you -- I mean, people arent bashful. Thats one 20 of the things that I can guarantee you from meetings Ive 21 had, is theyre not bashful. And you know, I think that 22 Im, youre going to have to look at all that and do a 23 management assessment, using the survey and the other 24 tools, to allow me to think the safety culture is improving 25 here.

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116 1 MR. GROBE: Lew, do you have 2 some sort of way that you are regularly integrating the 3 information that youre going to be receiving from these 4 various sources to get a broader sense of the health of the 5 people in this area?

6 MR. MYERS: I think the 7 answer to that is yes. I believe, if you go look at this 8 whole building block, we try to take the results of this 9 survey, try to take the results of 4 Cs, were getting 10 back out of the employee meetings were having with the ROP 11 Panel. For example, the ROP Panel gave me some feedback a 12 week ago, and we met with the team and weve already taken 13 some actions there.

14 What you find is the feedback that they were giving 15 me is actually the same feedback were getting out of 16 4 Cs. So, it had to do with the overtime boxes. That 17 went, that went from a complaint to a compliment at the 18 last meeting. So, were just going to keep raising 19 issues.

20 MR. PEARCE: Let me address one 21 more thing. Some of the issues that are culturally based, 22 it takes a long period of time to change someones culture, 23 but it doesnt take so long to change a behavior. And in 24 some cases, I know you recognize this, because the O350 25 Process does not stop at plant restart.

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117 1 Im sure were going to end up with some issues at 2 the end that we see that we have not gotten totally 3 resolved or dont, maybe its just that were unable to 4 demonstrate in some method that theyre totally resolved to 5 our satisfaction.

6 And in those cases, we may have some extra barrier, 7 extra method of monitoring whatever the performance issue 8 is, such that -- and Ill give you an example. How about 9 some of the extra oversight that we have in Corrective 10 Action Program. We may choose to continue that even after 11 restart, because we want to make sure that the, some of the 12 issues that we have there, continue to stay fixed until we 13 can assure ourselves that the, that the normal program is 14 going to take care of them.

15 But, the requirement is, or the thought is in my 16 mind, that we need to make sure when we restart, that were 17 getting corrective actions dealt with properly, we can 18 demonstrate that, we feel confident that weve got that, 19 but that may take some, some extra barrier for some period 20 of time even after restart for us to get through some of 21 the longer term internalization of our employees and that 22 kind of stuff.

23 MR. MYERS: Im excited, I 24 mean I am excited about investigators that were bringing 25 in. Weve got independent investigators, you know. First MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

118 1 that sends a chilling effect, especially if youre a 2 manager or supervisor.

3 MR. PEARCE: Definitely 4 chilling.

5 MR. MYERS: But it does. You 6 say, why would you want those investigators, dont you 7 trust us? Its not a question of trust, because you do 8 trust them. But your first instinct is, why would you do 9 that?

10 Well, you do that, because you want some independent 11 assessment of the behaviors, so you can make the 12 corrections you need to make. All right?

13 Its not a question of trust, but the first time we 14 say that were going to have these independents, rather 15 than doing it in-house by the groups, that were going to 16 have these independent investigators do these assessments, 17 you know, concerns; what do you think the reaction is going 18 to be from the managers. You dont trust us. Theyre 19 after us. I can tell you what they are.

20 But weve got to overcome that. Im excited about 21 that opportunity, because I think its going to help us 22 assess our own behaviors at the management level and make 23 the adjustments for the supervisors that we need to make, 24 you know, to be independent. Its hard to see it 25 yourself.

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119 1 MR. GROBE: Many of the areas 2 that youre assessment performancing are fairly easy to 3 assess with relative indicators. This is an area that is 4 much more complicated to assess. And youve described in 5 each of the sections, we went through some of them rather 6 briskly, but youve described a number of performance 7 indicators, and I think youve indicated that might develop 8 some more.

