ML030150732

Firstenergy Nuclear Operating Company (Fenoc), Revision 5 of Davis-Besse Unit 1, Return to Service Plan & Ten Other Associated Restart Plans

ML030150732
Person / Time
Site:	Davis Besse
Issue date:	01/09/2003
From:	Myers L FirstEnergy Nuclear Operating Co
To:	Dyer J Region 3 Administrator
References
1-1300
Download: ML030150732 (227)

Text

FENOC F O5501 North State Route 2 FirstEnergyNuclear OperatingCompany Oak Harbor,Ohio 43449 Lew W. Myers 419-321-7599 Chief Operating Officer Fax: 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1300 January 9, 2003 Mr. J.E. Dyer, Administrator United States Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351

Subject:

Transmittal of Revision 5 of the Davis-Besse Nuclear Power Station Unit 1, Return to Service Plan and ten other associated restart plans Ladies and Gentlemen:

The purpose of this letter is to transmit Revision 5 of the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS) Return to Service Plan and ten other associated restart plans.

Revision 5 of the Return to Service Plan supercedes all previous revisions in their entirety. However, it continues to accomplish the original objectives and reflects the current revision of the Building Block Plans and development of implementing procedures. The Return to Service Plan describes the DBNPS course of action for a safe and reliable return to service. This course of action includes those actions necessary to address each of the six issues identified in the Confirmatory Action Letter (CAL), the near-term corrective and preventive actions necessary to address the causal factors associated with the reactor head degradation event, and the longer-term actions necessary to assure that the underlying causal factors remain corrected and that improved performance at the DBNPS is sustained.

No commitments are identified in the attached Return to Service Plan or the ten other associated restart plans. A table of contents summarizing the plans that are being transmitted with this letter is also included. Also, it should be noted that FirstEnergy Nuclear Operating Company may periodically update the attached plans in the future, as necessary.

If you have any questions or require further information, please contact Patrick J.

McCloskey, Manager-Regulatory Affairs, at (419) 312-8450.

Sincerely, GH/...o. r/erS GH/s

. I6

Attachments cc: USNRC Document Control Desk J.B. Hopkins, DB-1 NRC/NRR Senior Project Manager S.P. Sands DB-1 NRC/NRR Backup Project Manager C.S. Thomas, DB-1 Senior Resident Inspector Utility Radiological Safety Board

Davis-Besse Return to Service Notebook Table of Contents Return to Service Plan Revision 5 January 9, 2003 Nuclear Quality Assessment of Return to Service Plan Revision 3 September 23, 2002 Restart Action Plan Revision 4 January 7, 2003 Restart Overview Panel Charter Revision 2 December 3, 2002 Containment Health Assurance Plan Revision 6 November 1, 2002 Reactor Head Resolution Plan Revision 1 July 10, 2002 Program Compliance Plan Revision 4 September 24, 2002 Systems Health Assurance Plan Revision 5 December 6, 2002 Management and Human Performance Excellence Plan Revision 3 January 7, 2003 Management and Human Performance Improvement Plan Revision 0 September 5, 2002 Restart Test Plan Revision 2 January 9, 2003 TOC Date: January 9, 2003

Attachment 1 Return to Service Plan Revision 5 January 9, 2003

Davis-Besse Nuclear Power Station Return to Service Plan

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DAVIS-BESSE RETURN TO SERVICE PLAN Revision: 5 Date: January 9,2003 Approvals:

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Table of Contents Summ ary of Revision Changes ................................................................................................... 2 I. Introduction and Purpose ................................................................................................ 3 II. Restart Organization ....................................................................................................... 4 III. Nuclear Quality A ssessm ent Oversight ............................................................................ 5 IV . Building Blocks .......................................................................................................... 5 A . Reactor H ead Resolution Plan ............................................................................ 6 B. Containm ent Health A ssurance Plan .................................................................. 8 C. System Health A ssurance Plan ............................................................................ 9 D . Program Com pliance Plan ...................................................................................... 11 E. Management and Human Performance Excellence Plan .................................... 12 F. Restart Test Plan ............................................................................................... 14 G. Restart Action Plan ............................................................................................ 14 V. Confirm atory Action Letter Status ................................................................................. 16 VI. Conclusions ......................................................................................................................... 19 Figures:

1. Davis-Besse Restart Building Blocks ....................................................................... 20

2. Restart Organization ................................................................................................ 21 Appendix:

1. Correlation of Causal Factors versus Restart Building Blocks ................. 22 Page 1 of 25 Revision 5 January 9, 2003

Summary of Revision Changes Revision 5 Section II: Revised the Restart Overview Panel description to match the intent of the Restart Action Plan.

Section IV: Building Blocks Editorial change to the reference to the Vice President - Oversight for consistency.

Item C:. System Health Assurance Plan:

Wording in the Charter portion was changed to reflect the wording in Revision 3 of the Building Block Plan. In the System Health Readiness Reviews portion, the wording was revised to reflect the changes made in Revision 3 to the System Health Assurance Plan. Minor editorial changes were made to the Latent Issues Review section.

Item E: Management and Human Performance Excellence Plan Changes were made to the charter and description of this plan to reflect the changes made to Revision 3 of this Building Block Plan.

Item F: Restart Test Plan Changes were made in the charter portion of this section to match the wording in Revision 2 to this Building Block Plan.

Section V: Confirmatory Action Letter Status The status of Items 1, 3, 4, 5, and 6 in this section.

Figure 2: Deleted "Restart" from the block referencing "Restart Senior Management Team."

Page 2 of 25 Revision 5 January 9, 2003

I. Introduction and PurDose Between March 6 and March 10, 2002, as a result of inspections conducted pursuant to NRC Bulletin 2001-01, "Circumferential Cracking of Reactor Vessel Head Penetration Nozzles,"

Davis-Besse Nuclear Power Station (Davis-Besse) management informed the Nuclear Regulatory Commission (NRC) of the presence of a large cavity in the Reactor Pressure Vessel (RPV) Head adjacent to a control rod drive nozzle. On March 13, 2002, the NRC issued a Confirmatory Action Letter (CAL) identifying six sets of commitments that the FirstEnergy Nuclear Operating Company (FENOC) will meet to address the conditions associated with degradation of the RPV Head prior to restart of the reactor, including meeting with the NRC to obtain approval for restart. The CAL was subsequently revised on May 15, 2002, to reflect the use of a replacement RPV Head.

Prior to this point, the Davis-Besse plant had good operational performance. All NRC reactor oversight cornerstones were GREEN. Previous Institute of Nuclear Power Operations (INPO) evaluations also showed no significant weaknesses, with generally improving trends.

This Return to Service Plan describes Davis-Besse's course of action for a safe and reliable return to service. This course of action includes those actions necessary to address each of the six sets of commitments in the CAL, the near-term corrective and preventive actions necessary to address the causal factors associated with the RPV Head degradation event, and the longer term actions necessary to assure that the underlying causal factors remain corrected and that continued safe performance at Davis-Besse is sustained. In addition, the root cause related to management not promptly identifying the degradation of the RPV Head will be corrected.

The near-term actions necessary to support restart are included in the Davis-Besse Inspection Manual Chapter (IMC) 0350 Restart List and will be discussed in an Integrated Restart Report, which will demonstrate that Davis-Besse is ready for restart and request NRC approval of restart and closure of the commitments in the CAL. The longer term, post-restart actions will be evaluated for incorporation into the Business Plan and/or the regulatory commitment management system.

This Plan consists of seven Building Blocks, designed to support safe and reliable restart of the plant and to ensure sustained performance improvements:

A. Reactor Head Resolution Plan B. Containment Health Assurance Plan C. System Health Assurance Plan D. Program Compliance Plan E. Management and Human Performance Excellence Plan F. Restart Test Plan G. Restart Action Plan Formal plans have been developed for each of the seven Building Blocks, along with implementing procedures and action plans where appropriate. These plans are available for Page 3 of 25 Revision 5 Tan"nrx

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NRC review. Status of the implementation of these plans is being discussed monthly in public meetings with the NRC IMC 0350 Panel, demonstrating Davis-Besse's performance.

Davis-Besse management is being deliberate and conservative in implementing the Return to Service Plan and will not return the Station to service until it is satisfied that the Station can be returned to power and operated safely and reliably over the long-term. FENOC senior leadership is directly involved in the direction and oversight of Davis-Besse's return to service.

A Restart Overview Panel, which includes independent industry experts, is providing additional oversight and review of plant activities discovered or performed as part of the Return to Service Plan Building Blocks.

I. Restart Organization The following are the key elements of the restart organization:

" A new Chief Operating Officer position has been established and is assigned to provide corporate direction and oversight of the Return to Service Plan.

" A new Executive Vice President - Engineering and Services position has been established to provide corporate direction and oversight of engineering activities under the Return to Service Plan.

" A new Vice President of Oversight position has been established to assess the quality of Building Block and restart activities.

" Building Block Teams (Figure 1) have been established to address the causal factors associated with the RPV Head degradation.

" A Restart Overview Panel has been established, consisting of FENOC executive management to provide an independent oversight of implementation of the Return to Service and Building Block Plans.

" An Engineering Assessment Board has been established to review products generated under several of the Building Blocks.

" A Senior Management Team has been established, consisting of the FENOC Chief Operating Officer, the Plant Manager, the Directors of Nuclear Engineering, Support Services, and Work Management, and independent oversight. The Senior Management Team is chartered to provide senior management review and oversight of restart activities.

" A Restart Station Review Board has been established, consisting of the Director of Support Services, site managers, and independent oversight, chartered to identify and classify items to be included in the Restart Action Database through a review of Condition Reports, Corrective Actions, and other documents.

Figure 2 depicts the restart organization and its relationship to the building blocks.

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III. Nuclear Ouality Assessment Oversight Davis-Besse (DB) Nuclear Quality Assessment (NQA), reporting to the Vice President of Oversight, provides oversight and verifies the adequacy of activities conducted as part of the Return to Service Plan. This will be performed by assessing key activities such as: review board meetings; in-depth technical review of engineering products; field verification of actual conditions pre- and post-remediation; and independent reviews paralleling those performed by the line organization. Specific activities are selected for review based on their safety and risk significance to provide reasonable assurance that Return to Service Plan activities are performed in a quality manner. Details regarding the activities to be verified are included in the Nuclear Quality Assessment Oversight of Davis-Besse Return to Service Plan.

NQA oversight is conducted using FENOC procedure NOP-LP-2004, Internal Assessment Process. As described in this procedure, the Quality Field Observation database will be used to document the results of these assessments. Findings and recommendations shall be documented on Condition Reports (CRs) and processed in accordance with FENOC procedure NOP-LP-2001, Condition Report Process. NQA will use the established process and develop a separate Quality Field Observation to document the overall NQA conclusion for each building block.

Assessment Team Leaders are certified in accordance with Davis-Besse procedure NA-QA-07006, Certification of Lead Auditor Personnel. Assessment team members, including technical specialists, receive training orientation in accordance with FENOC procedure NOP LP-2004, Internal Assessment Process.

IV. Building Blocks Each of the BuildingBlocks has been assigned an Owner and/or an individual responsible for Senior Oversight.

Block Owner Oversight Reactor Head Resolution E. David Baker Robert W. Schrauder Plan Containment Health Timothy J. Chambers J. Randel Fast Assurance Plan System Health Assurance Joseph W. Rogers James J. Powers, Plan Program Compliance Plan Neil A. Morrison James J. Powers Management and Human Lew W. Myers N/A Performance Excellence Plan Restart Test Plan Anthony R. Stallard J. Randel Fast Restart Action Plan Clark A. Price Lew W. Myers Page 5 of 25 Revision 5 January 9, 2003

Each of the plans for the first six Building Blocks identifies those actions that must be accomplished before restart under that plan. The Restart Action Plan, which is the seventh building block, describes the process for classifying restart items. An internal manager-level committee, the Restart Station Review Board, reviews corrective action documents and other documents to identify issues that need to be resolved prior to restart to ensure the safe operation of the plant. In accordance with the Restart Action Plan, this board determines what actions can be taken post-restart and which are added to the Restart Action Database. This database consists of the Davis-Besse Restart Action List and the Davis-Besse IMC 0350 Restart List.

The membership of the Restart Station Review Board consists of the Director- Support Services, manager-level employees, and independent oversight. The board chairman and alternate chairman are designated by the Vice President - Nuclear.

When viewed collectively, the Building Blocks address the causal factors identified in Chapters 5, 6, and 7 of the Davis-Besse Root Cause Analysis Report, originally submitted to the NRC on April 18, 2002. Revision 1 to the Davis-Besse Root Cause Analysis Report was submitted to the NRC on September 23, 2002. Appendix 1 provides a matrix which correlates the Building Block actions to the causal factors identified by FENOC and the corresponding causes and missed opportunities identified in the NRC's AIT Report.

The Management and Human Performance Excellence Plan includes actions to extend and deepen the analyses of causal factors in the Root Cause Analysis Report. This includes an in depth review, under the leadership of the new Vice President-Oversight, using formal root cause analysis tools to determine why indicators present before 2002 did not result in detection and resolution of the RPV Head degradation. This Management and Human Performance Root Cause Analysis Report was submitted to the NRC on August 21, 2002.

FENOC Nuclear Quality Assessment will monitor and sample each Building Block prior to restart. The Vice President-Oversight is a member of the Restart Overview Panel. A brief summary of the major elements of the actions and approach for each Building Block follows.

A. Reactor Head Resolution Plan Charter: Restore the degraded Davis-Besse RPV Head such that it is in full compliance with appropriate Commission rules and industry requirements.

During the Davis-Besse 13th Refueling Outage (13RFO), an inspection of the Reactor Pressure Vessel (RPV) Head nozzles was performed pursuant to NRC Bulletin 2001-01, "Circumferential Cracking of Reactor Vessel Head Penetration Nozzle." Extensive corrosion of the RPV Head was identified during this inspection that required either major repairs or replacement of the RPV Head. Condition Reports were written and a Root Cause Analysis was prepared.

FENOC has made the decision to replace the degraded RPV Head with an unused one from the canceled Midland Nuclear Power Plant. The replacement RPV Head is a Babcock and Wilcox design, and with minor modifications, can satisfy the applicable Nuclear Regulatory Commission (NRC) rules and industry requirements.

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The major attributes of this Plan include:

"* Procurement and Certification of the replacement RPV Head. Non-Destructive Examinations (NDE) were performed to confirm that the replacement RPV Head is suitable for use.

"* Minor RPV Head modifications, to ensure that the replacement RPV Head fits the Davis-Besse reactor. Inspection holes have been added to the Service Structure for more effective inspections.

"* Temporary fuel removal from the reactor and subsequent refueling.

"* Access to the Davis-Besse Containment for removal of the original RPV Head and placement of the new RPV Head on the RPV Head Stand.

"* Installation of replacement RPV Head, including transfer of existing Service Structure and transfer of existing CRDM to the new RPV Head.

"* Restoration, testing, and inspection of the RPV Head and Containment.

"* Storage and/or disposal of original Davis-Besse RPV Head.

"* Updating the Design and Licensing Basis Documents.

A temporary access opening was made in the Davis-Besse Containment vessel and shield building, allowing for the removal of the original RPV Head to its temporary storage location, and the transfer of the replacement RPV Head into the Containment building. The shield building and Containment vessel at Davis-Besse was restored to meet design requirements. An Integrated Leakage Rate Test (ILRT) will be performed to verify Containment integrity.

The degraded RPV Head is being temporarily stored at Davis-Besse. Final plans for permanent storage or disposal are under development.

Bechtel provided engineering services for the RPV Head replacement, including overall project management, detailed engineering, licensing support, quality assurance, and project controls.

Framatome-ANP was responsible for procurement and certification of the replacement RPV Head, including modifications to the RPV Head as required, providing a Certificate of Conformance documenting that the replacement RPV Head is suitable for use at Davis-Besse, and providing engineering and required evaluations to ensure the Davis-Besse design and licensing requirements are met (including ASME Code criteria).

The RPV Head replacement is a modification to the facility and is being performed in accordance with the provisions of 10 CFR 50.59 criteria. Completion of this modification will resolve the issue concerning boric acid corrosion degradation of Davis Besse's RPV Head, including disposition of the associated corrective actions, and performance of more effective periodic head inspections allowing for early detection of RPV Head degradation due to the increased size of the inspection holes. This will enable Davis-Besse to return to safe and reliable operation.

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B. Containment Health Assurance Plan Charter: Perform inspections and evaluations of Containment Systems, Structures and Components (SSCs) and assure completion of required remediation activities prior to restart. This will ensure that the condition of Containment supports safe and reliable operation. This will be accomplished by using qualified inspectors and evaluators.

Remediation will be taken, as necessary, to correct the conditions of the following:

V Boric Acid induced degradation sites

" Containment Vessel

" Containment Coatings

" Containment Emergency Sump

/ Decay Heat Removal Valve Pit V Alloy 600 Material

,/ Primary Water Stress Corrosion Cracking indications V Threaded and Bolted Connections V Fuel Reliability V Refueling Canal V Environmentally Qualified and Non-Environmentally Qualified Equipment The purpose of the Containment Health Assurance Plan is to perform inspections and evaluations of Containment SSCs and assure completion of required remediation activities prior to restart. To support this plan, an organization has been put into place to manage and implement activities, provide oversight, and provide the communications interface with external organizations.

The plan is focused on the extent of Primary Water Stress Corrosion Cracking of Alloy 600 welds in the Reactor Coolant System, and identifying damage that may have resulted from boric acid leakage and dispersion of boric acid in the Containment Building. The plan scope has been expanded to assess the adequacy or to improve the design of several areas based on input from team members, operating experience reviews, and internal and external oversight. These areas include the Containment Emergency Sump, Decay Heat Removal Valve Pit, Containment Vessel Pit, the Containment Vessel liner, the refueling canal, fuel reliability, and effects of boric acid on Environmentally Qualified (EQ) and non-EQ equipment, and Containment coatings.

Action plans for each of these focus areas direct the actions necessary to meet the objectives of this plan. FENOC is using industry experts to assist in evaluating these focus areas and developing needed corrective actions or modifications.

Procedures, Work Orders, and Condition Reports are used to control field activities.

Inspectors attend training for specific procedures and work orders prior to implementing field activities. This training standard was selected to ensure all inspectors are gathering data with similar, thorough standards and quality attributes. The rigor employed in the development and implementation of the Containment Health Assurance Plan in conjunction with the verification activities being performed by FENOC, provides assurance that the Containment (as a whole) and the individual areas specified will be restored to the condition necessary to support safe, reliable operation.

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C. System Health Assurance Plan Charter: Perform reviews of system health prior to restart to ensure that the condition of the plant is sufficient to support safe and reliable operation. Three levels of system reviews will be performed. An Operational Readiness Review of systems important to the safe and reliable operation of Davis-Besse was performed. A System Health Readiness Review of all Maintenance Rule risk significant systems not covered by the more extensive Latent Issue Review process will be performed. Latent Issues Reviews of the Reactor Coolant, Emergency Diesel Generators, Auxiliary Feedwater, Component Cooling Water, and Service Water systems will be performed to identify any latent issues, and to provide reasonable assurance that these systems can perform their safety and accident mitigation functions.

The purpose of this program is to perform reviews of system health prior to restart to ensure that the condition of the plant is sufficient to support safe and reliable operation.

This will be accomplished using the following 3-step approach, an Operational Readiness Review, System Health Readiness Reviews, and Latent Issues Reviews.

Other measures that will help ensure the success of the Davis-Besse System Health Assurance Plan are listed below:

" A substantially new Davis-Besse management team with a demonstrated track record is in place.

"* The FENOC Engineering Principles and Expectations were issued on July 10, 2002, and these new principles and expectations have been communicated to the system review team members.

"* An Engineering Assessment Board was implemented on June 28, 2002. This board, largely made up of outside experts with proven high standards, will independently review selected products from the system reviews to ensure technical adequacy.

1. Operational Readiness Reviews The Operational Readiness Review is complete and was performed to identify whether systems have significant shortcomings, and to initiate immediate actions to correct those problems. These reviews were initiated prior to entry into the IMC 0350 process.

Systems for review were selected considering system performance relative to the Maintenance Rule performance criteria, materiel condition, and operator burdens. The reviews were performed under the direction of the Plant Manager and included representatives from various site organizations.

2. System Health Readiness Reviews System Health Readiness Reviews will be performed on all risk significant Maintenance Rule systems. These reviews are more thorough than the Operational Readiness Reviews. These reviews are focused to provide reasonable assurance that these systems can perform their risk significant maintenance rule functions. These reviews include identification of the system's risk significant functions, reviews of testing or review of other information (like trending data) that assesses the system's Page 9 of 25 Revision 5 January 9, 2003

ability to support the system risk significant functions, walkdowns, and reviews of selected data sources. Problems identified during the reviews will be captured in the CR process. The Restart Station Review Board will review all CRs for restart requirements.

The original scope was described as selected Maintenance Rule and Technical Specification systems. Further evaluation has resulted in clarifying the scope of the reviews to include all Maintenance Rule Risk Significant systems not covered by the more extensive Latent Issue Review process. This is a risk-based approach that focuses plant resources in the highest risk areas. By performing these reviews on the identified systems, issues can be corrected that could potentially impact a system's ability to perform its risk significant maintenance rule functions.

Additionally, these reviews may identify programmatic issues that could impact other less risk significant systems and functions. As these programmatic issues are identified, CRs will be initiated and evaluations will be performed to determine if additional System Health Readiness Reviews should be performed. The Plant Manager will have final approval of all reports.

3. Latent Issues Reviews Latent Issues Reviews of the Reactor Coolant System, Auxiliary Feedwater System, Emergency Diesel Generators, Service Water, and Component Cooling Water systems will be performed prior to restart. The five systems selected for Latent Issues Reviews include three systems (Reactor Coolant, Auxiliary Feedwater, and Emergency Diesel Generators) with identified weaknesses and two systems (Component Cooling Water and Service Water) chosen based on their importance. The primary focus of these reviews is to provide reasonable assurance that these systems can perform their safety and accident mitigating functions. These reviews will be comprised of three major efforts. These efforts are the assessment of system attributes, review of various data sources, and walkdowns.