9 It might be worth while to put some effort into 10 looking at how youre assessing the coherence of how youre 11 assessing performance in this area, and how youre bringing 12 together all those areas of performance indicators to give 13 you an effective indication of organizational 14 effectiveness.

15 MR. PEARCE: Okay.

16 MR. GROBE: And how youre 17 going to review that, who is going to review that and what 18 period youre going to review it.

19 MR. PEARCE: Okay. Well look 20 at that, Jack.

21 MR. MYERS: You know, we do, 22 one of the major tools that I use in that area, is this 23 link in the Associates Group. Weve got them working in 24 our Maintenance Organization, Operations Organizations and 25 the 4 Cs. You know, what is the overall organizational MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

120 1 effectiveness of the actions were taking, you know? I 2 would hope they could help us with that question you just 3 asked too, so.

4 MR. GROBE: Other questions?

5 Okay, why dont you go on, Lew.

6 MR. MYERS: Let me get a 7 little closer here.

8 You know, we shared with you and the public that we 9 completed our Root Causes. So, what I wanted to clarify 10 today, there is a lot of root causes and they all feed into 11 a group of toolboxes, if you will, five areas of the 12 Management Improvement Plan. I think we did that.

13 Weve developed Corrective Actions, a group of 14 tools, if you will, that were taking in each one of those 15 areas. And well continue to share those Corrective 16 Actions in our work plans as we go forward.

17 To-date, you know, weve changed a lot of managers 18 here at the plant. Weve changed a lot of managers out at 19 FENOC, at the senior level. I also have the title of Chief 20 Operating Officer that I didnt have before. Sooner or 21 later, there will be another vice president at the site.

22 Im handling both positions now, but were going to 23 make sure that the leadership is consistent. Its not 24 going to be a roller coaster. Thats my job. Im proposed 25 to do that.

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121 1 Weve developed engineering standards. Weve done 2 safety culture survey to benchmark. Engineering Assessment 3 Board has been established. Its becoming part of our 4 internal organization.

5 Then finally, the Restart Oversight Panel will not 6 go away at restart either. You know, maybe I need to 7 change their name.

8 Weve added an executive in operations, that will be 9 with us for fairly extensive length of time. Weve got 10 weekend coverage requirements now. Project Review 11 Committees have been, have enhanced oversight. Corrective 12 Action Board is now chaired by the Plant Manager, has 13 performance indicators.

14 The Restart Oversight Panel. They are really high 15 level group of independent executives, providing us 16 feedback of the needs of our own employees. Takes nerve to 17 let them go out and have meetings with your employees, but 18 thats that management courage were talking about. Then 19 augmentation of our Engineering Organization.

20 So, weve taken those actions. And then the 4 Cs 21 Meetings, Town Hall Meetings, the equipment upgrades. Key 22 important part, I think, that we havent talked much about 23 is the restart of the plant. I mean, if you want to set 24 the standards, improve the quality of the asset. If you 25 want to set the standards, improve the quality of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

122 1 asset. So, we have to demonstrate that were improving the 2 quality of the asset, you know, to set the standards of 3 employees.

4 On the way up, we intend to start up with, by 5 addressing a lot of mods, that we have to make; a lot of 6 material condition improvements, like reactor coolant pump 7 maintenance, thermal walls that were working on, feed 8 water heaters. Improve the quality of the asset. Training 9 programs. So, well have to do that.

10 I would conclude by saying behaviors, once again, 11 its not necessary to sit up here talking about the 12 Davis-Besse employees. Lets talk about us. Behaviors are 13 a reflection of the management team.

14 We focused today on the Improvement Plan. Key 15 process there is Corrective Action Program. Weve got to 16 have that, so we think its ready for restart.

17 Engineering Assessment Boards have to ensure the 18 quality, engineering products are good. Corrective Action 19 Review Board; make sure were properly classifying our CRs 20 and doing, were identifying stuff. The Management/

21 Supervisor Assessments; thats to make sure our standards 22 are being implemented on procedure adherence.

23 Prejob Briefings in the field. If we had done a 24 better job of that before we found the head problem.

25 Vertical alignment of our values and we have to measure MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

123 1 that effectively. And our standards and our safety 2 culture, we talked a lot about that.

3 And finally, improving trends and material 4 condition. Thats got to be a key element of restart. Are 5 you improving the quality of your asset? You know, I would 6 be asking that.

7 And so, if we do those things, I believe we will be 8 able to come to you and tell you, we feel the management 9 team is ready for restart. Thank you.

10 MR. GROBE: Any final 11 questions?

12 I have a couple remarks I would like to make before 13 Christine wants to take a brief recess and then well go to 14 public questions and answers.

15 First off, I want to thank you for your 16 comprehensive presentation today. It was comprehensive.

17 Necessitated us to breeze through a couple of the areas.

18 We have the materials here, theyre on our website for the 19 public. And the root cause report is also on our website.

20 Its publicly available. So, the information that we 21 rushed through is available.

22 I also want to thank you for your candor. I believe 23 our goals have been achieved for this meeting. And our 24 goals, the NRCs goals were to begin to further understand 25 the Root Cause Assessment. Asking any questions that we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

124 1 have at this point, and begin to further understand your 2 plans for improvement.

3 I want to make it clear that our goal today was not 4 to endorse or accept or approve either of those areas, but 5 simply to further gain some understanding of those areas.

6 You describe the Root Cause thats comprised of four 7 areas. Thats your Root Cause Analysis Report, which we 8 received last month and gave a presentation to us publicly 9 on August 15th of that.

10 Last week, we received the analysis of operations 11 role, as well as the analysis of all the assessment groups 12 role in contribution to this problem at Davis-Besse.

13 And, you told us today that youre finalizing your 14 assessment of the corporate nuclear review groups 15 contribution to the problem. We have not yet received that 16 report.

17 I think this is a good focus. Id just like to, the 18 hardware design of the plant is built upon defensive 19 effort; the organization of the plant is also built upon 20 defensive effort; and your focus in this area is looking at 21 the broad spectrum of operations, organizational 22 improvement, organizational assessment, quality assurance 23 and appropriate review boards is a good approach.

24 You described today your Performance Improvement 25 Program. I think I can speak for the board, that many of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

125 1 the necessary elements are included in your plan. As 2 indicated by our questions today, there is still some 3 issues that are outstanding.

4 I dont want to prejudge by any stretch of the 5 imagination the outcome of our inspection in this area.

6 Geoff described a little earlier, the team that hes 7 leading up. Its a diverse team of experts both from 8 within the organization, the NRC, and outside consultants; 9 and theyre just beginning phase one of their review.

10 Phase one is a review of your root cause assessments 11 in these four areas; one of which we dont have yet, as 12 well as review of the alignment between your Corrective 13 Action Programs and those Root Causes.

14 Phase two and three, which cannot be scheduled yet, 15 cover phase two would be implementation of your Corrective 16 Action Program; observing how you recognize it and how 17 youre monitoring it. And then phase 3 would include our 18 assessment of your performance in this area. So, not only 19 watch your implementation, but performing these 20 assessments.

21 As weve heard today, several of your improvement 22 initiatives are just beginning; several are still in the 23 formative stages. The fact that youre doing Safety 24 Conscious Work Environment Evaluations is good. Thats 25 very important.

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126 1 The results, quite frankly, of the survey are 2 sobering. Less than four out of ten of your people believe 3 that senior management cares more about safety than 4 schedule. Less than half of your people have confidence in 5 Corrective Action Program. And only six in ten believe 6 that your ombudsman is effective. Thats not good news.

7 Its news that you need, but its not good news.

8 During these kinds of discussions, were always at 9 risk of losing focus on what the real issue is. We talk in 10 terms of management improvement, organization; and were at 11 risk of forgetting that all of this is people. Whether 12 theyre managers, supervisors or workers, theyre all 13 people.

14 Rarely have I seen a program that was not a good 15 program. Programs dont cause improvement. Programs dont 16 result in good performance. Its people that result.