The collective significance of problems identified during the Latent Issues Review will be evaluated to determine if further actions are required. Problems identified during the reviews will be captured in the CR process. The Restart Station Review Board will review all CRs for restart requirements.

The Plant Engineering Manager and the EAB will review and approve the Latent Issues Review Report for each system.

The list of systems that will not have a System Health Readiness Review or a Latent Issues Review performed is included in the System Health Assurance Plan. A matrix that compares the various documentation/data sources that will be made available for review for the Operational Readiness Reviews, System Health Readiness Reviews, and Latent Issues Reviews, is also included in the Building Block Plan.

Inspections will also be conducted to look for evidence of boric acid leakage and degradation on systems outside of containment. These inspections will be performed as part of the System Health Assurance Plan. In addition to the materiel condition Page 10 of 25 Revision 5 January 9, 2003

walkdowns being performed during the System Health Readiness Reviews and the Latent Issues Reviews, a separate boric acid inspection of systems outside of containment will be performed in accordance with procedure EN-DP-01506, Borated Water System Inspections (Outside Containment).

D. Proaram Compliance Plan Charter: Perform a review of applicable plant programs to ensure that the programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support the restart and safe operation of the Davis-Besse Nuclear Power Station. Prior to restart, perform Phase 2 detailed systematic reviews of the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, Radiation Protection Program, and the Operating Experience Program. Prior to restart, perform Phase 1 baseline assessments of applicable plant programs.

NOTE: Nuclear Quality Assessment will be assessed utilizing the Phase 2 methodology, but this assessment will be conducted independent of this plan.

Program weaknesses were a major contributor to the degradation of the Reactor Pressure Vessel Head. The program weaknesses identified are:

"* Standards

"* Ownership

"* Oversight Programs to receive a Phase 2 review, as described below, are identified in the Program Compliance Building Block Plan. Each of these programs will be reviewed over the next two years. The programs identified as contributing to the degradation of the Reactor Pressure Vessel Head are: the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, and the Operating Experience Program. The Radiation Protection Program will also receive a Phase 2 review.

The plan review process will use a two-phase approach.

Phase 1- Program Readiness Baseline Assessment Phase 1 performs a baseline assessment of applicable plant programs to determine if the programs are in a condition to support the restart and safe operation of Davis-Besse.

The programs to receive a Phase 1 assessment are identified in the Program Compliance Building Block Plan. (Exceptions include the Probabilistic Safety Assessment, Boric Acid Corrosion Control, Inservice Inspection, Plant Modification, Corrective Action, Radiation Protection Program, and Operating Experience programs that will receive a detailed review prior to restart). The program owner assesses the program by completing a standardized questionnaire. The program owner then presents the results of the assessment to a Program Review Board, which includes independent, external personnel. The Program Review Board reviews the program utilizing a screening form.

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Condition Reports (CRs) will be generated to document program deficiencies. The Restart Station Review Board will review all CRs for restart requirements.

Phase 2 - Detailed Program Reviews Phase 2 is an integral part of the long term comprehensive Management and Human Performance Excellence Plan. This phase is an in-depth systematic review of the programs, which are identified in the Program Compliance Building Block Plan. This process evaluates programs in depth to ensure that the programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support the restart and safe operation of Davis-Besse. Phase 2 reviews will be completed prior to restart for the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, Radiation Protection Program, and the Operating Experience Program. The Probabilistic Safety Assessment (PSA) was evaluated as a pilot for the review process. Condition Reports (CRs) will be generated to document program weaknesses and recommendations. The Restart Station Review Board will review all CRs for restart requirements.

E. Management and Human Performance Excellence Plan Charter: Conduct a thorough assessment of the management and organizational issues surrounding the degradation of the reactor head.

Create a comprehensive leadership and organizational development plan for the site, which includes actions to be taken prior to and after restart. This plan will include actions to be taken prior to and after restart.

A concise summary of the issue that led to the Davis-Besse RPV Head degradation is as follows:

Managementineffectively implementedprocesses, and thusfailed to detect and addressplantproblems as opportunitiesarose.

Using data from all the root cause reports associated with the head degradation, and other related assessments, the primary management contributors to this failure can be grouped into the following areas:

"* Nuclear Safety Culture

"* Management/Personnel Development

"* Standards and Decision-making

"* Oversight and Assessments

"* Programs/Corrective Action/Procedure Compliance Several program compliance and program implementation failures were identified in the Root Cause Reports, including inadequate implementation of the Corrective Action Program. The actions to address the program and implementation issues are being addressed by actions in this plan as well as actions from the Program Compliance Building Block. Actions will be initiated from the Management and Human Performance Improvement Plan to develop the proper focus, behaviors and teamwork Page 12 of 25 Revision 5 January 9, 2003

throughout the entire organization. These actions will consist of restart actions and actions to be taken after restart.

The ultimate objective of the Building Block activities is to achieve and sustain excellence in the operation of Davis-Besse. The overall goal of this Building Block is to initiate a substantive and demonstrative change in Davis-Besse management.

FENOC realizes that achievement of this goal will take time, and not all will be accomplished prior to restart. The Building Blocks will ensure strong corrective actions are in place for restart, however, many actions must continue for the plant to have sustained performance. FENOC's goal prior to restart is to ensure that the plant, programs, and organization are sufficient to support safe and reliable operations.

Performance indicators monitoring the effectiveness of the actions taken will be used to demonstrate and track the desired changes needed for restart. Longer term corrective actions such as system reviews, program reviews, and implementation of the Leadership in Action principles will continue well after restart.

In accordance with the Program Compliance Plan building block activity, the plant programs will be assessed for proper management Ownership, Standards, and Oversight. The Program Compliance Plan performs a baseline assessment of applicable plant programs, as well as a more detailed program review for selected programs. Long term, follow-up assessments of the programs will be performed using the same criteria, and the resultant program health will be communicated through specific program indicators.

Reviews of specific departments will be done by way of Functional Area Reviews.

These reviews will be performed in selected areas in order to assess restart readiness.

Long term monitoring and indicator presentation of specific area or section health will be performed through the self-evaluation process.

The Management Observation Program will be used to monitor worker behaviors, performance, and plant conditions. This program will be updated to schedule management observations to monitor effectiveness of work activities and worker behaviors.

Review boards, such as the Corrective Action Review Board and the Engineering Assessment Board will be used to monitor various work products for appropriate standards. Performance indicators will be used to monitor resultant quality.

A Management Monitoring Process will be used to monitor and trend the performance of specific management oversight activities taken on an individual basis. These will demonstrate the level of involvement of individual managers.

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F. Restart Test Plan Charter: Perform Restart Testing necessary to ensure the integrity of the Reactor Coolant System and the Containment Pressure Vessel, and to evaluate proposed testing of systems and components affected by RCS leakage and boric acid deposits. In addition, develop an Integrated Restart Procedure to ensure that proper sequencing of required restart activities are accomplished prior to mode ascension. Provide operator training on this procedure to ensure that this infrequently performed test/evolution is conducted in a safe, controlled manner.

This plan has four key elements to ensure that comprehensive testing is performed prior to and during restart, and that restart activities have been completed to ensure the Davis Besse Nuclear Power Station is in a condition to support sustained safe and reliable operation. These elements include:

" Testing the Reactor Coolant System (RCS), including components within the Reactor Coolant Pressure Boundary (RCPB) and associated piping exposed to full RCS pressure, to ensure integrity following replacement of the Reactor Pressure Vessel Head and maintenance of RCS piping and components. The leakage inspections include the reactor vessel head Control Rod Drive nozzles and the reactor bottom incore nozzles.

" Testing the Containment by performing an Integrated Leakage Rate Test in accordance with 10CFR50, Appendix J (Type A test) to ensure the integrity of containment following restoration of the containment pressure vessel.

" Evaluating the adequacy of proposed post-maintenance and post-modification testing on systems and components affected by RCS leakage and boric acid deposits and to determine if additional testing is required.

" Developing an Integrated Restart Procedure to ensure required restart activities, tests, and inspections have been performed prior to mode ascension.

The Integrated Restart Procedure shall identify the sequence of critical steps, procedures, and tests that must be performed to safely restart the Davis-Besse Nuclear Power Station. This procedure shall also include the necessary administrative controls required to authorize mode changes during plant restart. In addition to the normal procedure approvals, the Integrated Restart Procedure shall be reviewed by the Engineering Assessment Board and receive concurrence from the Senior Management Team. Final authority to restart the plant resides with the FENOC Chief Operating Officer.

G. Restart Action Plan Charter: Administer the identification, coordination, monitoring and closure of actions required to meet all Company-identified objectives and requirements under the Davis Besse Return to Service Plan.

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The Restart Action Plan establishes a mechanism for identification, monitoring and control of restart actions under the Davis-Besse Return to Service Plan. The Restart Action Plan also establishes a process and criteria for the evaluation, disposition, and closure of restart-identified actions and provides for the effective interaction with the Nuclear Regulatory Commission (NRC) during the Inspection Manual Chapter 0350 Reactor Oversight Process. This plan provides for the actions that the FENOC Management Team at Davis-Besse will perform to ensure that the plant is restarted in a safe and reliable manner and that the long-term performance of the plant will be sustainable. After NRC approval to restart has been received, final authority to restart the plant resides with the FENOC Chief Operating Officer.

The Davis-Besse Restart Station Review Board has been established to identify and classify items to be included in the Restart Action Database through a review of Condition Reports and Corrective Actions received from activities identified by the six Building Block Plans. The Restart Station Review Board makes the determination of items for inclusion in the Restart Action Database and further classifies those items that meet NRC IMC 0350 criteria. The Senior Management Team approves additions to the Davis-Besse IMC 0350 Restart List, with final approval by the FENOC Chief Operating Officer. The Restart Station Review Board uses criteria that parallel the NRC IMC 0350 Restart Checklist criteria. Those items processed through the Restart Station Review Board that are not required for restart are managed in accordance with the Corrective Action Program and evaluated for inclusion in the Davis-Besse Operational Business Plan and/or the regulatory management system.

Action Plans from the Containment Health Assurance, System Health Assurance, Reactor Head Resolution, Restart Test, and Program Compliance Building Blocks are further evaluated for technical accuracy by the Engineering Assessment Board. The Engineering Assessment Board has been introduced at each FENOC site to ensure a high degree of technical accuracy and assurance of nuclear safety.

The Restart Action Plan establishes the phases of Planning, Discovery, Implementation, and Validation/Closure. Closure packages documenting the resolution of issues on the Davis-Besse IMC 0350 Restart List, are prepared, validated, and approved, and made available for NRC review.

The Restart Overview Panel functions to provide an independent oversight and review of restart activities as part of the Davis-Besse Return to Service Plan. The Restart Overview Panel performs an overview of internal and external plant activities, advising the FENOC President, FENOC Chief Operating Officer and Davis-Besse Vice President on matters relating to the safe resumption of operation of Davis-Besse and provides recommendations as appropriate.

The Davis-Besse Restart Action Plan shall be maintained through restart and until the NRC terminates the IMC 0350 Reactor Oversight Process. This plan is implemented by a procedure that provides details of the responsibilities and activities required to administer and control the Restart Action Plan Building Block.

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V. Confirmatory Action Letter Status A number of actions to satisfy the CAL commitments are completed or underway. The current status of the CAL items is summarized as follows:

(1) Quarantine components or other material from the RPV Head and CRDM nozzle penetrations that are deemed necessary to fully address the root cause of the occurrence of degradation of the leaking penetrations. Prior to implementation, plans for further inspection and data gathering to support determination of the root cause will be provided to the NRC for review and comment.

Status: Applicable components and material were quarantined. Plans for inspection and data gathering to support determination of the root cause were provided to the NRC for review and comment. Following discussions between Davis-Besse and NRC personnel on November 1, 2002, the following additional specimens will be removed from the damaged reactor vessel head:

1) Approximately 8 inches diameter of head material unaffected by heat around CRDM penetration Nozzles 2 and 46,

2) Nozzle base material from any two of Nozzles 1, 2, 4, or 5 (heat no.

M3935),

3) Nozzle base material from Nozzle 47 (heat no. C2649-1), and

4) Nozzle base material from any two Nozzles 7, 12, 16, 20, 22-25, 27-29, 38 44, 48-55, 57, 64, 68, Or 69 (heat no. C2649-1).

Following removal of the material described above, and its shipment to Argonne National Laboratory (ANL), the head will be considered released from quarantine. All other specimen materials such as those sent to Canada and to Lynchburg, Virginia are also considered released from quarantine.

Therefore, Confirmatory Action Letter (CAL) Issue No. 1 will be considered closed following receipt of the material described above at ANL.

(2) Determine the root cause of the degradation around the RPV Head penetrations, and promptly meet with the NRC to discuss this information after you have reasonable confidence in your determination.

Status: FENOC provided a Probable Cause Summary Report to the NRC on March 22, 2002. FENOC submitted the technical Root Cause Analysis Report to the NRC on April 18, 2002. Responses to NRC questions on the Probable Cause Summary Report were submitted by FENOC on April 30, 2002, and May 14, 2002. Davis-Besse staff met with NRC headquarters personnel on May 9, 2002, to review the technical elements of the root cause analysis. A revision to the technical root cause report, deleting the preliminary conclusions that were more fully investigated and documented in the human performance root cause analysis report, was submitted to the NRC on September 23, 2002. FENOC has completed a formal root cause analysis report of the human performance failure to identify the degradation, which was submitted to the NRC on August 21, 2002. FENOC and Davis-Besse Page 16 of 25 Revision 5 January 9, 2003

management met with NRC Region III management on August 15, 2002, to discuss the human performance root cause analysis report. The results of this report were also discussed at the NRC IMC 0350 Panel public meeting, which was held on August 20, 2002.

(3) Evaluate and disposition the extent of condition throughout the reactor coolant system relative to the degradation mechanisms that occurred on the RPV Head.

Status: On April 15, 2002, FENOC began implementation of its Containment Health Assurance Plan. The scope of this plan has been increased to encompass the overall health of the Containment. NRC review of FENOC efforts in this area is documented in NRC Inspection Reports 50/346;2002-009 dated September 13, 2002 and 50/346;2002-012 dated November 29, 2002. While inspection Report 50/346;2002-012 concluded that the "Davis-Besse Containment Health Assurance Plan" was effectively implemented, three unresolved items associated with corrective actions on components potentially affected by boric acid corrosion were identified. These unresolved items were associated with corrective actions for corrosion of electrical conduit, the bottom nozzles on the reactor vessel, and the containment air coolers. Additionally, at the time, apparent cause determinations with designated corrective actions had been completed for only a small number of the components potentially affected by boric acid corrosion. Therefore, the NRC was not able to reach a conclusion on the completeness or technical adequacy of your corrective actions for structures, systems and components affected by boric acid corrosion. Therefore, CAL Issue No. 3 will remain open pending additional NRC inspection of FENOC action regarding those unresolved items and corrective actions for identified deficiencies.

(4) Obtain NRC review and approval of the repair or modification and testing plans for the RPV Head, prior to implementation of those activities. Prior to restart of the reactor, obtain NRC review and approval of any modification and testing activity related to the reactor core or reactivity control systems. If the reactor vessel head is replaced in lieu of repair or modification, the replacement must comply with appropriate Commission rules and industry requirements.

Status: FENOC replaced the RPV Head with a replacement RPV Head from the Midland Plant in Michigan. NRC review of the head replacement is documented in NRC Inspection Report 50/346;2002-007, dated November 29, 2002. Based on their inspection, NRC concluded that adequate records were available and required examinations performed to ensure that the replacement head was designed and fabricated in conformance with ASME Code requirements and that the original ASME Code Section III N-stamp remained valid. Licensing activities associated with the head replacement have been completed. The RPV Head was replaced using a temporary opening in the Containment while the reactor is de-fueled. Upon sastisfying the remaining actions of CAL Issue 1, the used RPV Head will be transported off-site for disposal. CAL Issue No. 4 will remain open pending Page 17 of 25 Revision 5 January 9, 2003

NRC review of successful completion of the reactor coolant system pressure test and control rod drive performance test.

(5) Prior to the restart of the unit, meet with the NRC to obtain restart approval. During that meeting, discuss the root cause determination, extent of condition evaluations, and corrective actions completed and planned to prevent recurrence.

Status: FENOC submitted Revision 3 of the "Davis-Besse Nuclear Power Station, Unit 1 Return to Service Plan" to the NRC on September 23, 2002. Upon completion of the restart actions described in this plan, FENOC will submit its Integrated Restart Report which will summarize the root cause determination, extent of condition evaluations and corrective actions completed and planned to prevent recurrence. Prior to FENOC finalizing its decision to enter operating Mode 2, FENOC will meet with NRC to discuss completed and planned actions as described in this Plan and to provide justification for restart. CAL Issue No. 5 will remain open pending that meeting and NRC approval.

(6) Provide a plan and schedule to the NRC, within 15 days of the date of this letter, for completing and submitting to the NRC your ongoing assessment of the safety significance for the RPV Head degradation.

Status: The Safety Significance Assessment was submitted to the NRC on April 8, 2002. In response to NRC Staff requests for additional information, FENOC submitted supporting information by letters dated June 12, 2002, July 12, 2002, and July 20, 2002. CAL Issue No. 6 is considered closed.

Page 18 of 25 Revision 5 January 9, 2003

VI. Conclusions FENOC is taking an integrated and comprehensive approach to complete the items in the CAL, address the causal factors in the Root Cause Analysis Report and AIT Report, and identify and implement restart actions and long-term actions to ensure that Davis-Besse is ready for safe and reliable operation and improved performance. FENOC is structuring its approach around seven key Building Blocks, including implementing documents. These plans have been made available for NRC review, and will provide the foundation for Davis-Besse's safe and reliable return to service. Lessons learned from the RPV Head degradation root cause analyses will be shared with the other'FENOC plants as well as with the nuclear industry.

Page 19 of 25 Revision 5 January 9, 2003

FIGURE 1 DAVIS-BESSE RESTART BUILDING BLOCKS Reactor Head Resolution Program Compliance Containment Health Restart Test Plan Management and Human System Health Assurance Plan Plan Assurance Plan Performance Excellence Plan Owner: T. Stallard Plan Owner: D. Baker Owner: N. Morrison Owner: T. Chambers Oversight: R. Fast Owner: J. Rogers Oversight: B. Schrauder Oversight: J. Powers Oversight: R. Fast Owner: L. Myers Oversight: J. Powers Desired Outcome - Return Oversight: N/A Desired Outcome - Ensure Desired Outcome - Ensure Desired Outcome - Identify to power with leaktight DesiredOutcome - Identify reactorhead can perform applicableprogramsare in impacts of Boric Acid plant. DesiredOutcome - Ensure and resolve safety system its safetyfunction. a condition to support the leakage into Containment Management and Human issues and ensure safety restartand safe operation and ensure Containment is Performanceissues are and reliability.

of Davis-Besse. readyfor safe and reliable identified and resolved.

operations.

Normal Plant Processes

+

Restart Action Plan

"* Condition Reports

"* Industry Experience Owner: C. Price Oversight: L. Myers

"* Employee Concerns Desired Outcome - Development of Restartand Post-Restart

"* Others Issues Program.

Page 20 of 25 Revision 5 January 9, 2003

FIGURE 2 Restart Organization Executive Vice Vice President President - Engineering Oversight and Services - Independent Oversight Vice PreE Engineering Assessment Board

- Senior Management Team

- Restart Station Review Board Page 21 of 25 Revision 5 January 9, 2003

APPENDIX 1 Page 1 of 4 CORRELATION OF CAUSAL FACTORS VERSUS RESTART BULDING BLOCKS Less than adequate material selection. PWSU(U ot Repair/Replace the RIV Hf CRDM nozzle interface at the J-groove weld due to Develop a plan to monitor C material susceptibility in the presence of a suitable restart (7.1.1) environment resulted in:

V CRDM nozzle crack initiated Containment Health Assurance Plan Review CRDM nozzle crack initiation/propagation V CRDM nozzle crack propagation to through wall against susceptibility (7.1.2) leak

, Boric acid corrosion of the low-alloy-steel RPV Head material (Root Cause: 5.1.1)

Less than adequate Boric Acid Corrosion Control and Program Compliance Plan Review of Boric Acid Corrosion Control and ISI Inservice Inspection Programs and program Programs (7.1.6).

• 1 -.

implementation regarding the RPV head resulted in: Containment Health Assurance Plan Inspections in the Containment for other SSCs that V Plant not identifying the through wall crack/leak may be affected by boric acid (7.1.5) during outages V/ Plant returned to power with boron on the RPV Head after outages V Plant not identifying degradation of RPV Head base metal during 12RFO V Boric Acid Corrosion of the low-alloy steel RPV Head material

('Root Cause: 5.1.2)

Less than adequate Environmental conditions. Cramped System Health Assurance Plan Review of modification requests to identify conditions due to the design and high radiation at the modifications that should be implemented prior to RPV Head resulted in: restart. (7.2.1)

V Plant not identifying the through wall crack/leak during (Note: the modification to improve access to the RPV outages Head service structure has been completed.)

V Plant returned to power with boron on the RPV Head after outages V Plant not identifying degradation of RPV Head base metal during 12RFO V Boric Acid Corrosion of the low-alloy steel RPV Head material.

(Contributing Cause: 5.2.1)

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APPENDIX 1 Page 2 of 4 CORRELATION OF CAUSAL FACTORS VERSUS RESTART BULDING BLOCKS Less than adequate maintenance and testing. Corrective Maintenance did not promptly correct the problem with equipment condition (CRDM flange leakage) that resulted in:

/ Plant not identifying the through wall crack/leak during outages i _____________________________

/ Plant not identifying degradation of RPV Head base System Health Assurance Plan Review of corrective maintenance, adequacy of PMs metal during 12RFO and CRs.