17 Your challenge is substantial. Your challenge is to 18 get into the hearts and minds of the people at every level 19 of your organization. You must use the word, vertical 20 alignment. Thats an excellent concept. You need to have 21 vertical alignment and safety as your principle focus.

22 Youre clearly not there yet.

23 Every day, when each of those people comes through 24 the gate, at the start of the workday, safety has to be 25 their principle focus. If its not, quite frankly, they MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

127 1 dont belong in any part of this.

2 Your approach in the past, based on the information 3 we received today, I believe your approach in the past 4 should result in improvement. I want to emphasize, youre 5 just beginning. Your efforts are just starting to have 6 coherence. Theyre just starting down a path that should 7 bring results.

8 The issues that weve discussed today are key 9 issues. These are the root causes of what happened over 10 the last several years, that resulted in the degradation of 11 the head, resulted in your failure to identify cracks. And 12 as your finding now through all your discovery efforts, 13 resulted in a number of other issues.

14 They must be fixed before this panel will be 15 satisfied that its able to recommend to NRC Senior 16 Management that Davis-Besse can be restarted and operated 17 safely.

18 In addition to all of the effort that we are putting 19 in, we will be putting in assessing the readiness of the 20 hardware. Were going to be putting in a substantial 21 effort in monitoring your performance in this area.

22 With that, Christine, I would suggest that we 23 probably want to take a brief recess.

24 MS. LIPA: Right, five 25 minutes.

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128 1 (Off the record.)

2 MS. LIPA: What were going 3 to do now is start the Q and A session. An important part 4 of todays meeting will be questions and comments from 5 members of the public. This portion of the meeting is to 6 allow members of public to ask questions of us, the NRC, 7 before this meeting is adjourned.

8 Also the questions, statements and answers will be 9 transcribed for future reference. We would like to 10 establish some ground rules. What were going to do is 11 start with public in here in the room, local members of the 12 public first and public officials, and then well go to 13 other members of the public in this room; and then go to 14 questions from people on the phone lines.

15 We have, we had earlier about 45 people on the phone 16 lines, and Im sure that some of those may have some 17 questions for us.

18 Each speaker should clearly pronounce their name for 19 the transcriber, and then youll be given about five 20 minutes to make a question or comment.

21 So, lets go ahead and begin; if theres anybody in 22 here that has a question, they can come to the microphone 23 and we will be happy to answer a question for you.

24 Any local members of the public or public officials 25 that want to come up and ask a question or make a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

129 1 statement?

2 Are there any other members of the public in the 3 room that would like to come up and ask a question?

4 HOWARD WHITCOMB: Ms. Lipa, 5 gentlemen, my name is Howard Whitcomb. Im a resident of 6 Oak Harbor.

7 As an outspoken individual labeled as a critic, Im 8 sure I have had the criticism myself of being a Monday 9 morning quarterback. To that I will take ownership of that 10 label if thats the case.

11 Mr. Myers isnt here. I did have a comment directed 12 to him. I had an opportunity to review the graphic he put 13 together on the vision, mission and objectives of the 14 company. And I thought it was an excellent job summarizing 15 all that information on one pictorial. So, if you can 16 carry that back to him, thats a compliment. I thought he 17 did a great job on that. And I think hes proud of it as 18 well.

19 MR. ESHELMAN: Certainly.

20 MR. WHITCOMB: In listening to 21 the comments collectively this morning; first of all, Im 22 not here to tear apart FirstEnergys efforts in everything 23 theyve done. Clearly youve done a lot of work; and to 24 your credit, thats a plus.

25 Ive been a resident in this community for 17 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

130 1 years. And Ive had the opportunity to review events as 2 theyve come up in the papers. A lot of you folks are new 3 and dont have the benefit of that historical perspective.

4 Mr. Pearce, I think that youre right on target. I 5 think that there was, or has been a sense at Davis-Besse, 6 all the way back to the beginning of commercial ops in 7 1977, there has been a resistance or reticence on the part 8 of workers to come forward and try to do the right thing.

9 Now, thats not to say theyre bad workers. Thats 10 just to say the environment, the climate in which theyve 11 been operating has been, for whatever reason, adverse in 12 their minds.

13 By your admission, and I agree with Mr. Grobe, even 14 the QA Organization had some, I guess, resistance to 15 independently verify on their own the state of affairs, so 16 they relied on information that was written and did no 17 independent verification. At a QA Organization, certainly 18 you understand that that is a major downfall in the whole 19 process. And, you need to address that.

20 Now, one thing though, I would like to say is this.

21 My major comment is, FirstEnergy has failed today to 22 present any basis or justification as to why this 23 Corrective Action Plan will succeed where prior plans and 24 efforts have failed; particularly the System Review and 25 Test Program that was done in the mid 1980s. And I was MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

131 1 part of that.

2 A lot of what youve identified was identified even 3 at that time, but today, you made a comment about the lack 4 of independent verification. I would like to read to you a 5 statement by a former vice president of this, of Toledo 6 Edison, in response to an inquiry by the NRC as to the 7 completeness of an investigation he was supposed to 8 perform.

9 He states, quote, "If the Senior Vice President says 10 that the wall is brown, why should I ask the cleaning lady 11 what color the wall is." That was in August of 1988.

12 Youre wrestling with problems that have existed 13 since day one. And they havent been addressed.

14 So, my comment is, today, you have failed to provide 15 assurance that your Corrective Action Plan is going to 16 succeed where others have failed. A lot of money was spent 17 in the mid 80s. A lot of money is being spent today.

18 We, the public, want to be confident that what 19 youre doing isnt going to be a repeat performance of 20 whats happened before. Thank you.

21 MS. LIPA: Thank you for your 22 comments, Howard.

23 Does anybody else have any questions for us?

24 BEATRICE MIRINGU: My name is 25 Beatrice Miringu, and I work for Ohio Citizens in Action.

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132 1 I think what you have told us today is the problems 2 that you are experiencing today are more of failing to 3 adhere to regulation and expectant standard from the 4 industry.

5 What concerns me more is if you go back to your 6 slide 59, the percentages that you have on how your 7 employees feel comfortable with what youre doing is very, 8 very low. Now, if your employees dont feel that the 9 Corrective Action Plan is really making any progress, how 10 do we in the community interpret what youre doing?

11 I think you need to demonstrate to us that your 12 Corrective Action Program is doing something, but at this 13 point, I think if your employees dont think that peer 14 issues in CAP prioritize appropriately and investigated 15 thoroughly and that they will be resolved; we in the public 16 would have a higher, a bigger problem understanding that.

17 I also want to suggest that when you make your 18 presentation next time, please set one slide where you 19 explain what all these acronyms mean. That would make it 20 easier for us to follow that.

21 MS. LIPA: Thank you.

22 Anybody else have any questions for us?

23 Okay, well go to anybody on the phonelines that has 24 a question for us. Go ahead.

25 PHONE OPERATOR: The first question MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

133 1 is from Ray of Manchester.

2 SPEAKER1: Thank you. This 3 is my question for the NRC, wondering if you could maybe 4 outline for us what the NRC measures, (inaudible) the 5 standards are that are required?

6 MR. GROBE: I think I 7 understood the question was what are the matrixes that the 8 NRC is monitoring, and how do we -- I believe the question 9 was, what are the matrixes the NRC is monitoring, and how 10 are we going to assess whether or not the company is ready 11 for restart.

12 We dont have a set of matrixes. The company is 13 developing performance indicators and matrixes and were 14 going to evaluate those. Most important to the NRC is the 15 results of our inspections. And we have a series of 16 inspections ongoing now and also plan for the future.

17 I believe there is five inspections that are ongoing 18 today; one is into the evaluation of the adequacy of 19 containment equipment that is inside containment; second 20 one has to do with the replacement of the head.