/ Boric Acid Corrosion of the low-alloy steel RPV Head material (Contributing Cause: 5.2.2) I I Page 23 of 25 Revision 5 January 9, 2003

APPENDIX 1 Page 3 of 4 Less than adequate Nuclear Safety Focus (Root Cause: Management and HIuman Management Changes, (8.1.1.a) 6.1.1) Performance Excellence Plan Management field presence/involvement plan to improve management oversight (8.1.1 .a)

Management Monitoring Process to monitor and trend oversight activities. (8.1.1 .a)

Case Study Training (8.1.1 .a)

Safety Conscious Work Environment assessment and training. (8.1.1 .b)

Less than adequate implementation of the Corrective Program Compliance Plan Detailed review of the Corrective Action Program Action Program (8.1.2)

(Root Cause: 6.1.2) Management and Human Review of corrective action document evaluations to Performance Excellence Plan enforce higher standards for cause evaluations and effective corrective action (8.1.2b)

Less than adequate analyses of safety implications (Root Management and Human Industry experience management review and establish Cause: 6.1.3) Performance Excellence Plan the FENOC Hierarchy of Documents. (8.1.3)

Less than adequate compliance with Boric Acid Program Compliance Plan Reinforce standards and expectations for procedure Corrosion Control (BACC) procedure and Inservice Test compliance and the need for work practice rigor.

Program (8.1.4b)

(Root Cause: 6.1.4)

Lack of Hazard Analyses. Management and Human Establish the FENOC Decision Making process at (Contributing Cause: 6.2.1) Performance Excellence Plan Davis-Besse including hazard analyses. (8.2.1 a)

Corrective Action Procedure Program Compliance Plan Detailed review of the Corrective Action Program (Contributing Cause: 6.2.2) (8.2.2b)

Page 24 of 25 Revision 5 January 9, 2003

APPENDIX 1 Page 4 of 4 CORRELATION OF CAUSAL FACTORS VERSUS RESTART BULDING BLOCKS Restart Test Plan Boric acid corrosion of RPV Head (3.1.2) Reactor Head Resolution Plan Replace the head.

Containment Health Assurance Plan Inspections in the Containment for other SSCs that may be affected by boric acid.

Boric acid corrosion control program (5.1) Program Compliance Plan Review of Boric Acid and ISI Programs.

Reactor Coolant System leakage detection Restart Test Plan Inspect for any leaks.

(5.2) Program Compliance Plan Develop leak detection program Boric acid in Containment Air Coolers (5.3) Containment Health Assurance Plan Inspections in the Containment for other SSCs that may be affected by boric acid.

Boric acid in radiation elements (5.4) Containment Health Assurance Plan Inspections in the Containment for other SSCs that may be affected by boric acid.

Delay of Modification of Service Structure System Health Assurance Plan Review of modification requests to identify (5.5.1) modifications that should be implemented prior to restart.

(Note: the modification to improve access to the RPV Head service structure has been completed.)

Delay of Repair of CRDM Flange Leakage Restart Test Plan Inspect for any leaks.

(5.2.2)

Page 25 of 25 Revision 5 January 9, 2003

Attachment 2 Nuclear Quality Assessment of Return to Service Plan Revision 3 September 23, 2002

Nuclear Quality Assessment Oversight of Davis-Besse Return to Service Plan Rev. 3 (Based on Davis-Besse Return to Service Plan dated 9/6/02)

Approvals:

-7/23/0

'S. A. Loehlein Date Manager - DB Nuclear Quality Assessment L. W. Pearce 1' lateL Vice President - FENOC Oversight Page 1 of 4 Revision 3

Nuclear Quality Assessment Oversight of Davis-Besse Return to Service Plan Mission Statement Davis-Besse (DB) Nuclear Quality Assessment (NQA) will provide oversight and verify the adequacy of activities conducted as part of the Return to Service Plan. This will be performed by assessing key activities such as: review board meetings; in-depth technical review of engineering products; field verification of actual conditions pre and post remediation; and independent reviews paralleling those performed by the line. Specific activities will be selected for review based on their safety and risk significance to provide reasonable assurance that Return to Service Plan activities are performed in a quality manner. Activities which will be verified as completed are listed in Attachment 1. Examples of verification activities under each building block are provided below.

NQA oversight will be conducted using FENOC procedure NOP-LP-2004, Internal Assessment Process. As described in this procedure, the Quality Field Observation database will be used to document the results of these assessments. Findings and recommendations shall be documented on condition reports and processed in accordance with FENOC procedure NOP-LP-2001, Condition Report Process. NQA will use this established process and develop a separate Quality Field Observation to document the overall NQA conclusion for each building block.

Assessment Team Leaders are certified in accordance with Davis-Besse procedure NA-QA-07006, Certification of Lead Auditor Personnel. Assessment team members, including technical specialists, receive training orientation in accordance with FENOC procedure NOP-LP-2004, Internal Assessment Process.

Reactor Head Resolution Plan

1. Verify modifications used for the replacement head allow the head to meet NRC rules and industry requirements.

2. Verify testing methodology used for acceptance testing and review selected critical tests.

3. Verify critical documents used to qualify the reactor vessel head.

4. Verify critical aspects of the installation, testing, and containment breech to ensure sound engineering practices and code compliance.

5. Verify design packages used in the resolution plan to ensure compliance with station procedures and ensure translation of design bases into plant documents.

5 Restart Action Plan

1. Verify the adequacy of the criteria used by the Restart Station Review Board in determining whether to include an action in the Restart Action Database.

2. Independently assess decision-making activities of the Restart Station Review Board.

3. Verify the Restart Action Plan will provide for effective interaction with the NRC.

Page 2 of 4 Revision 3

4. Verify the establishment of an Engineering Assessment Board including chairman designation, board membership, meeting frequency, and board responsibilities.

5. Verify that items processed through the Restart Station Review Board that are determined to not be required for restart are managed in accordance with the corrective action program and evaluated for inclusion in the Davis-Besse operational business plan and/or the Regulatory Management System.

I Program Compliance Plan

1. Review the methodology for performing the Phase 1 Program Readiness Baseline Assessments and Phase 2 Program Detailed Reviews to confirm that critical aspects are evaluated.

2. Verify the proper programs are chosen for review to support safe operation 3.. Perform independent Phase 1 Program Readiness Baseline Assessments of selected programs to confirm adequacy of line evaluations of the same program.

4. Perform reviews of selected attributes of several Phase 1 Assessments and Phase 2 Reviews to assess results of the program review

5. Verify adequacy of corrective actions implemented from selected condition reports generated during program reviews

6. Review the use of Operating Experience identified for selected programs to confirm lessons learned are implemented

7. Assess the interface and effectiveness of the program owner and the Program Review Board during selected program presentation System Health Assurance Plan

1. Review the methodology for performing system health readiness and latent issue review to veiify critical aspects are evaluated

2. Review the results of the Operational Readiness Reviews to verify that actions required were documented and properly completed

3. Review the use of Operating Experience identified for selected system reviews to confirm lessons learned are implemented

4. Verify proper systems were selected for system health readiness review

5. Perform an independent review of selected systems to assess the adequacy of line reviews of the same system

6. Verify the latent issues review of selected systems were effective in identifying issues

7. Review the adequacy of selected corrective actions implemented from selected condition reports generated during system reviews

8. Assess the interface and effectiveness of the system owner and the Engineering Assessment Board and Restart Station Review Board during selected system presentations I Containment Health Assurance Plan

1. Verify walkdown criteria for identification of degradation of material condition.

2. Verify appropriate basis and documentation for source targets and list of alloy 600 components.

3. Verify the inspectors are qualified.

Page 3 of 4 Revision 3

4. Verify walkdown inspection packages are thorough by performing independent walkdowns and comparing the results with the original for selected areas of containment.

5. Verify consistent and appropriate disposition of Condition Reports generated as a result of the inspection plan results. This will be accomplished by reviewing selected Condition Reports.

6. Verify corrective actions from Condition Reports are adequately implemented by field verification of selected areas of containment post remediation.

7. Verify an inspection plan is generated for future refueling outages that contains proper standards and inspection points.

5 Restart Test Plan

1. Verify the scope of Test Team activities is adequate to identify leakage during fill and vent of the Reactor Coolant System and at normal operating temperature and pressure

2. Verify that the sources of any leakage identified during fill and vent of the Reactor Coolant System and at normal operating temperature and pressure are adequately documented

3. Verify that adequate corrective actions are taken to correct any leakage identified during fill and vent of the Reactor Coolant System and at normal operating temperature and pressure.

4. Verify that corrective actions are taken to prevent recurrence of any leakage identified during fill and vent of the Reactor Coolant System and at normal operating temperature and pressure.

5. Verify that processes to correct any identified leakage are effectively performed in accordance with applicable site requirements and industry standards.

6. Verify the testing of Containment by the Integrated Leak Rate Test in accordance with 10CFR50, Appendix J. (Type A test)

7. Verify post maintenance and modification testing is reviewed during the System Health Review.

Management and Human Performance Excellence Plan _

1. Verify a thorough assessment is conducted of the management and organizational issues surrounding the degradation of the reactor pressure vessel head.

2. Verify a comprehensive leadership and organizational development plan is created.

3. Verify the establishment of performance indicators used to monitor the effectiveness of actions taken.

4. Verify selected actions of the Management and Human Performance Excellence Plan are effectively implemented.

5. Verify selected Functional Area reviews are completed to assess restart readiness.

Page 4 of 4 Revision 3 NQA Oversight of DB Return to Service Plan Revision 3 Page 1 RETURN TO SERVICE PLANsI RESTART NQA METHOD OF VERIFICATION STATEMENT IBUILDING BLOCKI Perform inspection evaluations of CTMT HEALTH Perform a sample (10%) of inspections to containment SSCs prior to restart to ensure ASSURANCE achieve a high levdfof confidence that the that the condition of containment supports line is performing critical inspections.

safe and reliable operation. _

This will be accomplished by completing CTMT HEALTH Verify the qualifications of inspectors and inspections and evaluations of SSCs using ASSURANCE evaluators.

qualified inspectors and evaluators.

Particular focus will include boric acid CTMT HEALTH Perform a sample (10%) of inspections to degradation of containment SSCs, ASSURANCE achieve a high level of confidence that the containment vessel, ctmt coatings, line is performing critical inspections.

emergency sump, alloy 600, and inspections for indications of PWSCC and threaded bolted component leaks.

These areas include the ctmt emergency CTMT HEALTH Perform a sample (10%) of inspections sump, ctmt vessel liner, EQ program and ASSURANCE and CR dispositions to achieve a high level effects of boric acid on equipment, of confidence that the line is performing refueling canal leakage, ctmt coatings, and critical inspections.

the decay heat valve pit.

Field inspectors have been trained to CTMT HEALTH Verify the qualifications of inspectors and conduct thorough inspections based on ASSURANCE evaluators.

specific requirements and quality attributes associated with CTMT inspections.

Inspectors will attend training for specific procedures and work orders prior to implementing field activities.

The replacement RPV head is a B&W REACTOR HEAD The original paperwork will be reviewed for design and with minor modifications, can RESOLUTION compliance with industry requirements and satisfy the applicable NRC rules and a sample of NDE will be verified industry requirements. acceptable.

The major attributes of this plan include: REACTOR HEAD The original paperwork will be reviewed for Procurement and certification of the RESOLUTION compliance with industry requirements and replacement head. NDE will be performed a sample of NDE will be verified to confirm that the replacement head is acceptable.

suitable for use.

The major attributes of this plan include: REACTOR HEAD Applicable MODs will be verified for Minor RPV head mods, to ensure that the RESOLUTION applicability to the replacement head.

replacement RPV head fits the DB reactor.

Inspection holes have been added to the service structure for more effective inspections.

The major attributes of this plan include: REACTOR HEAD Critical aspects in execution of the task will Access to the DB containment for removal RESOLUTION be verified.

of the original RPV head and placement of the new RPV head on the head stand.

The major attributes of this plan include: REACTOR HEAD Lift plans will be reviewed and critical lifts Installation of a new RPV head, including RESOLUTION will be monitored for compliance with transfer of existing service structure and standard lifting and rigging practices.

transfer of existing CRDM to the new RPV head.

The major attributes of this plan include: REACTOR HEAD Critical aspects in execution of the task will Restoration, testing, and inspection of the RESOLUTION be verified.

RPV head and containment. I NQA Oversight of DB Return to Service Plan Revision 3 Page 2 RETURN TO SERVICE PLANsI RESTART NQA METHOD OF VERIFICATION STATEMENT IBUILDING BLOCKI The major attributes of this plan include: REACTOR HEAD Verify final disposition for RPV Head.

Storage and/or disposal of original RPV RESOLUTION head.

The major attributes of this plan include: REACTOR HEAD Sampling of updates will be verified for Updating the design and licensing basis RESOLUTION accuracy, appropriate levels of detail, and documents proper standards.

A temporary access opening has been REACTOR HEAD Critical aspects in execution of the task will made in the DB containment vessel and RESOLUTION be verified.

shield building to allow for transfer of the replacement RPV head into the containment building and removal of the original RPV head.

The shield building and containment vessel REACTOR HEAD Critical aspects in execution of the task will will be restored to meet design RESOLUTION be verified.

requirements.

An ILRT will be performed to verify REACTOR HEAD Critical aspects in execution of the task will containment integrity RESOLUTION be verified.

The degraded head will be temporarily REACTOR HEAD No verification required.

stored at DB. RESOLUTION Bechtel has been contracted to provide REACTOR HEAD Critical aspects of work performed by engineering services for the RPV RESOLUTION Bechtel will be evaluated.

replacement including overall project management, detailed engineering, licensing support, quality assurance, and project controls.

Framatome-ANP has been contracted to REACTOR HEAD The original paperwork will be review for procure and certify the replacement RPV RESOLUTION compliance with industry requirements and head, including modifying the RPV head as a sample of NDE will be verified required, providing a Certification of acceptable.

Compliance documenting that the replacement head is suitable for use at DB and providing engr and required evaluations to ensure the DB design and licensing requirements are met (including ASME code criteria).

The RPV head replacement is a REACTOR HEAD Compliance with the 50.59 process will be modification to the facility and will be RESOLUTION verified.

performed in accordance with the provisions of 50.59 criteria.

Completion of this mod will resolve the REACTOR HEAD Post restart effectiveness review will be issue concerning boron corrosion RESOLUTION performed.

degradation of the RPV head, including disposition of the associated corrective actions and performance of more effective periodic head inspections allowing for early detection of head degradation due to the increased size of the inspection holes.

Conduct a thorough assessment of the MGMT AND HUMAN Oversight and Process Improvement management and organizational issues PERFORMANCE Department (OPID) oversight will verify surrounding the degradation of the reactor EXCELLENCE appropriate root cause methodology and pressure vessel head adequacy of the root cause NQA Oversight of DB Return to Service Plan Revision 3 Page 3 RETURNTO SERVICE PLAN j RESTART NQA METHOD OF VERIFICATION Create a comprehensive leadership and MGMT AND HUMAN Verify the adequacy of a comprehensive organizational development plan for the PERFORMANCE leadership and organizational development site. This plan to include actions to be EXCELLENCE plan taken prior to and after restart Performance indicators monitoring the MGMT AND HUMAN Verify the establishment of performance effectiveness of the actions taken will be PERFORMANCE indicators used to monitor the used to demonstrate and track desired EXCELLENCE effectiveness of desired changes.

changes.

Reviews of specific departments will be MGMT AND HUMAN Verify selected Functional Area Reviews done by way of Functional Area Reviews. PERFORMANCE are completed to assess restart readiness.

These reviews will be performed in EXCELLENCE selected areas in order to assess restart readiness.

The Management Observation Program MGMT AND HUMAN Verify that the Management Observation will be used to monitor individual PERFORMANCE Program has been updated to schedule performance. This program will be EXCELLENCE management observations.

updated to schedule management observations to monitor effectiveness of work activities and worker behaviors.

Review boards, such as the Corrective MGMT AND HUMAN Verify that review boards are effectively Action Review Board and Engineering PERFORMANCE monitoring work products for appropriate Assessment Board will be used to monitor EXCELLENCE standards. Verify establishment of various work products for appropriate performance indicators.

standards. These will have indicators to show performance at the individual section level.

A Management Monitoring Process will be MGMT AND HUMAN Verify the establishment of the used to monitor and trend the performance PERFORMANCE Management Monitoring Process.

of specific management oversight activities EXCELLENCE taken on an individual basis. These will demonstrate the level of involvement of individual managers.

Perform a review of applicable plant PROGRAM Confirm programs are reviewed through programs to ensure that the programs are COMPLIANCE review of completed documents and fulfilling required obligations, including perform an independent review of selected interfaces and handoffs and are sufficient programs.

to support the restart and safe operation of the Davis-Besse Nuclear Power Station Prior to restart, performed Phase 2 detailed PROGRAM Confirm programs are reviewed through systematic reviews of the Boric Acid COMPLIANCE review of completed documents.

Corrosion Control Program, Inservice Inspection program, Plant Modification program, Corrective Action program, Reactor Coolant System Unidentified Leakage program, Radiation Protection program, and Operating Experience program Prior to restart, perform Phase 1 baseline PROGRAM Confirm programs are reviewed through assessment of applicable plant programs COMPLIANCE review of completed documents, and identified in the Program Compliance perform independent reviews of selected Building Block Plan. programs to assess results of line reviews.

NQA Oversight of DB Return to Service Plan Revision 3 Page 4 RETURN TO SERVICE PLAN RESTART I NQA METHOD OF VERIFICATION STATEMENT IBUILDING BLOCKI Phase 1 performs a baseline assessment PROGRAM Confirm programs are reviewed through of applicable programs to determine if the COMPLIANCE review of completed selected documents.

programs are in a condition to support the restart and safe operation of DB.

The program owner-assesses the program PROGRAM Assessed by reviewing results of selected by completing a standardized COMPLIANCE program questionnaires and attending questionnaire and presenting the results to Program Review Board meetings.

the Program Review Board (EAB).

Condition reports will be generated to PROGRAM Review selected condition reports and document program weaknesses and COMPLIANCE restart restraint evaluations.

recommendations evaluated as restart restraints.

Phase 2 reviews are in depth systematic PROGRAM Confirm programs are reviewed through reviews of the programs, and the process COMPLIANCE review of completed documents.

ensure programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support restart and safe operation.

Testing the Reactor Coolant System RESTART TEST Verify the testing of the RCS ensures (RCS), including components and integrity at full temperature and pressure.

associated piping exposed to full RCS pressure, to ensure integrity following replacement of the Reactor Vessel Head and maintenance of RCS piping and components.

Testing the Containment by performing an RESTART TEST Verify that the ILRT test is peirformed in Integrated Leakage Rate Test in accordance with procedures and meets the accordance with 10CFR50, Appendix J acceptance criteria.

(Type A test) to ensure the integrity of containment following restoration of the containment pressure vessel.

Evaluating the adequacy of proposed post- RESTART TEST Verify the adequacy of testing as stated in maintenance and post-modification testing the integrated Restart procedure.

on systems and components affected by RCS leakage and boric acid deposits and to determine if additional testing is required.

Develop an Integrated Restart Procedure RESTART TEST Verify the development and to ensure required restart activities, tests implementation of the Integrated Restart and inspections have been performed prior procedure.

to mode ascension.

An Operational Readiness Review of SYSTEM HEALTH Assess completion of follow-up actions systems important to the safe and reliable ASSURANCE identified operation of Davis-Besse was performed.

A System Health Readiness Review of all SYSTEM HEALTH Verify completion of reviews and perform Maintenance Rule risk significant systems ASSURANCE an independent assessment of selected will be performed. systems.

NQA Oversight of DB Retum to Service Plan Revision 3 Page 5 RETURN TO SERVICE PLAN RESTART NQA METHOD OF VERIFICATION STATEMENT BUILDING BLOCK Latent issues reviews of the Reactor SYSTEM HEALTH Verify latent issues review of systems Coolant, Emergency Diesel Generators, ASSURANCE performed and assess selected results of Auxiliary Feedwater, Component Cooling review.

Water, and Service Water systems will be performed to identify any latent issues, and to provide reasonable assurance that these systems can perform their safety and accident mitigation functions will be performed prior to, restart.

System Health Readiness Reviews will be SYSTEM HEALTH Verify reviews are performed as required.

performed on all risk significant ASSURANCE Maintenance Rule systems to provide reasonable assurance that these systems can perform their risk significant maintenance rule functions.

These reviews include identification of the SYSTEM HEALTH Review selected reports for adequacy.

system's risk significant functions, testing, ASSURANCE other information (like trendingdata) that assesses the system's ability to support the system risk significant functions, walkdowns, and selected data sources.

The assigned system engineer will prepare SYSTEM HEALTH Review selected reports for adequacy.

a report based on the System Readiness ASSURANCE Review.

Problems identified during the SHRR and SYSTEM HEALTH Review selected condition reports and Latent Issues reviews will be captured in ASSURANCE verify RSRB review.

the CR process and the Restatt Station Review Board will review all CRs for restart requirements.

The Engineering Assessment Board will SYSTEM HEALTH Assess results of Engineering Assessment review the report to provide an ASSURANCE Board reviews.

independent assessment of the technical adequacy of the report.

Reviews will be comprised of three major SYSTEM HEALTH Review selected reports for compliance.

efforts: 1) assessment of system ASSURANCE attributes, 2) review of various data sources, and 3)walkdowns.

The Plant Engineering Manager and the SYSTEM HEALTH Verify report is reviewed by Plant EAB will review the Latent Issues Review ASSURANCE Engineering Manager and EAB.

Report for each system.

The Restart Senior Management Team SYSTEM HEALTH Verify proper approvals obtained.

chaired by the Vice President - Nuclear will ASSURANCE approve the report.

A separate boric acid inspection of systems SYSTEM HEALTH Verify adequacy of inspections.

outside of containment will be performed ASSURANCE with EN-DP-01506 Near-term actions necessary to support INTRODUCTION Verify appropriate actions are included in restart are being included in the Davis- AND PURPOSE the Restart Action List Besse IMC 0350 Restart List and will be discussed in an Integrated Restart Report The Integrated Restart Report will INTRODUCTION Review the Integrated Restart Report to document Davis-Besse's response to the AND PURPOSE ensure adequate response to the NRC's Augmented Inspection Team Augmented Inspection Team's report, and Report, and request NRC approval of to ensure that NRC approval for restart NQA Oversight of DB Return to Service Plan Revision 3 Page 6 RETURN TO SERVICE PLAN RESTART NQA METHOD OF VERIFICATION STATEMENT BUILDING BLOCK I restart and closure of the commitments in and closure of commitments in the the Confirmatory Action Letter Confirmatory Action Letter have been requested Longer-term post-restart actions will be INTRODUCTION Assess restart building block activities to evaluated for incorporation into the AND PURPOSE ensure post-restart actions are evaluated Business Plan and/or Regulatory for incorporation in the Business Plan Management System. and/or Regulatory Management System.

FENOC senior leadership will be directly INTRODUCTION Review composition of various oversight involved in the direction and oversight of AND PURPOSE committees to ensure FENOC senior Davis-Besse's return to service leadership involvement in direction and oversight The Restart Action Plan establishes a RESTART ACTION Assess the establishment of the Restart mechanism for identification, monitoring, Action Plan and control of restart actions under the Davis-Besse Retum to Service Plan The Restart Action Plan establishes a RESTART ACTION Assess the established process and process and criteria for the evaluation, criteria for adequacy of the evaluation, disposition, and closure of restart-identified disposition, and closure of restart-identified actions actions The Restart Action Plan provides for RESTART ACTION Evaluate Davis-Besse interaction with the effective interaction with the NRC during NRC during the Inspection Manual Chapter the Inspection Manual Chapter 0350 0350 Reactor Oversight Process Reactor Oversight Process After NRC approval to restart has been RESTART ACTION Verify final approval to restart has been received, final authority to restart resides provided by the FENOC chief operating with the FENOC chief operating officer officer The Davis-Besse Restart Station Review RESTART ACTION Assess the establishment of the Davis Board has been established to identify and Besse Restart Station Review Board classify items to be included in the restart including chairman designation, board action database through a review of membership, and meeting frequency condition reports and corrective actions received from activities identified by the six Building Block Plans The Davis-Besse Restart Station Review RESTART ACTION Evaluate the adequacy of the Board makes the determination of items for determinations for inclusion in the restart inclusion in the restart action database and action database; and evaluate further classifies those items that meet classification of those items that meet NRC NRC ICM 0350 criteria ICM 0350 criteria The Restart Senior Management Team RESTART ACTION Ensure approval is made for inclusion of approves the addition of items to the Davis- additional items in the Davis-Besse ICM Besse IMC 0350 restart list, with final 0350 restart list by the restart senior approval by the FENOC chief operating management team, and the FENOC chief officer operating officer The Restart Station Review Board uses RESTART ACTION Ensure the Restart Station Review Board criteria that parallel the NRC IMC 0350 uses criteria that parallel the NRC IMC restart checklist criteria 0350 restart checklist criteria Items processed through the Restart RESTART ACTION Assess the Restart Station Review Board Station Review Board that are not required process to ensure items not added to the for restart are managed in accordance with restart action list are documented and the Corrective Action Program and included in the Corrective Action Program evaluated for inclusion in the Davis-Besse and evaluated for inclusion in the Davis Operational Business Plan and/or the Besse Operational Business Plan and/or Regulatory Management System the Regulatory Management System NQA Oversight of DB Return to Service Plan Revision 3 Page 7 RETURN TO SERVICE PLAN RESTART NQA METHOD OF VERIFICATION STATEMENT BUILDING BLOCK .

Action plans from the Containment Health RESTART ACTION Verify that the referenced actions plans are Assurance, System Health Assurance evaluated for technical accuracy by the' Reactor Head Resolution, Restart Test and Engineering Assessment Board Program Compliance building blocks are further evaluated for technical accuracy by the Engineering Assessment Board The Engineering Assessment Board has RESTART ACTION Assess the establishment of an been introduced at each FENOC site to Engineering Assessment Board including ensure a high degree of technical accuracy chairman designation, board membership, and assurance of nuclear safety meeting frequency, board responsibilities, and the introduction of this Engineering Assessment Board at each of the FENOC sites The Restart Action Plan establishes the RESTART ACTION Ensure the Restart Action Plan includes phases of planning, discovery, the appropriate phases implementation, and validation/closure.

Closure packages documenting the RESTART ACTION Verify that closure packages are resolution of issues on the Davis-Besse adequately prepared, validated, approved, IMC 0350 restart list are prepared, and made available for NRC review validated, approved, and made available for NRC review The Restart Overview Panel functions to RESTART ACTION Assess the function of the Restart provide independent oversight and review Overview Panel of restart activities as part of DB Return to Service Plan. The Restart Overview Panel performs an overview of internal and external plant activities, advising the FENOC president, chief operating officer, and Davis-Besse vice president on matters relating to the safe resumption of operation of Davis-Besse and provides recommendations as appropriate The Davis-Besse Restart Action Plan shall RESTART ACTION Assess the maintenance of the Davis be maintained through restart and until the Besse restart Action Plan through restart NRC terminates the IMC 0350 reactor and until the NRC terminates the 0350 oversight process reactor oversight process The Davis-Besse Restart Action Plan is RESTART ACTION Ensure a procedure has been developed implemented by a procedure(s) that to implement the Davis-Besse Restart provides details of the responsibilities and Action Plan and review the procedure for activities required to administer and control adequacy the Restart Action Plan building block

Attachment 3 Restart Action Plan Revision 4 January 7, 2003

Davis-Besse Restart Action Plan Revision: 4 Date: January 7, 2003 Owner: C. A. Price RecommenfOor Approval Senior Management Team Chairman: L. W. Myers QApj y" L-.W. Myers

Table of Contents Title Page Summ ary of Revision Changes .................................................................... 2 Executive Summary ...................................................................................... 3 Charter and Definitions ................................................................................. 4 Restart Action Plan Objectives ..................................................................... 6 Plan Description ............................................................................................. 7 Overview ............................................................................................... 7 Purpose ................................................................................................... 8 Organization .......................................................................................... 8 Responsibilities ..................................................................................... 9 Management of Restart Action Database and Process ........................ 12 NRC Inspection Interface .................................................................... 13 IM C 0350 Restart List Closure Process ............................................. 13 Validation of Closure Packages ........................................................... 14 Interface with Restart Outage Schedule .............................................. 15 Integrated Restart Report ..................................................................... 15 Figures and Tables ........................................................................................ 17 Page 1 of 23 Revision 4 January 7, 2003

Summary of Revision Changes Revision 4 Revised the title of the Restart Senior Management Team to Senior Management Team and changed the membership to be consistent with the revised Charter for this team.

Eliminated the Performance Indicator and Integrated Schedule Support Team from Figure.2.

These responsibilities are now integrated into existing line organizations.

Revised the definitions of the Engineering Assessment Board and the Senior Management Team to be consistent with their Charters.

Moved the responsibility for distributing copies of Action Plans and maintaining central files for Action Plans and closure documentation from the Regulatory Interface Team to the Restart Action Plan Team Owner.

Page 2 of 23 Revision 4 January 7, 2003

Executive Summary The Restart Action Plan establishes a mechanism for identification, monitoring and control of restart actions under the Davis-Besse Return to Service Plan. The Restart Action Plan also establishes a process and criteria for the evaluation, disposition, and closure of restart-identified actions and provides for the effective interaction with the Nuclear Regulatory Commission (NRC) during the Inspection Manual (I1MC) Chapter 0350 Reactor Oversight Process. This plan provides for the actions that the FENOC Management Team at Davis-Besse will perform to ensure that the plant is restarted in a safe and reliable manner and that the long term performance of the plant will be sustainable. After NRC approval to restart has been received, final authority to restart the plant resides with the FENOC Chief Operating Officer.

The Davis-Besse Restart Station Review Board has been established to identify and classify items to be included in the Restart Action Database through a review of Condition Reports and Corrective Actions received from activities identified by the six Building Block Plans. The Restart Station Review Board makes the determination of items for inclusion in the Restart Action Database and further classifies those items that meet NRC IMC 0350 criteria. The Senior Management Team reviews the addition of restart actions to the Davis-Besse IMC 0350 Restart List with final approval by the FENOC Chief Operating Officer. The Restart Station Review Board uses criteria that parallel the NRC IMC 0350 Restart Checklist criteria. Those items processed through the Restart Station Review Board that are not required for restart are managed in accordance with the Corrective Action Program and evaluated for inclusion in the Davis Besse Operational Business Plan and/or the Regulatory Management System.

Action Plans for the Containment Health Assurance, System Health Assurance, Reactor Head Resolution, Restart Test, and Program Compliance Building Blocks are further evaluated for technical accuracy by the Engineering Assessment Board. The Engineering Assessment Board reports to the Director - Nuclear Engineering and has been introduced at each FENOC site to ensure a high degree of technical accuracy and assurance of nuclear safety.

The Restart Action Plan establishes the phases of Planning, Discovery, Implementation, and Validation/Closure. Closure packages documenting the resolution of restart actions on the Davis-Besse IMC 0350 Restart List are prepared, validated, and approved, and made available for NRC review.

The Restart Overview Panel functions to provide an independent oversight and review of restart activities as part of the Davis-Besse Return to Service Plan. The Restart Overview Panel performs an overview of internal and external plant activities, advising the FENOC President, Chief Operating Officer and Davis-Besse Vice President on matters relating to the safe resumption of operation of Davis-Besse and provides recommendations as appropriate.

The Davis-Besse Restart Action Plan shall be maintained through restart and until the NRC terminates the IMC 0350 Reactor Oversight Process. This plan is implemented by a procedure that provides details of the responsibilities and activities required to administer and control this Restart Action Plan Building Block.

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Charter Administer the identification, coordination, monitoring and closure of actions required to meet all Company-identified objectives and requirements under the Davis-Besse Return to Service Plan.

Definitions Building Block Plans: Plans that address the major areas of concentration that need to be addressed prior to restart and identify actions or process changes or improvements that shall be accomplished to support restart.

Davis-Besse IMC 0350 Restart List: The list that identifies those restart actions that FENOC identifies to the NRC to address the checklist items identified in the NRC Manual Chapter 0350 Panel Restart Checklist.

Davis-Besse Restart Action List: The list that identifies those items that FirstEnergy Nuclear Operating Company (FENOC) plans to correct over and above the Davis-Besse IMC 0350 Restart List prior to restart, and post restart items that will be evaluated for inclusion in the Davis-Besse Operational Business Plan and/or Regulatory Management System related to Building Block or restart activities.

Davis-Besse Return to Service Plan: Describes the Davis-Besse course of action for a safe and reliable return to service. a Engineering Assessment Board: A review board of FENOC personnel, independent consultants and industry experts tasked with reviewing engineering products and products from the Building Block Plans. The Engineering Assessment Board provides technical oversight to ensure Nuclear Engineering Department products and activities exhibit a high degree of technical accuracy and assurance of nuclear safety.

IMC 0350 Oversight Panel: The NRC panel chartered to provide focused and coordinated regulatory oversight in accordance with the requirements of the IMC 0350 Reactor Oversight Process.

IMC 0350 Reactor Oversight Process: A formal restart approval process which establishes criteria for NRC oversight of licensee performance and establishes a record of major regulatory and licensee actions taken and technical issues resolved, leading to approval for restart and eventual return of the plant to the routine reactor oversight process.

Restart Action Database: A total list of restart items comprised of the Davis-Besse IMC 0350 Restart List and the Davis-Besse Restart Action List.

Restart Station Review Board: A committee consisting of the Director of Support Services, site managers and independent oversight established and chartered to identify and classify items Page 4 of 23 Revision 4 January 7, 2003

to be included in the Restart Action Database through a review of Condition Reports, Corrective Actions, and other documents.

Senior Management Team: A team consisting of the FENOC Chief Operating Officer, the I Plant Manager, the Directors of Nuclear Engineering, Support Services, and Work Management and independent oversight. The Senior Management Team is chartered to provide senior management review and oversight of restart activities.

Restart Overview Panel: A panel of FENOC executive management and outside industry experts who provide an independent oversight and review of plant activities discovered or performed as part of the Davis-Besse Return to Service Building Blocks.

Page 5 of 23 Revision 4 January 7, 2003

Restart Action Plan Objectives

"* Establish a mechanism for coordinated management identification, monitoring and control of restart actions.

"* Provide effective interaction with the NRC IMC 0350 Reactor Oversight Process.

"* Coordinate the planning, discovery, implementation, and validation/closure of actions from the Building Block Plans..

"* Control and maintain the Restart Action Database

"* Provide the Restart Station Review Board with criteria for assessing items to be placed in the Restart Action Database.

"* Administer Restart Station Review Board and Senior Management Team activities related to restart activities.

"* Provide a process for the Restart Station Review Board to review and categorize recommended restart items.

"* Provide a process for the Senior Management Team to review restart issues.

"* Provide an interface with the Restart Overview Panel to review actions from the Building Block Plans, the Restart Station Review Board, the Senior Management Team, or i

Engineering Assessment Board.

"* Provide a process for validation and closure of restart items on the Davis-Besse IMC 0350 Restart List.

"* Maintain a centralized file with copies of documentation related to Building Blocks, Action Plans, and Closure Packages to facilitate reviews by the NRC and oversight organizations.

Page 6 of 23 Revision 4 January 7, 2003

Plan Description Overview There are four significant phases of the Restart Action Plan process to be accomplished to return Davis-Besse to safe and reliable operations. These phases are planning, discovery, implementation, and validation/closure. Each phase is discussed below.

Planning: The planning phase is essential to ensure that all restart issues are properly and thoroughly identified and characterized during the discovery phase. In addition, planning ensures that personnel are properly trained and qualified to perform discovery activities. Planning is accomplished by development of:

• Building Block Plans

• Building Block Discovery Action Plans

• Implementing Procedures

• Restart Implementation Action Plans

• Training

• Schedules Discovery: This is accomplished by performing the activities identified in the Building Block Discovery Action Plans using implementing procedures, and by the day-to-day activities associated with Operations, Maintenance, and Engineering. Emergent issues and findings identified during the performance of the implementing procedures are documented on Condition Reports.

During the discovery phase, it is of utmost importance that all activities are performed and properly documented. This provides the needed evidence to demonstrate to management and the NRC that the staff and contractors at the DBNPS did what was expected by the Davis-Besse Return to Service Plan and the Building Block Plans, and the work was thorough, accurate, and comprehensive in nature. It is also a requirement and expectation that issues identified either during discovery, or by the performance of day-to-day activities are accurately documented on Condition Reports in a timely manner.

Implementation: The Restart Station Review Board categorizes the Condition Reports identified during discovery, and their associated Corrective Actions. Corrective Actions classified as restart are planned as individual activities, or "binned" into Restart Implementation Action Plans to develop a comprehensive approach to managing numerous corrective actions of a similar nature. These corrective actions are intended to fix the physical plant (structures, systems and components), programs, processes and procedures, department functions, and management and oversight prior to restarting the plant. During the implementation phase, it is also important to accurately document what, how, why, when and who performed the associated corrective actions. This documentation allows the development of Restart Closure Packages to demonstrate to the NRC that restart items have been properly completed.

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Validation/Closure: The validation and closure process involves a planned and organized method to gather and validate the documented evidence to demonstrate that the planning, discovery and implementation activities for Davis-Besse IMC 0350 Restart List items have been properly completed or that post restart issues are understood and properly tracked to closure after restart. The Restart Action Database plays a key role in managing restart activities to closure.

Purpose The Restart Action Plan Building Block provides overview, coordination and control of restart activities to ensure the safe, reliable, and sustainable operation of Davis-Besse associated with the ongoing actions under the NRC IMC 0350 Reactor Oversight Process and the Davis-Besse Return to Service Plan. The Restart Action Plan Team maintains the process for, and control of, the Restart Action Database that includes the Davis-Besse IMC 0350 Restart List and the Davis Besse Restart Action List.

The Restart Action Plan Building Block also provides a coordinated interface with the other Building Block Plans, including monitoring, validation and closure of restart items on the Davis Besse IMC 0350 Restart List. The Restart Action Plan Team administers and coordinates the activities of the Restart Station Review Board, Senior Management Team, and the Restart Overview Panel. The Restart Action Plan Team is also responsible for coordinating the preparation of the Integrated Restart Report and tracking post-restart activities while still under the IMC 0350 Reactor Oversight Process.

Organization The Restart Action Plan Team is part of the restart organization (Figure 1) and one of the Building Block Plans subject to oversight by the Restart Overview Panel. The Restart Action Plan Team consists of separate sub-teams to coordinate its various restart activities (Figure 2).

The Restart Action Plan Team Owner reports to the FENOC Chief Operating Officer.

The six sub-teams/boards of the Restart Action Plan Team are the Regulatory Interface Team, Restart Action Process Administrator, Restart Station Review Board, Senior Management Team, Return To Service Plan Administrator and the Validation Team. Each of the sub-teams or boards is headed by a lead or a chairman that has responsibility for the overall actions and products of the sub-team.

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Responsibilities Regulatory Interface Team Each Building Block Team includes a Regulatory Interface Team member assigned to monitor its actions and products. This provides the Restart Action Plan Team with an understanding of the discovery phase of the Building Block Team activities that will define the corrective action recommendations from the Building Block efforts.

The Regulatory Interface Team is responsible for:

"* Providing an interface and liaison between the Building Block Teams and the NRC.

"* Working with the Building Block Owner and team personnel to consult on regulatory issues and ensuring regulatory requirements are understood.

"* Coordinating issues and commitments resulting from Condition Report evaluations, the Confirmatory Action Letter, and emergent plant or industry issues pertinent to restart.

"* Facilitating communication of restart action item status and closure to the NRC.

"* Interfacing with the Building Block Teams to monitor the activities of the Building Block Discovery Action Plans and Restart Implementation Action Plans.

"* Monitoring and assisting, if necessary, the integration of corrective actions into the work schedules.

"* Updating the status of Restart Action Database items.

"* Leading and/or coordinating the efforts to support the NRC inspection, and ensuring Condition Reports are generated for inspection issues.

"* Facilitating the development and presentation of Restart Closure Packages to the NRC.

"* Coordinating resolution of questions or issues resulting from NRC reviews and inspections and documenting final NRC closure and acceptance of completed actions.

"* Generation and maintenance of procedures to implement the actions of this Building Block Plan.

The Restart Action Plan Team is responsible for:

"* The administration of the process for identifying, coordinating, and tracking actions for the Restart Action Database.

"* Coordinating the restart activities of the Restart Station Review Board, Senior Management I Team and Restart Overview Panel.

Page 9 of 23 Revision 4 January 7, 2003

"* Ensuring Condition Reports and Corrective Actions are reviewed by the Restart Station Review Board.

" Maintaining an agenda for the review of items by the Restart Station Review Board and providing administrative support during restart meetings, including documenting the actions for each item.

" Preparing agendas and providing administrative support including the generation of meeting minutes for the Senior Management Team and Restart Overview Panel.

" Maintaining the Restart Action Database and providing status/reports of items included in the database as necessary.

" Distributing copies of Action Plans to appropriate personnel, and maintaining a central file of Action Plans and closure documentation to facilitate reviews by the NRC and oversight personnel.

Restart Station Review Board The Davis-Besse Restart Station Review Board has been established to identify and classify items to be included in the Restart Action Database through a review of Condition Reports, Corrective Actions and other documents. A quorum of the Restart Station Review Board consists of at least four voting members, no more than two of who can be alternates, in addition to the Chairman or Alternate Chairman. Actions by the Restart Station Review Board are approved by consensus. If consensus cannot be reached, a vote will be taken with the majority vote being the final decision.

The Restart Station Review Board is responsible for:

" Review of Condition Reports using the restart criteria (Table 1 and Table 2) to ensure that the Condition Reports that identify issues that need to be resolved and actions that need to be completed prior to restart are added to the Restart Action Database.

" Evaluating and classifying Corrective Actions resulting from Condition Reports designated to be evaluated prior to restart, to determine which actions are required to be completed prior to restart and to ensure that Condition Report corrective actions are added to the Restart Action Database

" Reviewing the list of open Procedure Change Requests, Work Orders, and pending modifications for determination of restart activities.

" Recommending to the Senior Management Team those items to be tracked as IMC 0350 I actions using the criteria from Table 1 and Table 2.

Senior Management Team includes the FENOC Chief Operating Officer, the Plant Manager, the Directors of Nuclear Engineering, Support Services and Work Management and independent oversight. A quorum of the Senior Management Team consists of at least two regular members Page 10 of 23 Revision 4 January 7, 2003

in addition to the Chairman or Alternate Chairman. Actions by the Senior Management Team are approved by a consensus.

The Senior Management Team is responsible for:

"* Reviewing and recommending approval of Building Block Plans and revisions, Building Block Team assignments, and criteria for identification of restart issues.

"* Review and approval of Building Block Discovery Action Plans and Restart Implementation Action Plans.

"* Periodically reviewing the decisions of the Restart Station Review Board to ensure items identified as post-restart are consistent with senior management's expectations.

"* Reviewing and approving additions or revisions to the Davis-Besse IMC 0350 Restart List.

"* Review and concurrence of Restart Closure Summaries as ready for restart.

The Restart Overview Panel consists of three members of the FENOC Executive Management, the Vice President-FENOC Oversight, at least three industry experts and a representative of the Ottawa County government.

The Restart Overview Panel is responsible for:

"* Assessing the comprehensiveness of Building Block Plans, Building Block Discovery Action Plans, and Restart Implementation Action Plans and their implementation.

"* Performing independent oversight and review of plant activities needed for restart to ensure that Davis-Besse is ready to resume power operations and will be safely operated and maintained.

"* Making recommendations for Return to Service for Davis-Besse.

The FENOC Chief Operating Officer is responsible for:

"* Final approval of the Return to Service Plan and subsequent revisions.

"* Final approval of Building Block Plans and subsequent revisions.

"* Approving the Davis-Besse IMC 0350 Restart List and subsequent revisions.

"* Approving all changes to the Integrated Restart Schedule that extend the completion dates of milestones or significantly increase the scope of the outage.

"* Concurrence of Action Item Closure Documents as ready for NRC inspection.

"* Acting as alternate Chairman of the Restart Overview Panel.

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a Providing oversight and direction to the Senior Management Team.

• Final authority to restart the Davis-Besse Nuclear Power Station.

Management of Restart Action Database and Process Restart Action Database: The Restart Action Database tracks restart items classified by the Restart Station Review Board to return the plant to safe and reliable operation and to a condition of management excellence. It contains restart items from both the Davis-Besse IMC 0350 Restart List and the Davis-Besse Restart Action List. The long-term, post-restart actions are maintained in the Restart Action Database, and are evaluated for incorporation into the Davis Besse Operational Business Plan and/or the Regulatory Management System. The Restart Action Database is maintained by the Restart Action Plan Team and provides the basis for review and disposition of items by the Restart Station Review Board and the Senior Management I Team.