21 As we speak, there is already activities ongoing to 22 repair the hole that had to be cut in the containment 23 structure itself to get the new head into containment and 24 the old one out. So, we have inspectors here observing 25 that.

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

134 1 Weve talked about Geoff Wrights inspection into 2 the Management/Human Performance area. We have another 3 inspection that is headed by an individual named Ken 4 OBrien. Its a team of folks that are looking at program 5 evaluations and program effectiveness.

6 And another inspection that is also on site this 7 week, headed by Marty Farber, which is looking into the 8 adequacy of systems outside containment.

9 So, there is a series of inspections that are 10 ongoing now. The results of those inspections will 11 contribute to our evaluation of readiness for restart as 12 well as our continuing evaluation of the companys matrix 13 and their performance evaluation.

14 SPEAKER1: Maybe just one 15 follow-up. I guess. (inaudible) 16 MR. GROBE: Did you understand 17 that?

18 MS. LIPA: Were having 19 trouble hearing the question.

20 SPEAKER1: (inaudible) 21 restart, any response to that?

22 MR. GROBE: Could you ask the 23 question one more time? Could you ask the question one 24 more time?

25 SPEAKER1: Sure, can you hear MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

135 1 me?

2 MS. LIPA: Yes.

3 SPEAKER1: The question 4 addresses the company prefers December 7 restart, just how 5 do you respond to that?

6 MS. LIPA: Your question is, 7 the company has established a December 7th restart. And 8 the answer to that question is, the NRC panel has a lot of 9 work to do. Were not driven by the Licensees schedule.

10 So, we have inspections that we have ongoing. We have 11 assessments that we need to make. Were not working to the 12 Licensees schedule. Thats really all I have to say about 13 that.

14 SPEAKER1: Thank you.

15 MS. LIPA: Thank you.

16 Any other questions?

17 PHONE OPERATOR: The next question 18 is from Dan Horner.

19 DAN HORNER: My name is Dan 20 Horner. Im with McGraw Hill Publications. I had a couple 21 questions. First one, to Jack Grobe.

22 You had mentioned early on in the meeting about the 23 issue of arriving from an inaccurate information. I wonder 24 if you could explain how that plays into the restart 25 position, particularly for example, just finally determined MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

136 1 that FENOC provided inaccurate information to NRC, and 2 adversely how that would effect the restart date, if it was 3 found they deliberately provided inaccurate information; 4 would that push the restart date back further or are those 5 processes delayed? What are you going to do about 6 that?

7 MR. GROBE: Okay. Thank 8 you. That was Dan Horner from McGraw Hill. He asked the 9 question, regarding inaccurate records, and inaccurate 10 information provided outside the company, how the NRCs 11 assessment of that might impact on restart.

12 The NRC has requirements at 10 CFR 50.9 that those 13 requirements, there is two of them. One is that, records 14 are required to be kept by the NRC -- Im sorry, required 15 by the NRC to be kept by the company. Have to be complete 16 and accurate, and submissions, and information provided by 17 the company to the NRC has to be complete and accurate.

18 And the results of the AIT follow-up, thats the 19 Augmented Inspection Team Follow-up Inspection that was 20 completed several weeks ago, indicated that there were 21 violations in both of those requirements. That there were 22 records that were required to be kept by the company that 23 were not accurate, and that there were, there was 24 information and submissions to the NRC from company that 25 were not accurate.

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

137 1 Those issues have to be fixed prior to restart; and, 2 thats an issue that the, corrective actions for which 3 well be evaluating going forward.

4 The second part of Dans question was whether, if 5 the NRC concludes that any of those violations were 6 deliberate, what actions would be taken.

7 At this point, we have an ongoing investigation into 8 a number of issues that are, that occurred over the last 9 several years; and I wouldnt want to speculate on the 10 results of that. And based on the results of that 11 investigation, appropriate actions, regulatory actions will 12 be proposed.