Restart Action Review Process: The Davis-Besse Corrective Action Program provides the basis for the majority of the review process. Identified issues from either the Building Block Team reviews, emergent issues, or those identified by the NRC, must be documented on a Condition Report (CR) to begin the review and evaluation process.

The Restart Station Review Board reviews Condition Reports and Corrective Actions and makes the determination if the item meets the IMC 0350 Criteria by evaluating it against the criteria on Table 1. If the item meets one or more of those criteria, it is classified as a Davis-Besse IMC 0350 Restart List item. If it does not fall within the IMC 0350 Criteria, the item is evaluated for restart from the criteria in Table 2. If pre-restart is required, it is included on the Davis-Besse Restart Action List. If pre-restart is not required, the item is evaluated for incorporation into the Davis-Besse Operational Business Plan and/or the Regulatory Management System and added to the Restart Action Database. Items not related to restart are classified as not applicable and are managed using the Corrective Action Program.

The Senior Management Team reviews the addition of new restart actions to the Davis-Besse IMC 0350 Restart List with final approval by the FENOC Chief Operating Officer.

Once the restart determination has been made and the corrective actions have been identified, the issue or action moves forward for implementation. The Engineering Assessment Board reviews actions from the Containment Health Assurance, the System Health Assurance, Reactor Head Resolution, Restart Test, and the Program Compliance plans. If additional issues or actions are identified, those new issues are referred back to the Restart Station Review Board for evaluation and restart determination. Once Corrective Actions have been implemented, closure of the restart item will occur. The Validation Team performs selected in-line reviews and acceptance of Restart Closure Packages for items on the Davis-Besse IMC 0350 Restart List. The Senior Management Team provides final concurrence of Restart Closure Summaries.

The flow chart of the Restart Action Plan Process is shown in Figure 3.

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The Restart Action Database tracks the status of items on the Davis-Besse Restart Action List and the Davis-Besse IMC 0350 Restart List. This tracking process includes an identification of the responsible organization or individual for resolution of the issue, the scheduled completion date for resolution and the actual completion date.

of The Building Block Teams generate action plans to evaluate either in-plant inspections structures, systems and components, or programmatic reviews that generate Condition Reports, Corrective Actions, or reports that document the results of the inspections or reviews performed.

or after These reports may include recommendations for actions to be completed either prior to adequacy and restart. Reports are reviewed by the Engineering Assessment Board for technical completeness.

for If the inspections, corrective actions, or resulting reports generate new recommendations Action restart actions, new Condition Reports are written and evaluated under the Restart Review Process.

NRC Inspection Interface Support for inspections by the NRC for the duration of the NRC IMC 0350 Reactor Oversight Team Process is coordinated by the Regulatory Interface Team. The Regulatory Interface Baseline assesses inspection activities as they are defined by the NRC Oversight Panel.

inspections performed by the NRC may be assigned to the Compliance Unit to monitor, to Service facilitate, and coordinate the inspection. Inspections related to Davis-Besse Return activities and actions are coordinated by the Regulatory Interface Team. Larger team inspections the may require adjusting Regulatory Interface Team resources to cover the scope and breadth of the inspection. This may include the addition of supplemental personnel for the duration of inspection.

the An Inspection Team Lead is assigned for each inspection. The lead coordinates all aspects of support for the inspection, including the entrance meeting, interview schedules, daily briefings, issue resolution, and the exit meeting. A database tracks each inspection issue, documents the reference materials provided to the NRC, and logs Condition Reports generated during inspection.

IMC 0350 Restart List Closure Process Restart Closure packages, which consist of Action Item Closure Documents or Restart Closure Summaries, are developed for restart items on the Davis-Besse IMC 0350 Restart List. Restart Closure packages include the necessary documentation to provide evidence that restart corrective actions have been satisfactorily completed. Restart Closure Packages are independently reviewed by the Validation Team and approved by the Building Block Owners or Responsible Director. The Senior Management Team reviews and concurs with Restart Closure Summaries.

Restart Closure Package development is the responsibility of the Action Plan Owners and associated responsible individuals identified in the action plans.

Revision 4 January 7, 2003 I Page 13 of 23

The Regulatory Interface Team is responsible for providing guidance and support in the development of Restart Closure Packages and for maintaining a central file of closure documentation to facilitate NRC inspections and oversight reviews.

Validation of Closure Packages The validation process ensures consistency and complete implementation of activities associated with the Davis-Besse IMC 0350 Restart List. This is accomplished through a review of documentation associated with selected in-process restart activities and Restart Closure Packages. Validation will be performed on selected individual Condition Reports included in the Davis-Besse IMC 0350 Restart List, and on Action Plans and Building Block Plans. The validation process also considers the results of Quality Assessment oversight activities and Engineering Assessment Board/Program Review Board assessments in determining the adequacy for closure of items on the Davis-Besse IMC 0350 Restart List.

Once approved, Restart Closure Packages will be made available for NRC inspection and acceptance. The Regulatory Interface team provides the interface with NRC personnel to facilitate resolution of questions or issues and documentation of final acceptance and closure by the NRC.

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I- . .

Interface with Restart Outage Schedule The Restart Action Plan Team interfaces with the Work Management organization to include appropriate restart activities into the work activity schedules. This interface is imperative to ensure that those work activities identified within action plans are factored into the Integrated Restart Schedule.

Integrated Restart Report The Integrated Restart Report provides a summary of the restart actions taken at Davis-Besse.

The purpose of this report is to provide an integrated discussion of restart actions and to demonstrate that Davis-Besse is ready for restart. The general outline for this report is provided below:

, Section 1 describes the purpose of the Integrated Restart Report.

SSection 2 provides background information, including a description and chronology of the events leading to discovery of the degradation of the RPV Head, a description of the as found condition of the RPV Head, and a high level summary of the Return to Service Plan and Building Blocks. This section should include a discussion regarding the scope of work that was performed beyond that required by the 0350 process to ensure Davis-Besse is ready to restart.

3 summarizes the safety significance of the as-found condition of the degraded RPV Head and related safety equipment (i.e.. Containment Air Coolers).

>- Section 4 summarizes the Reactor Head Resolution Plan and the results of implementation of the Plan, and demonstrates that the replacement head and restored containment will continue to be able to perform their design basis functions.

5 summarizes the results of the Technical Root Cause Analyses Report, findings and corrective and preventative actions.

) Section 6 summarizes the results of the Non-Technical Root Cause Analysis Report, and associated root causes/evaluations/assessments/reviews (as identified on the Davis-Besse IMC 0350 Restart List, Item 1.b), their findings and corrective and preventive actions.

This section is divided into a number of subsections:

• Summary of the actions in the Management and Human Performance Improvement Plan.

• Summary of the various oversight boards described in the Restart Action Plan.

• A discussion of the results of FENOC's measures for verifying the effectiveness of the corrective and preventive actions, including performance indicators and assessments.

Page 15 of 23 Revision 4 January 7, 2003

This section will demonstrate that FENOC has taken appropriate action to address the causes and contributing factors and to improve performance, and has established appropriate barriers to ensure the adequacy of the work performed during implementation of the Return to Service Plan and associated Building Blocks.

, Section 7 discusses FENOC's discovery activities to determine the extent of condition and significant corrective actions taken to assure that Davis-Besse is ready to restart. This section is divided into a number of subsections:

• Description of the results of the Containment Health Assurance Plan and associated corrective actions (restart and post-restart).

+ Description of the results of the Program Compliance Plan and associated corrective actions (restart and post-restart).

+ Description of the results of the System Health Assurance Plan and associated corrective actions (restart and post-restart).

+ Description of the results of the Functional Area Reviews and associated corrective actions (restart and post-restart).

+ A summary the Restart Test Plan and the results of implementation of the Plan to date.

A summary of other significant actions taken (i.e.. those actions not addressed by the Building Block discussions) to ensure Davis-Besse is ready to support restart and sustained improved operations.

This section will demonstrate that the condition of the plant, programs, and organization are acceptable to support restart.

> Section 8 provides a summary regarding the basis for FENOC's conclusions that the Davis-Besse Nuclear Power Station is ready for restart.

Page 16 of 23 Revision 4 January 7, 2003

Figure 1: Restart Organization Executive Vice ..... ..

President - Engineering Oversig and Services - Independent i Iy Vice President - DB Engineering Assessment Board r------ L------------- -------- -------------------- T----------------1I II T - - - -

I I stem Health Program Containment Restart Test Reactor Head Restart Action urance Plan Compliance Health Plan Resolution Plan Plan Plan Assurance Plant

- Senior Management Team

- Restart Station Review Board Page 17 of 23 Revision 4 1 January 7, 2003

Figure 2: Restart Action Plan Team Oversight: Lew W. Myers Manager Owner: Clark A. Price Regulatory Affairs I. 1------ ------

Regulatory Interface Restart Restart Station Senior Management Return To Service Validation Team Team Action Process Review Board Team Plan Administrator Administrator Page 18 of 23 Revision 4 ' January 7, 2003 I

Figure 3 Davis-Besse Restart Action Plan Process I 1 Validation;Closure Normal CA Closure Process (non-0350 item)

Follow Health Condition

• Normal

.r INC 0350*Completed Corrective RansContainment Building Block Plans ntim t -i Process Restart ListAcin Building Block Assurance Reports Discovery Plans System Health Work Orders Non-RestartYes No Restart Assurance Modifications Implementation Program Compliance Building Block 0350? Actions Identified Adtoa ReouinIMC

--- Reports meets the Restart 3Cionetive Action Plans Reactor Head Reouinrestart criteria? Atoso Implementing Impoedues Management & Human Procedures Performance <"

Excellence No Restart Test Engineering ves:rtAssessment Action List -- Board Davis-Besse Plant Staff Building Block Building Block Owners Restart Station Review Board Regulatory Owners Interface Team Restart Action Plan Team Engineering Assessment Board Senior Validation Team Restart Station Review Board Restart Overview Panel (for Management Senior Management and Human Team Management Performance Excellence)

Restart Team Overview Panel Page 19 of 23 Revision 4 1 January 7, 2003

Table 1: Criteria for Inclusion of an Issue on the Davis-Besse IMC 0350 Restart List

1. Any event, finding, performance indicator or condition that would be ranked as white, yellow or red under the Nuclear Regulatory Commission's Significance Determination Process (SDP).

2. Any cited violations of Davis-Besse's license, technical specifications, regulations or orders under any mode of plant operation.

3. A loss of FENOC's ability to maintain and operate the facility in accordance with the design and licensing basis (for example, a programmatic breakdown or repetitive examples of inadequate design control, including 10 CFR 50.59 plant modifications of equipment important to safety or plant operating practices).

4. A condition or programmatic breakdown indicating a lack of reasonable assurance that FENOC can or will conduct its activities without undue risk to public health and safety (for example, multiple repetitive failures to adhere to procedures that affect risk significant equipment, equipment important to safety or plant operation).

5. A failure of management controls to effectively address previous risk-significant concerns to prevent recurrence (for example, repetitive examples of inadequate root cause evaluations and corrective action(s) affecting risk-significant equipment and/or plant operation).

6. An issue encompassed by a previously identified / existing IMC 0350 issue.

Page 20 of 23 Revision 4 January 7, 2003

Table 2. Restart Screening Criteria for the Restart Station Review Board Issues should be evaluated against Criteria 1 through 9. If Criteria 1-9 do not apply, then identify as not applicable to pre- or post-restart criteria.

Issues shall be designated as restart action items if they satisfy one or more of the following criteria:

1. Nuclear Safety: Required to address a nuclear safety issue.

Issues may be classified as follows:

a. Items that could result in significant personnel radiation exposure, radioactivity release or effluent discharge in excess of limits

b. Cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant impact on nuclear safety. (Not applicable to individual work issues)

2. Operability: Required to address an operability issue.

Issues may be classified as follows:

a. An existing component failure, deficiency or condition that could result in operation in or entry into a Limiting Condition for Operation (LCO) action statement if left uncorrected.

b. Would result in failure or inability to perform a required surveillance test during the current outage or the following operating cycle in accordance with plant technical specifications.

c. Would increase the risk to operation or safety associated with performing a surveillance.

d. Cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on operability. (Not applicable to individual work issues.)

Page 21 of 23 Revision 4 January 7, 2003 1

3. Design Basis: Required to address design margin or conformance with the design basis.

Issues may be classified as follows:

a. Design basis deficiencies, i.e. deficiencies in safety-related or technical specification equipment not in conformance with design basis documents.

4. License and Licensing Basis: Required to address issues requiring a license amendment under 10CFR 50.59 or nonconformance with the license or license conditions.

Issues may be classified as follows:

a. Non-conformance with the license or license conditions.

b. Technical Specification changes or amendments needed under 10CFR50.59 to support safe plant operation.

5. Licensing Commitments: Required to address restart licensing commitments and Confirmatory Action Letter issues.

Issues may be classified as follows:

a. Existing deficiencies or conditions that would result in the failure to meet a Confirmatory Action Letter requirement or a restart commitment to an outside agency.

6. Configuration Management: Required to address an organizational, programmatic or process deficiency that could prevent maintenance of adequate design margins or conformance with a design basis.

Issues may be classified as follows:

a. Deficiencies in configuration management programs, processes, engineering analysis codes or operating, maintenance or test procedures that have a reasonable probability of affecting equipment operability.

Page 22 of 23 Revision 4 January 7, 2003

7. Reliability: Required to address significant equipment material condition deficiencies singly or in aggregate or repetitive failures that could affect safety system availability, impact plant reliability, or reduce the ability of operators to operate the plant safely.

Issues may be classified as follows:

a. Cumulative deficiencies, backlogs or conditions that in the aggregate are evaluated to have significant negative impact on safety system availability or reliable plant operation. (Not applicable to individual work issues.)

b. Degraded critical components or conditions that could result in plant transient, power reduction or shutdown.

c. Conditions that have resulted in repetitive safety system or equipment failures.

Issues that are not classified as restart may be classified as follows if further tracking beyond the Corrective Action Program is desired:

8. Post-Restart Issues:

a. Issue can be scheduled for a subsequent outage.

b. Issue can be readily worked on line, does not affect safe and reliable operation, does not represent a significant challenge to Maintenance Rule Goals or LCO allowed outage time, and does not impair operations necessary to perform surveillance or monitoring.

c. Issue is classified as minor maintenance or housekeeping and does not affect plant operations.

d. Issue is an administrative issue.

e. Issue is a documentation deficiency that has no safety impact.

9. Industrial Safety Concerns: Industrial safety concerns will not be classified as "restart" because the priority and resolution of these concerns will be addressed under the established work control process priorities and scheduling. Although an industrial safety issue is not classified as restart, it will be worked promptly, commensurate with the safety risk.

Page 23 of 23 Revision 4 January 7, 2003 I

Attachment 4 Return Overview Panel Charter Revision 2 December 3, 2002

DAVIS-BESSE RESTART OVERVIEW PANEL Charter PREPARED BY: ___________________ __ _DATE: / 6?o Juith'Hirsch, Restart Action Process Administrator APPROVED BY: DATE :4/4Z .

Lew W. Myers, Chfef Operating Officer Revision 02 EFFECTIVE DATE: December 3, 2002

TABLE OF CONTENTS SECTION TITLE PAGE PURPOSE 3 1.0 POLICY 3

2.0 REFERENCES

3 3.0 RESPONSIBILITY 3 4.0 MEMBERSHIP 5 5.0 TRAINING 6 6.0 7.0 MEETINGS 6 REVIEWS 8 8.0 9.0 RECORDS 8 Scope of Revision 0 Initial Issue 1 Eliminate references to Vice President, clarify duties of Chairman, delete identification of meeting minutes as quality records.

2 Minor editing changes including delete "Restart" from Senior Management Team ROP Page 2 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 1.0 PURPOSE This document governs the function of the Restart Overview Panel for the FirstEnergy Nuclear Operating Company's (FENOC) Davis-Besse Nuclear Power Station under the Davis-Besse Return to Service Plan.

2.0 POLICY The Restart Overview Panel (ROP) shall function to provide an independent oversight and review of plant activities discovered or performed as part of the Davis-Besse Return to Service Building Blocks.

The ROP shall act to overview internal and external plant activities, advising the FENOC President, Chief Operating Officer and Davis-Besse Vice President on any matter relating to the safe resumption of operation of Davis-Besse and provide recommendations as appropriate. Subcommittees and other teams may be created to perform specific review functions on behalf of the ROP. The ROP shall primarily assess the planning, discovery, and implementation of the Return to Service Building Blocks.

3.0 REFERENCES

3.1 FENOC Quality Assurance Program Manual 3.2 ANSI N18.7-1976/ANS 3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants 4.0 RESPONSIBILITY 4.1 The FENOC President is responsible for:

4.1.1 Appointing the ROP chairman, ROP membership and scheduling required meetings.

4.2 The Chief Operating Officer (COO) is responsible for:

4.2.1 Approval of the ROP charter.

4.2.2 Providing corporate direction needed for restart and primary interface for Davis-Besse activities, reporting to the President of FENOC.

4.2.3 Providing direction for the agenda for regular and special ROP meetings.

4.2.4 Recommending candidates for ROP membership, including the alternate ROP chairman.

ROP Page 3 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 4.3 The ROP Chairman is responsible for:

4.3.1 Reviewing and recommending the ROP Charter for approval.

4.3.2 Appointing ROP subcommittee chairmen, alternate chairmen and task force or team members 4.3.3 Conducting ROP meetings, which includes development of agenda, selection of regular meeting dates and special meeting dates, as necessary.

4.3.4 Ensuring that ROP reviews are performed.

4.3.5 Ensuring the generation of ROP meeting minutes.

4.4 The Davis-Besse Senior Management Team is responsible for: 2 4.4.1 Providing members for ROP subcommittees as requested.

4.4.2 Responding to recommendations and action items identified by the ROP.

4.5 ROP members and subcommittee members are responsible for:

4.5.1 Performing in-depth, independent reviews, in areas of their expertise, to identify concerns and carry out the duties defined in this charter.

4.5.2 Making recommendations for Return to Service for Davis-Besse Nuclear Power Station.

4.6 Restart Action Process Administrator is responsible for:

4.6.1 Serving as the ROP Administrator.

4.6.2 Providing the administrative duties necessary to support the implementation of this policy. These duties include, and are not limited to, maintaining this document, ensuring compliance with commitments related to ROP activities, documenting meeting minutes, maintaining files, resolving comments as directed by the Chairman and/or the committee members, and maintaining an action list of open items.

4.6.3 Scheduling Building Block team presentations for ROP reviews.

4.6.4 Ensuring that actions and issues for presentation to the ROP are ready for their review.

ROP Page 4 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 5.0 MEMBERSHIP 5.1 The ROP shall have at least seven members, one of which is the Chairman, with membership from FENOC, Institute of Nuclear Power Operations (INPO), and external industry experts or consultants. In addition to the ROP Chairman, membership is comprised of the following:

"* FENOC President

"* FENOC Chief Operating Officer

"* FENOC Executive Vice President

"* FENOC Vice President - Oversight

"* FENOC Company Nuclear Review Board(CNRB) external member

"* INPO representative

"* External industry experts (2 minimum)

"* Representative of Ottawa County 5.2 Independent reviews may be supplemented through additional industry experts or organizations. S 5.3 The ROP members are selected for their area of expertise. They will be members of the nuclear industry that have many years of industry experience.

They can also be members that represent the general public. Members shall have the overall expertise in industry management, nuclear regulatory process, utility experience, and nuclear plant management experience or community leadership.

5.4 ROP members may invite non-members to participate in ROP meetings with approval of the committee.

5.5 Appointment of committee members, chairmen, alternate chairmen and task force members will be documented in the meeting minutes. This serves as formal appointment in writing and is applicable to the ROP and associated subcommittees.

5.6 ROP subcommittees shall have at least two members, one of which is the subcommittee chairman. Unless approved by the FENOC President, the subcommittee chairman should be an ROP member.

ROP Page 5 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 6.0 TRAINING 6.1 The ROP Administrator shall be responsible to ensure that ROP members 2 complete the required site-specific training.

7.0 MEETINGS 7.1 Meeting Frequency Meetings may be scheduled as needed but not less frequently than once per month. If a situation requires a special meeting, it may be held by having a quorum physically present or by establishing a quorum by a telephone conference call.

Regularly scheduled meetings shall be held at the Davis-Besse site. Special meetings may be held at an alternate location if more accessible on a short notice.

7.2 Quorum A quorum shall consist of not less than six members including the ROP Chairman or alternate Chairman. Additionally, it shall be subject to the following constraints:

The ROP Chairman or alternate Chairman (FENOC Chief Operating Officer) shall be present for all meetings

• No alternates shall participate as voting members in ROP activities.

• A majority must be present to have a meeting 7.3 Meeting Agenda Meeting agenda is prepared by the ROP Administrator, approved by the ROP 2 Chairman or alternate chairman and distributed in advance of the scheduled 2 meeting date. To ensure timely inclusion, ROP members should submit items to be considered for the agenda to the ROP Administrator at least one (1) week prior to the scheduled meeting.

Items to consider for the agenda include:

Time, date, and location of the meeting Discussion/Approval of past minutes Building Block Plan Status Startup Checklist status Subcommittee Reports Specific Topics Input from others; e.g., Vice Presidents Action/Open Items 2 Review of SMT actions ROP Page 6 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 The proposed agenda for regularly scheduled meetings should be distributed to:

ROP Chairman & members Other meeting participants and presenters 2 Perry Vice President Personnel as directed by the Chairman Beaver Valley Vice President 7.4 Conduct of Meeting The Chairman shall preside at ROP meetings. He shall ensure that action desired by the ROP on an item is clearly identified and, if not resolved, carried forward to a future meeting as a recommendation or action item. Discussion on an item will continue until there is consensus on the desired action. When consensus does not exist, the Chairman may request a motion and a vote of the members.

Minority positions shall be addressed in the minutes. Majority approval of the members is required to pass a motion.

7.5 Meeting Minutes 7.5.1 Meeting minutes shall be prepared for the ROP meeting. Results of subcommittee reviews will be documented in the ROP minutes as general discussion in the respective topical areas. The meeting minutes, as a minimum, shall include discussion and recommendations made by the ROP.

7.5.2 ROP and subcommittee meeting minutes, approved by the Chairman, shall be distributed to the members for review within 30 days of the meeting.

Approved meeting minutes are distributed to personnel identified in paragraph 7.3 as applicable. The ROP Administrator shall retain the approved ROP subcommittee meeting minutes.

7.5.3 Three types of follow-up mechanisms are available. All are to be documented in the meeting minutes. Recommendations and action items require formal tracking and resolution. Resolution can be in the form of a formal presentation at the meeting. The resolution must be reviewed and approved by the committee members and documented in the meeting minutes.

a. Recommendations are issued by the ROP as a result of a safety, reliability or management concern and/or issues that warrant the attention of the FENOC President.

b. Action items are issues that are raised during the meeting that warrant the attention of Davis-Besse Building Block Owners.

c. Suggestions are items raised during meetings considered by the ROP membership worthy of formal notation but not requiring response as in

a. or b. above. They will be documented in the meeting minutes.

Formal response is not required and they will not be tracked.

ROP Page 7 of 8 Rev. 02

Davis-Besse Restart Overview Panel Charter Revision 02 8.0 REVIEWS 8.1 ROP members individually performing review of an activity or action shall not have been responsible for that activity or action under review.

8.2 The ROP may create subcommittees to perform specific review functions on behalf of the ROP. Delegated review responsibilities are identified on Attachment

1. Unless directed otherwise, in writing, by the ROP Chairman, the subcommittee is expected to function in accordance with this policy.

2 9.0 RECORDS 9.1 There are no quality assurance records for this Panel.

ROP Page 8 of 8 Rev. 02

Attachment 5 Containment Health Assurance Plan Revision 6 November 1, 2002

Davis Besse Containment Health Assurance Plan Revision: 6 Date:

Owr: T. J. Chambers ersi J. R. Fast Recommend fo Approval RSMT Chairman: L. W. Myers proved by: W. Myers 0

Table of Contents Title Page Summary of Revision Changes ......................................................... 2 Executive Summary ................................................................................ 3 Charter ..................................................................................................... 4 Overall M ethodology Flowchart ...................................................... 5 Containment Health Assurance Evaluation ...................................... 6 General Inspection M ethodology ....................................................... 8 Containment Health Assurance Planning .......................................... 9 Area Remediation Approach ............................................................. 10 As-Left Condition Documentation ......................................................... 13 Page 1 of 15 Revision 6 November 1, 2002

Summary of Revision Changes Revision 6: General editorial changes throughout. Added Fuel Integrity as a Containment Focus area in the Overall Methodology Flowpath and in the text. Removed discussion of and requirements for Independent Inspection Activities. The removal of the Independent Inspections is acceptable due to 1) the fact that a substantial portion of the inspections have already been performed twice, the first a detailed visual (partial scope ) prior to the Boric Acid Corrosion control training and the second a full scope visual after the training was completed, and

2) the Engineering Assurance Board is performing oversight activities on products and reports developed by Containment Health.

Page 2 of 15 Revision 6 November 1, 2002

Executive Summary The purpose of the Containment Health Assurance Plan is to perform inspections and evaluations of Containment Systems, Structures, and Components (SSCs) and assure completion of required remediation activities prior to restart. This will serve to ensure that the condition of containment supports safe and reliable operation. To support this plan, an organization has been put into place to manage and implement activities, provide oversight and provide the communications interface with external organizations.

The plan is focused on determining the extent of primary water stress corrosion cracking of alloy 600 welds in the Reactor Coolant System, and identifying damage that may have resulted from boric acid leakage and dispersion of boric acid in the Containment Building. The plan scope has been expanded to assess and assure the adequacy of several areas based on input from team members, operating experience reviews, and internal and external oversight. These areas include the Containment Emergency Sump, Decay Heat Valve Pit, the Containment Vessel liner, the refueling canal, fuel reliability, and affects of boric acid on Environmentally Qualified (EQ) and non-EQ equipment and Containment Coatings. Action plans for each of these focus areas direct the activities necessary to meet the objectives of this plan. FENOC is using industry experts to assist in evaluating these focus areas and developing needed corrective actions.

Procedures, Work Orders and Condition Reports are used to control field activities and evaluations, and to resolve issues. Inspectors attend training for specific procedures and work orders prior to implementing field activities. This training standard was selected to ensure all inspectors are gathering data with similar, thorough standards and quality attributes. The rigor employed in the development and implementation of the Containment Health Assurance Plan in conjunction with the verification activities being performed by FENOC provides assurance that the Containment (as a whole) and the individual areas specified will be restored to the condition necessary to support safe, reliable operation.

Page 3 of 15 Revision 6 November 1, 2002

Charter The purpose of this program is to perform inspections and evaluations of Containment Systems, Structures and Components (SSCs) and assure completion of required remediation activities prior to restart. This will serve to ensure that the condition of containment supports safe and reliable operation. This will be accomplished by using qualified inspectors and evaluators to characterize and as necessary, correct the condition of the following:

Boric Acid induced degradation sites Containment Vessel Containment Coatings Containment Emergency Sump Decay Heat Valve Pit Alloy 600 material PWSCC indications Threaded and Bolted Connections Fuel Reliability Page 4 of 15 Revision 6 November 1, 2002

OVERALL METHODOLOGY FLOWCHART I

I Develop Methodology I

Train Inspectors on Containment Inspection Requirements / Boric Acid Corrosion Control Containment Focus Areas

"* Emergency Sump Inspections "* Decay Heat Valve Pit

"* Alloy 600 "* Containment vessel liner

"* Threaded / Bolted "* Environmental Qualification Connections

"* Containment Air Coolers I Inspect Reactor Vessel I "* Refueling Canal Leakage

"* Containment Coatings

"* Alloy 600

"* Fuel Reliability 1

Perform / Complete Inspections K' l

All Concerns i Documented in Condition Report Process I 4

Containment Clean Up and Remediation Plans in Place to Resolve Outstanding Issues Formal Report to document our course of 4 action and problem resolution Page 5 of 15 Revision 6 November 1, 2002

Containment Health Assurance Evaluation Organization:

To implement this plan, an organization has .been put into place to manage and provide oversight of plan activities as well as interface with external organizations. The organization, consisting of an overall Owner, Oversight team, Engineering team, Field team, and Communications team provides the ownership and leadership for the Containment Health Assurance Plan.

The Engineering Assessment Board (EAB) has the responsibility to provide oversight to the organization. This Board provides an independent outside look, validates plans, procedures, and[

processes.

The Engineering team has the overall responsibility for the scope development, plan and procedure development, evaluation of results, determination of appropriate corrective actions, and verification that corrective actions are adequately implemented in the field.

The Field team is responsible for inspection and data gathering for procedures developed by the Engineering team, and implementation of hardware related corrective actions resulting from the Engineering team's evaluation of condition reports.

The Communications team is responsible for interfacing with external organizations and ensuring information as requested by these organizations is collected, reviewed and provided to the respective organizations.

Containment Extent of Condition Evaluation:

There are two specific degradation mechanisms observed on the Reactor Vessel head that will be addressed in this Extent of Condition Evaluation. The mechanisms are Primary Water Stress Corrosion Cracking (PWSCC) and Borated Water Corrosion.

The Extent of Condition will be evaluated via walkdowns of Systems, Structures and Components (SSCs) within Containment. In defining the scope of the walkdowns, three separate criteria were developed to ensure that a bounding evaluation is performed. These criteria are:

(1) Sources: I As used in this evaluation, Sources are components containing borated water that are considered likely leak locations. The Sources are further divided into three groups: Mechanical joints (e.g., valve packing, valve flanged bonnets, thermowells, manways, handholes, and Reactor Coolant Pumps), Alloy 600 components/welds, and instrument tubing. The Alloy 600 components/welds are susceptible to PWSCC.

Page 6 of 15 Revision 6 November 1, 2002

Inspection procedures will be used to ensure that Mechanical Joints and Alloy 600 components/welds within the Reactor Coolant System (RCS) pressure boundary are inspected. The inspection scope includes inspection of Alloy 600 components/welds and Mechanical Joints (including valve bonnets). Upon completion of the inspection procedures, 100% of these defined Sources within the RCS Pressure boundary will have been inspected in 13RFO and will assure that evidence of RCS leakage from any source is properly evaluated (including the potential impact on susceptible materials of the RCS pressure boundary).

(2) Targets:

As used in this evaluation, Targets are components within the RCS that utilize materials susceptible to Boric Acid Corrosion (carbon and low alloy steels) as part of the pressure boundary. The Targets include the following RCS components: Reactor Vessel, Once Through Steam Generators (OTSGs), Pressurizer, Reactor Coolant Pumps (RCPs), Core Flood Tanks (CFT), and individual piping sections (e.g. various Hotleg and Coldleg "spools"). Targets will receive a visual inspection of the external surfaces of installed insulation for evidence of leakage (boric acid residue or bulging of the insulation). Where insulation has been removed, a bare metal visual inspection will be substituted. These inspections are included in an inspection procedure. Additionally, each connection point between a Target and non-susceptible piping will be inspected due to the presence of an Alloy 600 component/weld. A Source inspection will verify that no boric acid has migrated undetected under the insulation to reach a susceptible component (Target). This will require removal of insulation to permit a visual inspection. These inspections (external inspection of the insulation and visual inspection of connection points) will provide adequate assurance that there is no undetected degradation of the RCS pressure boundary.

(3) Miscellaneous (non-RCS pressure boundary) SSCs This criterion refers to SSCs that utilize materials susceptible to Boric Acid Corrosion but are not part of the RCS. The intent is to verify that boric acid corrosion has not adversely impacted the function of containment SSCs. Inspection procedures will be used to perform these inspections which will be performed as "Area Walkdowns" by qualified Boric Acid Corrosion Control Inspectors. As-found conditions will be evaluated by the appropriate Engineering organization. The Boric Acid Corrosion Control Inspector Job Familiarization Guidelines are discipline oriented; that is the qualification and training is focused on Electrical, Mechanical, and Structural attributes required for the inspection process.

Page 7 of 15 Revision 6 November 1, 2002

General Inspection Methodology:

(1) Field inspectors who have been trained to conduct thorough inspections based on specific requirements and quality attributes associated with Containment inspections will perform these inspections. Utilizing the systematic approach to training to qualify personnel to perform Containment inspections ensures that they use a common standard in performing their inspections. Inspectors will attend training for specific procedures and work orders prior to implementing field activities. This training standard was selected to ensure all inspectors are gathering data with similar knowledge standards and quality attributes.

(2) Photographs of representative conditions will be made to document the "As-found" condition of each inspection point. Photographs will be made to document any Boric Acid deposits/corrosion discovered during these walkdowns. All findings of boric acid and/or corrosion will be documented under the Corrective Action Program.

(3) The use of visual inspection of Alloy 600 components/welds to detect evidence of throughwall PWSCC requires adequate access to perform a visual inspection. Additionally, the design of component/weld must provide assurance that leakage will be detectable at the surface. This may require additional evaluation of certain nozzles (such as Incore nozzles) to verify that a visual inspection is adequate. The basis for acceptability of a visual examination for these components is provided in Framatome ANP document 51-5018163 00, "PWSCC Extent of Condition Evaluation."

(4) Where evidence of boric acid deposits exists, the source of the deposits and the leak path will be traced to ensure that there is no wastage of the RCS pressure boundary. As an example, it is known that there are boric acid deposits on the seam between pieces of insulation on the bottom of the Reactor Vessel, suggesting that the boric acid came from inside the insulation. It is therefore necessary to perform an inspection under the insulation to determine whether or not there is wastage on the Reactor Vessel and to determine the source of the boric acid. This inspection is being performed under an inspection procedure.

(5) After proper documentation, existing boric acid deposits will be cleaned up. This will prevent future degradation of susceptible materials due to re-wetting of dry boric acid deposits. It will additionally ensure a proper baseline condition for future inspections.

(6) SSCs that have experienced degradation due to boric acid corrosion will be evaluated and reworked or preserved as needed. This will set the standard for future efforts and will serve as a baseline in future outages to determine if there are ongoing issues in Containment.

(7) Additional procedures are in development to support inspections and evaluations. Since training and quality requirements could differ for future procedures job tasks and procedures will be evaluated using the systematic approach to training to ensure individuals are trained and have the skills to complete the task.

Page 8 of 15 Revision 6 November 1, 2002

Containment Health Assurance Planning:

Based in part on the data obtained during containment inspections, operating experience reviews, and internal and external oversight, various specific focus areas have been developed that warrant additional evaluation. Other focus areas may be added to the Containment Health Assurance Plan as evaluations continue. Teams are being established to evaluate each of the following focus areas:

1. Alloy 600 components and welds (Alloy 82/182) within the Reactor Coolant System

2. Containment Emergency Sump material condition and design basis 3.' Decay Heat Valve Pit

4. Containment Vessel Liner

5. Distributed boric acid on Environmentally Qualified equipment

6. Refueling Canal leakage.

7. Containment Air Cooler degradation.

8. Containment coatings

9. Nuclear fuel reliability Action Plans are being developed for each of the focus areas. Procedures, Work Orders, and Condition Reports are used to control field activities and evaluation, and to resolve issues. FENOC is enlisting industry expertise to assist in evaluating these focus areas and developing needed corrective actions. Evaluations and corrective actions will be formally reviewed by the Engineering Assessment Board.

Page 9 of 15 Revision 6 November 1, 2002

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F FV0 8F 2700 DUE TO THE CONTAINMENT AIR COOLERS ACTING AS A CONDENSER, THE CONTAINMENT AIR COOLERS HAVE EXPERIENCED ADDITIONAL BORON BUILD UP. ALL THREE CONTAINMENT AIR COOLERS WILL BE RENOVATED TO SUPPORT PLANT START UP.

Page 10 of 15 Revision 6 November 1, 2002

27 0 DUE TO SERVICE WATER PIPING ACTING AS A CONDENSER, THIS AREA HAS EXPERIENCED ADDITIONAL BORON BUILD UP. THIS AREA WILL BE RENOVATED TO EXHIBIT OUR STANDARDS AND EXPECTATIONS.

A COMPREHENSIVE PLAN WILL BE DEVELOPED TO COMPLETE CONTAINMENT REMEDIATION.

Page 11 of 15 Revision 6 November 1, 2002

Alloy 600 Weld Detail of Pressurizer Link to Inspection Plan Data Sheet or Pictures by double clicking on hyperlink PZR-08 PZR-08 In___ition Pictures Plan

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MJUM,'a.1 Inspection. Plan IP-M-028: Alloy 600 Extent of Condition Data Sheet Serial Number

• Pre-nspecto n .briefconducted prior to Containment entry (stop 4.3): [3 Yes [ No Data Packge reviewede scopelboundaries understood and dwgs. available. [M Yes ] No If Insulated, perform 'as found" inspection of insulated components (siep.6.1.). Yesv~

anddesaClen/cear NoPAZ14SetIo C(*veon4-q vl,¢-ý,*c *..,-4-*4 0] Insulation installed []Insulation, removed (locate and inspect) ",\*9 Seams Clean/cdear Yes [I No Clean~ctaar: 0] Yes C1 No Free of buiging: F1 Yes El Noi ,%,.%*'Or%,-'*

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"As found" inspection of RI A 3600 inspection of weld area is required.

N The inspection must be from within 6' or optical enhancement must oe used.

Component[Weld/ Connection: ( Illumination verified (CO r. (t 1ri2.n,*=aA . ",,. , j _

(step 6.2) S] A photo taken of each componentfweld/connection Free of evidence of leakage:. M] Yes 0 No Free of corrosion: r1 Yes r" No Free of boric acid crystals: 0 Yes No Description of Identified Leakage: Photo taken [j Continued []

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Recommended preservation actions. or actions for facilitating future inspections (step 6.8): None. j]

Continued 0 Comments: If applicable, then annotate:

t4b soec'At Ada. AOttc- ro S;ae , Notification of Shift Manager.

?ý-,o"s AachJc(4. Time Date Notification of Plant Eng Mgr.

Time Date Continued 0 r CR Number_

Examined by: J111LC0 a 0 MID Tag, Work Request or WO 0.0i EXU~l*W DatNumber._____________

Reviewed by. 1/II"/it'2 ( Photo(s)

File Name/Location Supervisor S_____________________ r"\1f- In -&"1.Ml4#

Page 13 of 15 Revision 6 November 1, 2002

Page 14 of 15 Revision 6 November 1, 2002 ZOOZ'l J-IqTUOAON 9 UOTSTAQ-d g I jo gI OiNd zo- 11-170 ZO-80-NZJ S.

Attachment 6 Reactor Head Resolution Plan Revision 1 July 10, 2002

Davis-Besse Reactor Head Resolution Project Review Revision 1 Date 6' o'Q Prepared by: E. D. Baker Ov ht: R. W. Schrauder RSMT Chairman: H. W. Bergendahl Approved by: I[W. Myers Revision 1 is a total rewrite, therefore revision bars are not included.

2

Table of Contents Title Page Executive Summ ary .............................................................................. 2 Charter / Purpose ................................................................................... 4 B ackground ........................................................................................... 5 D iscussion ............................................................................................. 6 Milestone Activities and Proposed Milestone Schedule ........................ 8

"*Procurement and Certification of the replacement RPV Head ........ 8

"*RPV Head Modifications, including adding Inspection Holes for more Effective Inspections ...................... 9

"*Temporary Fuel Removal from the Reactor and Subsequent Refueling .............................................................. 10

"*Access to the Davis-Besse Containment for removal of the original RPV Head and placement of the new RPV Head on the RPV Head Stand .......................................... 10

"*Installation of new RPV Head, including Transfer of existing Service Structure and existing CRDMs to the new RPV Head .............................................................. 10

" Restoration, Inspection, and Testing of the RPV Head and Containment .................................................. 11

"* Storage and/or Disposal of original Davis-Besse RPV Head ........ 11

"*Updating the Design and Licensing Basis Documents .................. 11

"*Proposed Milestone Schedule ..................................................... N/A C onclusion ............................................................................................ 13 Page I of 13 Revision I July 10, 2002

Executive Summary:

During the Davis-Besse 13th Refueling Outage (13RFO), an inspection of the reactor pressure vessel (RPV) head nozzles was performed pursuant to NRC Bulletin 2001-01, "Circumferential Cracking of Reactor Vessel Head Penetration Nozzle." Extensive corrosion of the RPV Head was identified during this inspection that required either major repairs or replacement of the RPV Head. Condition Reports were written and a Root Cause¢ Analysis was prepared.

FirstEnergy Nuclear Operating Company (FENOC) has made the decision to replace the degraded RPV Head with an unused one from the cancelled Midland Unit 2 Nuclear Power Plant. The replacement RPV Head is a Babcock and Wilcox design, and with minor modifications, can satisfy the applicable Nuclear Regulatory Commission (NRC) rules and industry requirements.

The major attributes of this Plan include:

"* Procurement and Certification of the replacement RPV Head

"* RPV Head Modifications, including adding Inspection Holes for more Effective Inspections

"* Temporary Fuel Removal from the Reactor and Subsequent Refueling

" Access to the Davis-Besse Containment for removal of the original RPV Head and placement of the new RPV Head on the RPV Head Stand

"* Installation of new RPV Head, including Transfer of existing Service Structure and existing CRDMs to the new RPV Head "N Restoration, Inspection, and Testing of the RPV Head and Containment

"* Storage and/or Disposal of original Davis-Besse RPV Head

"* Updating the Design and Licensing Basis Documents

"* Proposed Milestone Schedule A temporary access opening will be made in the Davis-Besse containment vessel and shield building to allow for transfer of the replacement RPV Head into the containment building and removal of the original RPV Head. The shield building and containment vessel at Davis-Besse will be restored to meet design requirements. An integrated leak rate test (ILRT) will be performed to verify containment integrity.

The degraded RPV Head will be temporarily stored at Davis-Besse. Final plans for permanent storage or disposal are under development.

Bechtel has been contracted to provide engineering services for the RPV Head replacement, including overall project management, detailed engineering, licensing support, quality assurance, and project controls.

Framatome-ANP has been contracted to procure and certify the replacement RPV Head, including modifying the RPV Head as required, providing a Certificate of Conformance Page 2 of 13 Revision 1 July 10, 2002

documenting that the replacement RPV Head is suitable for use at Davis-Besse, and providing engineering and required evaluations to ensure the Davis-Besse design and licensing requirements are met (including ASME code criteria).

The RPV Head replacement is a modification to the facility and will be performed in accordance with the provisions of 10 CFR 50.59 criteria. Completion of this modification will resolve the issue concerning boron corrosion degradation of Davis Besse's RPV Head, including disposition of the associated corrective actions, and performance of more effective periodic head inspections allowing for early detection of RPV Head degradation due to the addition of the inspection holes. This will enable Davis-Besse to return to safe and reliable operation.

Page 3 of 13 Revision 1 July 10, 2002

Charter:

Reactor Vessel Head Resolution Plan Restore the degraded Davis-Besse RPV Head such that it is in full compliance with appropriate Commission rules and industry requirements.

Purpose:

The purpose of this Building Block is to identify the milestone activities and proposed schedule associated with the Reactor Vessel Head Replacement Project. It is intended to be management's communication and direction to the site staff, not a procedure. Work is expected to be performed in accordance with existing procedures and processes. If the required procedures and processes do not exist, they shall be developed to control the activities to ensure applicable 10 CFR 50 Appendix B criteria are met.