13 So, its much too early to focus on that issue, 14 because we dont have the results of the investigation.

15 DAN HORNER: When you say we 16 had investigated it, you mean specifically, you talking 17 about the OI investigation?

18 MR. GROBE: No, I apologize 19 for not being clear. When I said we, I meant the Nuclear 20 Regulatory Commission. The 0350 Panel does not do 21 investigations. The NRC Office of Investigations looks 22 into matters that might potentially have been more than 23 just mere errors or mistakes by people, that might have 24 been willful. And the Office of Investigations has an 25 investigation into a variety of issues at Davis-Besse MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

138 1 ongoing at this time.

2 The panel will receive the results of that 3 investigation when its completed. And the panel will 4 evaluate the results of that investigation, and make 5 whatever recommendations it believes are appropriate for 6 action to be taken by the agency.

7 DAN HORNER: The investigation 8 conducted by OI, the 0350 Panel, will receive those results 9 and they will not make conditions on restart until they 10 receive information from OI; is that correct?

11 MR. GROBE: I believe I 12 understood your question, Dan, was whether or not the panel 13 has received information from OI, and the results of its 14 investigation, and it has not. OI has not completed their 15 investigation.

16 DAN HORNER: Im sorry, there 17 must have been a sound problem. My question was, does the 18 O350 Panels decision on restart, can an 0350 Panel make a 19 decision on restart without having received the information 20 of OI, or is this information from OI going to be a factor 21 in the decision on restart?

22 MR. GROBE: Its our current 23 plan that we receive the investigation results and 24 determine what actions may be appropriate prior to 25 restart. And I emphasize thats our current plan.

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

139 1 DAN HORNER: Okay. I have 2 another question for one of the representatives of FENOC, 3 if I could. I obviously cant see whos on the panel. I 4 understood from the conversation, Mr. Myers has left. But, 5 I believe at the beginning, you talked about the 6 importance, of the process, of going to address problems, 7 or going to take necessary measures to address problems, 8 emphasizing sort of the need to address these problems down 9 the road.

10 I wonder how that squared with what seems to be a 11 very aggressive schedule made out yesterday for restart on 12 December 4th. So, if could you explain how those two 13 statements fit together.

14 MR. GROBE: Dan, the purpose 15 of this question and answer period is for you to provide 16 comments to us, or ask questions of the NRC staff. Thats 17 actually a fairly complicated question, and I would suggest 18 that you contact FirstEnergy separately if that would be 19 okay.

20 DAN HORNER: Okay, thank you.

21 MS. LIPA: Any other 22 questions?

23 PHONE OPERATOR: No other 24 questions at this time.

25 MS. LIPA: Okay, thank you.

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140 1 Any other questions in the room here, before we 2 close?

3 PAUL RIDZON: Im Paul Ridzon.

4 Jack said you wanted documentation problems cleared up 5 before restart. Would that be a retroactive or just you 6 want to see things, the process cleaned up going forward?

7 MR. GROBE: I apologize for 8 not being clearer. What I meant to say, was that Licensee, 9 we expect the Licensee to correct violations, this is 10 violations of NRC requirements. Well be evaluating the 11 corrective actions for those violations. That would 12 include, I believe, correcting the specific violations, as 13 well as taking action to prevent recurrence in the future.

14 So, those would be the things that we expect to see prior 15 to restart.

16 PAUL RIDZON: Just a question to 17 FENOC. Could you give some light, I believe you said the 18 participation in the survey was about one third. Was that 19 just the most recent or was that kind of all of them, going 20 back to 99?

21 MR. PEARCE: I dont know the 22 percentage of respondents past, the most recent survey, but 23 I can find that out for you and give you that information 24 the next meeting that we have.

25 PAUL RIDZON: Thank you.

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141 1 MS. LIPA: Anybody else have 2 any questions?

3 Any other questions?

4 Okay. I would like to thank you all for coming 5 today; and, the results of this will be, the transcript 6 will be on our web page in a couple weeks.

7 Thank you.

8 (Off the record.)

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

142 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 30th day of September, 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