The Reactor Vessel Head Replacement Project consists of the following milestone activities:

"* Procurement and Certification of the replacement RPV Head

"* RPV Head Modifications, including adding Inspection Holes for more Effective Inspections

"* Temporary Fuel Removal from the Reactor and Subsequent Refueling

"* Access to the Davis-Besse Containment for removal of the original RPV Head and placement of the new RPV Head on the RPV Head Stand

"* Installation of new RPV Head, including Transfer of existing Service Structure and existing CRDMs to the new RPV Head

"* Restoration, Inspection, and Testing of the RPV Head and Containment

"* Storage and/or Disposal of original Davis-Besse RPV Head

"* Updating the Design and Licensing Basis Documents

"* Proposed Milestone Schedule Page 4 of 13 Revision 1 July 10, 2002

Background:

Davis-Besse is a raised loop pressurized water reactor (PWR) manufactured by Babcock

& Wilcox (B&W). The current reactor licensed thermal output is 2,772 megawatts. The plant achieved initial criticality on August 12, 1977. The Reactor Coolant System (RCS) has an operating pressure of 2,155 psig and a design pressure of 2,500 psig. Davis-Besse has accumulated 15.78 effective full power years of operation when the plant was shut down for 13RFO.

On August 12, 2001, Davis-Besse received NRC Bulletin 2001-01, "Circumferential Cracking of RPV Head Penetration Nozzles." In subsequent discussions with the NRC on November 28, 2001, FENOC committed to perform a qualified visual inspection, non destructive examination (NDE) of 100% of the CRDM nozzles and characterization of flaws. These inspections were performed during 13RFO in March 2002. In the course of the inspection, significant degradation of the RPV Head base metal was discovered between nozzles 3 and 11, in addition to some minor corrosion at nozzles 2 and 46.

Condition Reports were written documenting the adverse conditions and a Root Cause Analysis was prepared.

Due to the degradation of the RPV Head FENOC has made the decision to replace the degraded RPV Head with an unused one from the cancelled Midland Unit 2 Nuclear Power Plant. Delivery of the replacement RPV Head is a routine commercial delivery with special road use permitting due to the size and weight of the component. It weighs 110 tons, is approximately 17 feet in diameter, and is approximately 8 and one-half feet in height.

Page 5 of 13 Revision I July 10, 2002

Discussion:

The RPV Head is classified as Nuclear Safety Related, therefore 10 CFR 50 Appendix B applies as well as other applicable regulations, including 10 CFR Part 21.

The RPV Head bolts to the reactor vessel using sixty stud assemblies. The RPV Head serves as part of the primary pressure boundary, support for the service structure, support for the CRDMs, radiation barrier, and the structural hold down for the reactor vessel internals. The RPV Head contains 69 penetrations for the CRDMs. Also, a skirt welded to the closure head provides an attachment for the service structure. It is designed and analyzed in accordance with ASME Boiler & Pressure Vessel Code, Section 111, 1968 Edition with Addenda through Summer 1968, refer to attached illustration.

Replacing the RPV Head, in effect, modifies two of the three fission product barriers that are designed to ensure the protection of public health and safety.

Specifically, the RPV Head is part of the RCS, and plays a key role in preserving the integrity of the RCS. The RCS is the second of three fission product barriers. It must provide a leak-tight barrier under normal operating conditions. During anticipated transients, such as a loss of off-site power, the RPV Head must function to ensure that the RCS pressure boundary remains intact to allow adequate decay heat removal during natural circulation, to prevent fuel cladding damage. It must also function to preserve the flow path of the safety injection systems following accidents such as loss-of-coolant accidents.

The containment structure consisting of the shield building and containment vessel act together to provides the final fission product barrier during normal, off normal and accident conditions. The shield building must provide radiation shielding and tornado missile protection. The steel containment vessel must prevent significant releases of radioactivity to the environment during these same conditions.

In addition, the RPV Head is a significant contributor to ensuring that the first fission product barrier, the fuel cladding, remains intact following anticipated transients and accidents. Since the RPV Head is the primary interface and support structure for the CRDMs, one of its primary functions is to align the control rods with the fuel elements such that negative reactivity can be immediately inserted into the core when required to shutdown the reactor and maintain it in a safe shutdown condition.

The replacement RPV Head will restore the degraded Davis-Besse RPV Head such that it is in full compliance with the appropriate Commission rules and industry requirements.

Completion of this modification will correct the problems associated with the boron corrosion degradation of Davis-Besse's RPV Head, ensuring that the three fission product barriers that are designed to ensure the health and safety of the public are maintained.

Page 6 of 13 Revision I July 10, 2002

Reactor Pressure Vessel Head Stainless Steel Cladding yButtering PT of J groove Weld Page 7 of 13 Revision 1 July 10, 2002

Milestone Activities and Proposed Milestone Schedule:

The following milestone activities provide a description of activities for the success of the RPV Head replacement at Davis-Besse.

Procurement and Certification of the Replacement RPV Head FENOC has issued Purchase Order Number 7094336 (PO) to Framatome-ANP Inc.

establishing the procurement and certification requirements for the replacement RPV Head.

Framatome-ANP has procured the replacement RPV Head under the provisions of 10 CFR Part 21. The replacement RPV Head was designed and manufactured under Section III of the ASME Code. However, following the cancellation of the Midland 2 project, the replacement RPV Head has not been maintained under a quality assurance program under 10 CFR Part 50 Appendix B. To resolve this nonconformance, Framatome-ANP will perform NDE and will provide certification of the replacement RPV Head, consistent with the PO, that meets the requirements of Section III Class A, 1968 Edition, Summer 1968 Addenda. This will include assembling and assessing existing documentation related to the replacement RPV Head, performance of additional NDE tests, including ISI examinations, as necessary, analyses, including reconciliation and verification of acceptability in accordance with IWA-4000 of 1995 Edition through 1996 Addenda of ASME Section XI, Certificate of Conformance and other needed documentation to assure acceptability of the replacement RPV Head.

Framatome-ANP will provide the supporting NDE records ensuring the integrity of the RPV Head. These include:

"* radiographs of the dome-to-flange weld

"* a magnetic particle examination on the head-to-flange weld, including 1/22 thickness of the base metal

"* relief request (RR-A2) for the baseline examination

"* radiograph and surface examination for the CRDM nozzle-to-flange welds, if they do not exist

"* a bottom-up ultrasonic (UT) baseline of the CRDM nozzles Additionally, relief request RR-A26 applicable to ASME Section XI, 1995 Edition through the 1996 Addenda and ASME Section III, 1968 Edition through the Summer 1968 Addenda pertaining to the reactor head-to-flange weld (Weld WH-7) and the CRDM nozzle body-to-flange weld (Weld WH-9) on the radiography of the welds will be submitted prior to installation of the replacement RPV Head.

FENOC will perform a receipt inspection of the replacement RPV Head prior to shipment and arrival at Davis-Besse ensuring that the requirements of the PO are complied with.

The RPV Head will be escorted by appropriate personnel to ensure that no physical Page 8 of 13 Revision I July 10, 2002

damage occurs enroute and that the RPV Head arrives at Davis-Besse in the same material condition as when it left Midland.

RPV Head Modifications, including adding Inspection Holes for more Effective Inspections A number of modifications will be completed to modify the replacement RPV Head support skirt for Davis-Besse. The modifications to the pressure retaining materials of the RPV Head shall be performed in accordance with the Davis-Besse ASME Section X1 Repair/Replacement Program. Framatome-ANP shall notify FENOC of any Non Conformances (NCRs) and modifications which pertain to any of the installed equipment.

These modifications will include:

" installing inspection holes in the support skirt to facilitate more effective inspections allowing for early detection of RPV Head degradation

"* modifying the replacement RPV Head support skirt to fit the Davis-Besse service structure and welding the service structure to the support skirt

"* modifying the replacement RPV Head keyways to ensure sufficient clearance for engagement

"* replacing the 0.500 inch diameter O-rings with a slightly smaller, 0.455 inch diameter O-rings. The replacement O-rings will ensure a proper fit and seal

• installing modified split nut rings for ease of maintenance

• relocating the indexing pins to provide for proper mating of the CRDM flange joint with the Davis-Besse CRDMs

• adjusting/machining CRDM indexing holes to match the Davis-Besse configuration ASME Code reconciliation will be performed in accordance with IWA requirements.

This will include reviews and evaluations to confirm that materials, fabrication, and examination techniques are consistent between the two heads; reviewing replacement RPV Head nonconformances for applicability to Davis-Besse; comparing replacement and Davis-Besse design specifications, design reports, and drawings; and reconciliation of dimensional differences between the replacement RPV Head and the Davis-Besse RPV Head.

These activities will be performed in accordance with ASME Code Section XI as a repair/replacement activity and under the provisions of 10 CFR 50.59 criteria as detailed in EWR 02-0217-00, "Reactor Vessel Head Replacement and Associated Service Structure Modifications" following Davis-Besse procedures. Currently, it is expected that these activities will not require NRC approval in accordance with 10 CFR 50.59.

Page 9 of 13 Revision I July 10, 2002

Temporary Fuel Removal from the Reactor and Subsequent Refueling The Davis-Besse reactor has been temporarily defueled to support the containment opening and the fuel has been stored in the spent fuel pool. Containment structures, systems, and components (SSC) that could impact spent fuel pool cooling will be protected or isolated until subsequent refueling is completed.

Davis-Besse will be refueled using the original Cycle 14 configuration per the Davis Besse reload analysis.

Access to the Davis-Besse Containment for Removal of the Original RPV Head and Placement of the new RPV Head on the RPV Head Stand Prior to opening of the Davis-Besse containment a security plan will be established to control the access opening and all fuel will be removed from the reactor vessel and will be placed in the spent fuel pool. FENOC will address the load path of the RPV Head for a potential load drop. SSCs that are required for the present plant condition will be protected or a determination made that a load drop would not affect the SSCs to perform its intended function. Access to the Davis-Besse containment for removal of the original RPV Head will consist of opening the containment vessel and shield building to allow removal of the original RPV Head. This activity will be performed under the parent document Engineering Work Request (EWR) 02-0146-00, "Containment Structure Access Openings for Reactor Pressure Vessel Head Replacement".

Installation of new RPV Head, including Transfer of existing Service Structure and existing CRDMs to the new RPV Head The existing service structure and CRDMs will be transferred onto the new RPV Head by Framatome-ANP utilizing Davis-Besse approved procedures and processes. The lower service structure flanges and upper support skirt flanges were match drilled for both the replacement and Davis-Besse, therefore, the Davis-Besse service structure will be welded to the replacement head support skirt flange, as detailed in the Framatome-ANP drawings. The RPV Head contains 69 penetrations for the CRDM nozzles. The modifications of the RPV Head are performed under EWR 02-217-00, "Reactor Vessel Head Replacement and Associated Service Structure Modifications".

Page 10 of 13 Revision I July 10, 2002

Restoration, Inspection, and Testing of the RPV Head and Containment Restoration of the Davis-Besse containment will be conducted to ensure that the containment and pressure vessel are returned to their original design configuration by reinstalling the cut sections of rebar with Cadweld rebar splices and/or rewelding rebar, as necessary, (Cadwelding may not be possible in the comers of the openings) and by placing safety related concrete to restore shield building integrity. The restoration activities will be conducted in accordance with the existing design requirements, thus ensuring that the containment vessel and shield building will be capable of performing their intended function. The restoration of the temporary access openings in the service structure will be performed as part of the scope of EWR 02-0217-00. These temporary openings were made in anticipation of repairing the original Davis-Besse RPV Head.

Post modification testing will also include a containment ILRT. This testing will ensure that the design and testing requirements of ASME and other industry standards are complied with.

Storage and/or Disposal of original Davis-Besse RPV Head The degraded RPV Head will be temporarily stored at Davis-Besse. Final plans for permanent storage or disposal are under development.

Updating of Design and Licensing Basis The Davis-Besse design and licensing basis will be updated, as required, to reflect the modification for the replacement of the RPV Head. This will include updating the Davis Besse Design Specification, replacing Davis-Besse head drawings, updating stress reports, updating the USAR and other documentation, as required, in order to maintain both the design and licensing basis and to maintain configuration management consistent with the requirements of 10 CFR 50.

Page 11 of 13 Revision I July 10, 2002

Proposed Milestone Schedule:

LATER Page 12 of 13 Revision I July 10, 2002

==

Conclusion:==

The RPV Head replacement is a modification to the facility and will be performed in accordance with the provisions of 10 CFR 50.59 criteria.

The replacement will restore the degraded Davis-Besse RPV Head such that it is in full compliance with appropriate Commission rules and industry requirements. Completion of this modification will correct the problems associated with the boron corrosion degradation of Davis Besse's RPV Head, including disposition of the associated corrective actions, and performance of more effective periodic head inspections allowing for early detection of RPV Head degradation due to the increased size of the inspection holes. This will enable Davis-Besse to return to safe and reliable operation.

Page 13 of 13 Revision I July 10, 2002

Attachment 7 Program Compliance Plan Revision 4 September 24, 2002

Davis-Besse Program Compliance Plan Revision: 4 Date: September 24,2002 Owner: Neil A. Morrison bersfgtJimPwr Reeorkrfedor Approval RSMT Chairman Approved by Lew W. Myers

Table of Contents Title Page Summary of Revision Changes ............................................................ 2 Executive Summary............................................................................... 3 Program Compliance Plan Charter .......................... 4 Program Compliance Organization Chart .............................................. 5 Plan Description Phase 1: Program Readiness Baseline Assessments ...... 6 Plan Description Phase 2: Program Detailed Reviews .......................... 8 Plant Programs to be Reviewed ................................... 12 Page 1 of 14 Revision 4 September 24, 2002

Summary of Revision Changes Revision 4: The changes in Revision 4 include removal of the Reactor Coolant System Unidentified Leakage Program from the list of programs receiving a Phase 2 detailed review. The program does not exist today, therefore it must be developed, or a similar type of program must be developed prior to restart. In addition to this change, the External and Internal Dosimetry Program was removed from the Phase 1 review list. This program will be reviewed as part of the Radiation Protection Program.

Revision 3: The changes in Revision 3 include the addition of the Summary of Revision Changes page, in accordance with NG-VP-00100, Restart Action Process. The Radiation Protection Program will receive a Phase 2 Detailed Review, which is an addition to this revision. Provisions were made to allow the addition of other programs for a Phase 1 Program Readiness Baseline Assessment, or a Phase 2 Detailed Review, without the need to revise this Building Block Plan. The schedule for Phase 2 Program Detailed Reviews was deleted in this revision.

General editorial changes were made for clarification of wording.

Page 2 of 14 Revision 4 September 24, 2002

Executive Summary Program weaknesses were a major contributor to the degradation of the Reactor Pressure Vessel Head. The program weaknesses identified are:

"* Standards

"* Ownership

• Oversight We have identified the programs on Attachment 1 to receive a Phase 2 review described below. Each of these programs will be reviewed over the next two years. The programs identified as contributing to the degradation of the Reactor Pressure Vessel Head are: the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, , and the Operating Experience Program.

The plan review process will use a two-phase approach.

Phase 1- Program Readiness Baseline Assessment Phase 1 performs a baseline assessment of applicable plant programs to determine if the programs are in a condition to support the restart and safe operation of Davis-Besse. The programs listed in Attachment 1 will receive a Phase 1 assessment prior to restart (with the exception of the Probabilistic Safety Assessment Program, Boric Acid Corrosion Control Program, In Service Inspection Program, Plant Modifications Program, Corrective Action Program, , Radiation Protection Program, and Operating Experience Program that will receive a detailed review prior to restart). The program owner assesses the program by completing a standardized questionnaire. The program owner then presents the results of his/her assessment to a Program Review Board, which includes independent, external personnel. The Program Review Board reviews the program utilizing a screening form. Condition Reports (CRs) will be generated to document program weaknesses and recommendations. The CRs will be evaluated to determine whether the corrective action should be identified as a restart restraint.

Phase 2 - Detailed Program Reviews Phase 2 is an integral part of the long term Comprehensive Management and Human Performance Excellence Plan. This phase is an in-depth systematic review of the programs listed in Attachment 1. This process evaluates programs in depth to ensure that the programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support the restart and safe operation of Davis-Besse. Phase 2 reviews will be completed prior to restart for the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, Radiation Protection Program, and I the Operating Experience Program. The Probabilistic Safety Assessment Program (PSA) will be evaluated as a pilot for the review process. Condition Reports (CRs) will be generated to document program weaknesses and recommendations. The CRs will be evaluated to determine whether the corrective action should be identified as a restart restraint.

Page 3 of 14 Revision 4 September 24, 2002

Program Compliance Plan Charter Perform a review of applicable plant programs to ensure that the programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support the restart and safe operation of Davis-Besse Nuclear Power Station. Prior to restart, perform Phase 2 detailed, systematic reviews of the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, , Radiation Protection Program, and the Operating Experience Program. Prior to restart, perform Phase 1 baseline assessments of applicable plant programs.

Page 4 of 14 Revision 4 September 24, 2002

Program Compliance Organization Chart Page 5 of 14 Revision 4 September 24, 2002

Phase 1: Program Readiness Baseline Assessment Purpose Program weaknesses contributed to the degradation of the Reactor Pressure Vessel Head in the area of standards, ownership, and oversight. Perform a baseline assessment of applicable plant programs to determine if the programs. are in a condition to support the restart and safe operation of Davis-Besse and to ensure condition reports exist to track resolution of program deficiencies. As such, this effort will review the following:

Standards

"* The program attributes comply with those required by basis documents and commitments;

"* The program attributes comply with the "spirit" as well as the letter of the basis documents and commitments.

Ownership

"* The program goals and scope are appropriate;

"* Interfaces and handoffs with other programs or work groups are positively controlled and effectively implemented;

"* The program appropriately implements Operating Experience; and Oversight

"* The program has an appropriate level of management involvement.

"* The program has an owner who is properly qualified;

"* The roles and responsibilities for program implementation are clearly defined and appropriately implemented.

Scope The USAR, Operating License, Technical Specifications, and the Davis-Besse Team Work and Ownership model were reviewed for programs along with contacting selected managers to identify applicable programs for review. Plant Programs that meet the criteria listed below and not selected for a Phase 2 Detailed Review prior to restart will be reviewed under Phase 1 prior to restart.

"* a program that affects the operation of a Structure, System, or Component (SSC) with a safety function,

"* a program that, if deficient or if deficiently implemented, could result in an adverse impact on the safety function of a SSC, Page v

6 of 14 Revision 4 Sevtember SB 24. 2002

• a program that, if deficient or if deficiently implemented, could result in a failure to prevent, detect or correct an adverse impact on the safety function of a SSC.

These identified programs are listed in Attachment 1. Programs that have been identified as under development or are in draft will not be assessed under Phase 1 but will be reviewed under the Phase 2 Detailed Review process following restart and completion of the program development. Additional programs may be designated for a Phase 1 Review based on the recommendation of the Program Compliance Plan Oversight to the Davis-Besse Senior Management.

Methodology for Phase 1 - Program Readiness Baseline Assessment The program owners for the selected programs shall perform an assessment by completing a standardized Baseline Assessment Questionnaire designed to address important program attributes such as ownership, qualifications, and interfaces/handoff control. The program owner will then make a short presentation and make themselves available to the Program Review Board to address questions and issues. The assessment shall be organized as discussed in NG-EN-00385 "Program Compliance Review". The Program Review Board reviews the programs utilizing a screening form. Condition Reports (CRs) will be generated to document program deficiencies. If the Program Review Board determines additional assessment of an item on the screen is needed they shall initiate a CR to direct the performance of a focused self-assessment. The Restart Safety Review Board will evaluate whether any of the CRs should be considered restart restraints. When the program is ready to support the restart and safe operation of Davis-Besse, the Manager of the Program Owner shall make an affirmation to that fact. The Corrective Action process will be used to address issues identified during any step of the assessment process.

Reviews-Proeram Review Board The Program Review Board is a subcommittee of the Engineering Assessment Board and is intended to provide a high level of independence to provide a critical look at the programs.

The Program Review Board shall consist of personnel as defined in NG-EN-00385, Program Compliance Review.

Page 7 of 14 Revision 4 September 24, 2002

Phase 2: Program Detailed Reviews PURPOSE This review is an integral part of the Comprehensive Management and Human Performance Plan. As programs are reviewed, evaluations will be made about standards, ownership, oversight, technical adequacy, and performance indicators. This document provides a general methodology to perform detailed reviews of selected programs. Program weaknesses contributed to the degradation of the Reactor Pressure Vessel Head in the area of standards, ownership, and oversight. This review is designed to ensure that the programs are in full compliance with the basis document(s) or that sound documented technical basis exists for any differences, the programs are fulfilling required obligations including interfaces and handoffs, and are sufficient to support the restart and safe operation of Davis-Besse. As such, this effort will review the following:

Standards

"* The program attributes comply with those required by basis documents and commitments;

"* The program attributes comply with the "spirit" as well as the letter of the basis documents and commitments.

Ownership

"* The program goals and scope are appropriate;

"* Interfaces and handoffs with other programs or work groups are positively controlled and effectively implemented;

"* The program appropriately implements Operating Experience; and Oversight

"* The program has an appropriate level of management involvement.

"* The program has an owner who is properly qualified;

"* The roles and responsibilities for program implementation are clearly defined and appropriately implemented; The Phase 2 review is a comprehensive review that evaluates the foregoing critical aspects of a program. In view of the broad scope of this effort, it is important to obtain outside expertise that will question existing conditions. To this end, outside expertise from other plants as well as contracted expertise will be involved in this effort to prove a high level of independence for these reviews.

Page 8 of 14 Revision 4 September 24, 2002

SCOPE Phase 2 performs a detailed systematic review of the programs listed in Attachment 1. Six programs were identified as contributors in the Root Cause Analysis Report of the technical causes of the degradation of the Reactor Pressure Vessel Head (April 15, 2002). These programs are the Boric Acid Corrosion Control Program, Inservice Inspection Program, Plant Modification Program, Corrective Action Program, Operating Experience Program, and Reactor Coolant System Unidentified Leakage Program. Detailed reviews of these five programs will be performed prior to restart. A program to include Reactor Coolant System Unidentified Leakage will be developed to address the current lack of an integrated approach.

A detailed systematic review will also be performed on the Probabilistic Safety Assessment Program as a pilot review to develop and test the detailed review methodology and the Radiation Protection Program at the direction of the Davis-Besse Senior Management Team.

Additional programs may be designated for the Phase 2 Detailed Review based on the recommendation of the Program Compliance Plan Oversight, to the Davis-Besse Senior Management Team. These additional program reviews may be designated to occur prior to or following restart.

Phase 2 detailed, systematic reviews are scheduled to be performed on the remaining programs listed in Attachment 1 over the next 2 years. A schedule for these programs will be developed and may be modified, as plant needs change in the future.

METHODOLOGY FOR PROGRAM DETAILED REVIEWS The programs will be reviewed in accordance with NG-EN-00385, Program Compliance Review. The methodology is as follows:

Identify the program basis documents and commitments and determine the programmatic elements needed to fulfill the basis document. Review the program implementing procedure(s) and manuals. Compare the basis document requirements against the program implementing procedure(s). Compare the philosophy of the implementing procedures against the philosophy the basis document portrays. Determine if sound technical justification exists for deviations from the bases documents. Include in this portion of the review, consideration of applicable "Owner's Group" or Industry Group implementing policies or accepted alternate approaches to the basis document.

Page 9 of 14 Revision 4 September 24, 2002

• Determine if the program is implemented in full compliance with the spirit and letter of the governing and implementing documents. Verify if the program goals and scope are appropriate. Review condition reports, self-assessments, Quality Assurance audits, Peer Reviews, and NRC audits, to include the time frame of at least the past three years, of the program under review to identify any previously identified areas for program improvement. (The basis for the time frame is that issues identified in self-assessments, audits, or Condition Reports greater than three years old generally have diminished value or no are longer valid because of changes in plant processes, procedures, and organizational structure.) Review corrective actions resulting from the program assessments and condition reports reviewed to determine if they were appropriately implemented and effective. Determine if an appropriate schedule for regular program assessments exists.

Identify key program interfaces and handoffs. Check the interfaces and handoffs to ensure that required supporting interfaces and receiving handoffs are addressed by the procedure of the interfacing programs. Review examples of the program execution. Look for areas that require "tribal knowledge" to be successfully implemented as opposed to procedure or program driven. Verify that interfaces and handoffs with other programs or work groups are positively controlled and effectively implemented. As appropriate, include interviews with groups impacted (interface and handoff) by the program.

" Verify that the roles and responsibilities for program implementation are clearly defined and appropriately implemented. Verify if the program has an appropriate level of management involvement. Verify performance indicators provide an accurate indication of the health of the program.

" Verify that the program has an owner who is properly qualified. Determine if a sufficient number of qualified personnel exist to manage, implement and interface with the program.

Determine if qualification criteria have been established. Determine if appropriate training exists and has been completed.

"* Review Operating Experience (for the past five years) external to Davis-Besse for applicability and potential impact to the program under review. (The basis for the time frame is that programs continuously evolve as better understanding of issues and new technologies immerge. Because of this continuous process the value in reviewing Operating Experience beyond 5 years is greatly diminished). Verify effective implementation of industry lessons learned related to the program.

"* Generate Condition Reports to document identified weaknesses and recommendations for program changes or upgrades identified during the review that will restore compliance with the basis document or correct interface/handoff deficiencies.

Qualifications for the outside expertise is discussed in NG-EN-00385 "Program Compliance Plan."

Page 10 of 14 Revision 4 September 24, 2002

Summary Report The Phase 2 report shall be developed per the requirements of NG-EN-00385 "Program Compliance Review".

The approved report, which includes a listing of the CRs generated, will be submitted to the Restart Action Plan Team, for use in developing and maintaining the Restart Action List.

Review-Program Review Board The Program Review Board (PRB) will review the Summary Reports to ensure the adequacy of the report and recommendations. Comments identified by the board will be addressed within the report.

Following the PRB review and resolution of any comments, the completed program reviews will be reviewed and approved by the Oversight of the Program Compliance Plan for Davis Besse.

Page 11 of 14 Revision 4 September 24, 2002

Attachment 1 Existing Programs to receive Phase 1 review prior to restart and Phase 2 Review after restart.

10CFR50.59 Program Air Operated Valve (AOV) Reliability Program Appendix R and Safe Shutdown Program ASME Section XI Repair, Replacement, and Modification Program Auxiliary Chemistry Control Program Breaker Reliability Program Calculation Control Program Check Valve Reliability Program Chemistry Measuring & Test Equipment Program Commercial Grade Dedication Program Commitment Management Program (TERMS)

Configuration Management Program Containment Leakage Rate Test Program (Appendix J)

Control of Work Controlled Materials Program Core Design & Reload Analysis Program Corrosion-Erosion Monitoring and Analysis Program (CEMAP)

Engineered Spare Parts List Program Environmental Qualification (EQ) Program Equipment Modernization Program Fire Protection Program Foreign Material Exclusion Program Fuel Reliability Program Heat Exchanger Monitoring Program Hydraulic Snubber Program Infrared Thermography Program Inservice Test Program Leak Reduction Program Locked Valve Program Lubrication Monitoring and Analysis Program Maintenance Rule Program Material Receipt Inspection Program Measuring & Test Equipment Program Meteorological Monitoring Program Motor Operated Valve (MOV) Reliability Program Motor Reliability Program On-line Risk Management Program Operability Determination Program Post Accident Sampling Program Predictive Maintenance Program Preventive Maintenance Program Page 12 of 14 Revision 4 September 24, 2002

Primary Water Chemistry Monitoring & Control Program Procurement Program Quality Classification Control Program Radioactive Effluent Controls Program Radioactive Materials Program Reactivity Management Program Safety Tagging Program Secondary Water Chemistry Monitoring & Control Program Service Water System Reliability Program Severe Accident Management Program Shelf Life Evaluation Program Shutdown Risk Management Program Software Control Program Steam Generator Program Management Temporary Leak Sealing Temporary Modification Process Test Control Program Thermal Performance Monitoring Program Transient Counting Valve Packing Program Vendor Manual Control Program Ventilation Filter Testing Program Vibration Analysis Program Welding Implementation & Qualification Program Programs to receive Phase 2 review prior to restart Boric Acid Corrosion Control Program Corrective Action Program Inservice Inspection (ISI) Program Operating Experience Program Plant Modification Program Probabilistic Safety Assessment (PSA) Program (pilot)

Radiation Protection Program Page 13 of 14 Revision 4 September 24, 2002

Programs identified to be developed, to receive Phase 2 review after restart Alloy 600 Program Barrier Control Program Buried Commodities Program (Cathodic Protection)

Cable Reliability Program Containment Coating Program Controller Reliability Program Electrical Load Control Program Grid Reliability Program Material Reliability Project Program Power Supply Reliability Program Protective Relay Program Pump Reliability Program Relief Valve Reliability Program Set Point Control Program Page 14 of 14 Revision 4 September 24, 2002

Attachment 8 System Health Assurance Plan Revision 5 December 6, 2002

Davis-Besse System Health Assurance Plan Revision: 5 Date: December 6, 2002 J.Wwn ers sight:J. J. Powers "Reco o-r pproval SMT Chairman Approved by: L.4W. Myers

Table of Contents Title Paize Summ ary of Revisions .......................................................................... 2 Executive Summ ary ............................................................................ 3 Operational Readiness Review ............................................................ 6 Purpose ....................................................................................... 6 System s Selected for Review .................................................... 6 Operations Readiness Review Panel ........................................... 8 System H ealth Readiness Review s ....................................................... 9 Purpose ............................................................................................ 9 System Selected for Review ..................................................... 11 Organization Chart .................................................................. 12 Flow Chart ................................................................................. 13 Latent Issues Review Guideline ......................................................... 15 Purpose ..................................................................................... 15 System s Selected for Review .................................................... 17 Organization Chart .................................................................. 18 Flow Chart ................................................................................. 19 .................................................................................. 21 Attachm ent 2 .................................................................................. 22 Page 1 of 23 Revision 5 December 6, 2002

SUMMARY

OF REVISIONS Description of Change Reason for Change Area of Chan e Issuing Revision 5 on Changed revision number Signature Page December 6, 2002 and date Changed "...review Based on new direction Page 3, third bullet of from management, the EAB products..." to "...review Executive Summary will not be required to selected products..."

review the final SHRR reports. The EAB review of other documents was maintained.

Changed last sentence to Based on new direction Page 4, last paragraph of from management, the Plant require Plant Manger System Health Readiness Manager will have final approval of reports instead Reviews of EAB review. approval of SHRR reports.

EAB review will not be required.

Changed the sentence Based on new direction Page 10, last paragraph of from management, the Plant stating the EAB will review System Health Readiness Manager will have final the report to Plant Manager Reviews approval of SHRR reports.

approval of the report EAB review will not be required Updated to match procedure Editorial Page 1, Table of Contents Editorial Capitalized the first letter of Page 6, Systems Selected For Review each word in section heading and Revision made to align with Deleted the words... ",

Page 4, Third Paragraph the Return to Service Plan the Restart Senior Management Team chaired and NG-VP-00100. RSMT by the Vice President will not be approving these Nuclear will approve the reports.

report."

Deleted these two Revision made to align with Page 17, Second and Third the Return to Service Plan paragraphs that discussecI Paragraphs and NG-VP-00100. The review and approval of th e:1 Latent Issues Reviev RSRB and the RSMT will Reports by the RSRB an d not be approving these reports.

the RSMT.

Revision 5 December 6, 2002 1 rage 2-ot z

Executive Summary The purpose of this program is to perform reviews of system health prior to restart to ensure that the condition of the plant is sufficient to support safe and reliable operation.

This will be accomplished using the following 3-step approach, an Operational Readiness Review, System Health Readiness Reviews, and Latent Issues Reviews. Other measures that will help ensure the success of the Davis-Besse System Health Assurance Plan are listed below:

"* A substantially new Davis-Besse management team with a demonstrated track record is in place

"* The FENOC Engineering Principles and Expectations were issued on July 10, 2002, and these new principles and expectations have been communicated to the system review team members

"* An Engineering Assessment Board was implemented on June 28, 2002. This board, largely made up of outside experts with proven high standards, will independently review selected products from the system reviews to ensure technical adequacy

1. Operational Readiness Review The Operational Readiness Review is complete and was performed to identify whether systems have significant shortcomings, and to initiate immediate actions to correct those problems. These reviews were initiated prior to entry into the 0350 process. Systems for review were selected considering system performance relative to the Maintenance Rule performance criteria, materiel condition, and operator burdens. The reviews were performed under the direction of the Plant Manager and included representatives from various site organizations.

2. System Health Readiness Reviews System Health Readiness Reviews will be performed on all risk significant Maintenance Rule systems. These reviews are more thorough than the Operational Readiness Reviews.

These reviews are focused to provide reasonable assurance that these systems can perform their risk significant maintenance rule functions. These reviews include identification of the system's risk significant functions, reviews of testing or review of other information (like trending data) that assesses the system's ability to support the system risk significant functions, walkdowns, and reviews of selected data sources Problems identified during the reviews will be captured in the CR process. The Restart Station Review Board will review all CRs for restart requirements.

The original scope was described as selected Maintenance Rule and Technical Specification systems. Further evaluation has resulted in clarifying the scope of the reviews to include all Maintenance Rule Risk Significant systems not covered by the more extensive Latent Issue Review process. This is a risk-based approach that focuses plant resources in the highest risk areas. By performing these reviews on the identified systems, issues can be corrected that could potentially impact a system's ability to perform its risk significant maintenance rule functions.

Paqe 3 of 23 Revision 5 December 6, 2002 I I

Additionally, these reviews may identify programmatic issues that could impact other less risk significant systems and functions. As these programmatic issues are identified, CRs will be initiated and evaluations will be performed to determine if additional System Health Readiness Reviews should be performed. The Plant Manager will have final approval of all reports.

3. Latent Issues Reviews Latent Issues Reviews of the Reactor Coolant System, Auxiliary Feedwater System Emergency Diesel Generators, Service Water and Component Cooling Water systems will be performed prior to restart. The five systems selected for Latent Issues Reviews include 3 systems (Reactor Coolant, Auxiliary Feedwater, and Emergency Diesel Generators) with identified weaknesses and two systems (Component Cooling Water and Service Water) chosen based on their importance. The primary focus of these reviews is to provide reasonable assurance that these systems can perform their safety and accident mitigating functions. These reviews will be comprised of three major efforts. These efforts are the assessment of system attributes, review of various data sources, and walkdowns. The collective significance of problems identified during the Latent Issues Review will be evaluated to determine if further actions are required. Problems identified during the reviews will be captured in the CR process. The Restart Station Review Board will review all CRs for restart requirements.

The Plant Engineering Manager and the EAB and will review the Latent Issues Review Report for each system. identifies the list of systems that will not have a System Health Readiness Review or a Latent Issues Review performed. Attachment 2 is a matrix that compares the various documentation/data sources that will be made available for review for the Operational Readiness Reviews, System Health Readiness Reviews, and Latent Issues Reviews.

Inspections will also be conducted to look for evidence of boric acid leakage and degradation on select systems outside of containment. These inspections will be performed as part of the System Health Readiness Assurance Plan. In addition to the materiel condition walkdowns being performed during the System Health Readiness Reviews and the Latent Issues Reviews, a separate boric acid inspection of systems outside of containment (as listed below) will be performed in accordance with procedure EN-DP-01506, Borated Water System Inspections Outside Containment.

Boric Acid Addition Containment Spray Core Flood Decay Heat High Pressure Injection Letdown (included in Makeup)

Makeup System Reactor Coolant Drain Reactor Coolant Quench Tank Circulation Seal Injection Reactor Sample System, Radwaste/Post Accident Spent Fuel Pool Cooling & Filtering Page 4 of 23 Revision 5 December 6, 2002 I

System Health Assurance Charter Charter: Perform reviews of system health prior to restart to ensure that the condition of the plant is sufficient to support safe and reliable operation. Three levels of system reviews will be performed. An Operational Readiness Review of systems important to the safe and reliable operation of Davis-Besse was performed. A System Health Readiness Review of all Maintenance Rule risk significant systems not covered by the more extensive Latent Issue Review process will be performed. Latent Issues Reviews of the Reactor Coolant, Emergency Diesel Generators, Auxiliary Feedwater, Component Cooling Water, and Service Water systems will be performed to identify any latent issues, and to provide reasonable assurance that these systems can perform their safety and accident mitigation functions.

Page 5 of 23 Revision 5 December 6, 200, I1

Operational Readiness Review Purpose To perform reviews to assure selected systems and programs are ready to return to service and run reliably through Cycle 14 and beyond. This review is complete. A CR was initiated to track the open items.

The information reviewed was similar to the information contained in the Quarterly System Health Report with regards to window colors relative to the Maintenance Rule performance criteria, materiel condition, and operator burdens. Additionally, the issues below were reviewed:

"* Significant issues or corrective actions resulting from recent Condition Reports (CRs)

"* System/component issues representing operational mode restraints

"* Latent issues relating to systems or system components

"* Issues warranting consideration based on Operating Experience from this, or other facilities Lastly, the Responsible Engineers provided an analysis of their system's health and where required, identified modifications or maintenance required to sustain or improve overall system health and reliability.

Systems Selected For Review Systems were informally selected based on:

"* Systems identified with Red or Yellow performance

"* Maintenance Rule safety significance

"* Significance in delivering power to the grid

"* Amount of maintenance and modification activities scheduled for 13 RFO

"* Systems suspected of having latent operation and maintenance issues

"* Amount or significance of recent CRs

"* Systems posing undue operations and maintenance burden

"* Industry operating experience This review included the following systems:

"* Auxiliary Feedwater

"* Containment Vessel Gas Monitoring

"* Emergency Diesel Generators

"* Essential & Miscellaneous AC

"* Station and Instrument Air

"* Instrument Isolation Valves

"* Main Turbine

"* Main Generator Page 6 of 23 Revision 5 December 6, 2002 1

• Moisture Separator Reheaters

• Excitation

• Fire Protection

• Annunciators

• Switchyard and Transformers

• Boric Acid Addition

• Component Cooling Water

• Decay Heat/Low Pressure Injection

• High Pressure Injection

• Makeup and Purification

• Reactor Coolant

• Service Water

• Steam Generators 0 Auxiliary Boiler/Auxiliary Steam

• Chlorination 0 Circulating Water

• Condensate

• Demineralized Water 0 Main Feedwater Pumps/Turbines/Piping

• Startup Feedwater Pump

• Fuel

• Main Steam

• Motor Driven Feedwater Pump

• 125/250 VDC

• Anticipatory Reactor Trip System

• Control Rod Drive

• Integrated Control System 0 Non-nuclear Instrumentation 0 Radiation Monitoring

• Reactor Protection System

• Safety Features Actuation System

• Steam Feedwater Rupture Control System

• Clean Waste/Waste Gas

• Containment Air Coolers

• Cranes Page 7 of 23 Revision 5 December 6, 2002 1

Operations Readiness Review Panel The respective System Engineer presented the following information:

"* Significant issues or corrective actions resulting from recent CRs

"* System/component issues representing operational mode restraints

"* Latent issues relating to systems or system components or other

"* Issues warranting consideration based on Operating Experience from this, facilities

"* Program, procedure or drawing inadequacies Readiness Review. The The System Review Panel reviewed the results of the Operational System Review Panel consisted of the following personnel:

"* A Plant Engineering Supervisor

"* A Maintenance Superintendent with operations experience

"* Operations Superintendent

"* Operations Support Superintendent or a Senior Reactor Operator designee

"* Quality Assurance Representative (Optional)

"* Design Engineering Representative (Optional)

"* Outage Management Representative (Optional)

"* Online Scheduling Representative (Optional)

"* Business Services Representative (Optional)

The Plant Manager chaired the Panel.

Revision 5 December 6, 2002 1 Page 8 of 23

System Health Readiness Reviews Purpose System Health Readiness Reviews will be performed on all risk significant Maintenance Rule systems to provide reasonable assurance that these systems can perform their risk significant functions prior to restart.

System Engineers will coordinate reviews with representatives with experience in Design Engineering, Operations, and Maintenance. Training for System Engineers will be performed prior to performing the reviews to ensure expectations are clear and review details are properly understood.

Reviews will be performed to identify:

0 Risk significant functions of the identified system or subsystem. Follow-on activities will confirm the ability of the systems to satisfy these functions.

• Testing, or review of other information (like trend data) that assesses the systems ability to support risk significant functions.

0 Preventive maintenance activities that monitor and assess the condition of selected components that support the system risk significant functions and verify adequacy of those activities.

• Completed equipment CRs initiated since 1995 affecting the system risk significant functions. 1995 was selected because extensive reviews were conducted in the late 1980's and there was relatively little change in personnel turnover both from a management and worker level perspective between those reviews and 1995.

0 Corrective Work Orders initiated since 1995 affecting the risk significant functions and verify that degrading trends are not developing.

• Modifications initiated since 1990 to address deficiencies of the system to support risk significant functions and ensure identified problems were properly resolved.

1990 was selected because this was the timeframe in which the modification for the reactor head service structure inspection ports was identified and subsequently deferred. Additionally, documents could have been initiated before 1995 but acted on after 1995.

• Industry Operating Experience initiated since 1995 that supports the system risk significant functions and verifies incorporation of lessons learned.

• Violations and non-cited violations initiated since 1995 and verify adequacy of the resolutions.

• Equipment Operators and Reactor Operators shall be interviewed for their impression of how the system and system components are performing.

Maintenance personnel shall be interviewed to see if they that have worked on components receiving repetitive corrective maintenance. The technicians shall be questioned in a manner that will promote insight into potential problems and solutions.

Page 9 of 23 Revision 5 December 6, 2002 I

The review of documents listed above will mainly be those documents associated with components and equipment that support the risk significant maintenance rule functions.

System Engineers may also choose to review documents on additional components or equipment based on performance history, industry operating experience, or other reasons.

The review will also include a system walkdown, with operators and maintenance personnel to aid in assessing the materiel condition of the system. All System Health Readiness Review systems identified in this plan will be walked down per procedure EN DP-01503. Walkdown attributes and the results of the walkdowns will be recorded. In addition to walkdowns for the systems identified for System Health Readiness Reviews, the Auxiliary Building will be walked down under this plan as part of the Boric Acid Extent of Condition.

Existing programs will be utilized to resolve conditions identified by the reviews.

Conditions (either individually or collectively) that could impact the function or reliability of the system will be documented by CRs. CRs will be reviewed for collective significance across system boundaries. Conditions identified as potential restart work, will be reviewed by the Restart Station Review Board for inclusion in the Restart Action List, and will be corrected prior to restart. Corrective Maintenance will be scheduled and executed under the Work Management Program. Items that do not require immediate correction may be included in a post-restart tracking list.

A report will be prepared by the System Engineer to identify the results of the review including specific items reviewed as well as specific items not reviewed with the related justification. The Plant Engineering Manager and the Plant Manager will review this report.

Page 10 of 23 Revision 5 December 6, 2002 I I

Systems Selected for Review The scope of this review includes the following identified risk significant systems:

System Responsible Engineer Oversight Containment Vessel M. Beier J. Cunnings Decay Heat / Low Pressure Injection B. Villines J. Cunnings High Pressure Injection B. Villines J. Cunnings Makeup J. Marley J. Cunnings Steam Generators D. Gerren J. Cunnings Auxiliary Boiler T. Gulvas J. Cunnings Condensate/Condenser T. StClair J. Cunnings Feedwater D. Haley J. Cunnings Main Steam D. Haley J. Cunnings Station & Instrument Air D. Dreier J. Cunnings HVAC, Intake Structure F. Zurvalec J. Cunnings 125 / 250 VDC E. Johnson B. Hovland Anticipatory Reactor Trip System E. Bennett B. Hovland 13.8KV D. Duquette B. Hovland 4160VAC D. Duquette B. Hovland 480VAC J. Fehl B. Hovland 240 / 120 VAC Essential J. Fehl B. Hovland HVAC, Switchgear Rooms F. Zurvalec B. Hovland HVAC, Emergency Core Cooling F. Zurvalec B. Hovland Containment Air Cooling J. Otermat B. Hovland Integrated Control System E. Johnson B. Hovland Non Nuclear Instrumentation E. Johnson B. Hovland Reactor Protection System T. Laurer B. Hovland Diverse Scram System E. Bennett B. Hovland Station Black Out Diesel Generator A. Wise B. Hovland Safety Features Actuation System B. Wharry B. Hovland Steam Feedwater Rupture Control A. Wise B. Hovland Switchyard / Transformers (includes J. Jiamachello B. Hovland Fire Detection in Switchyard)

HVAC, Emergency Diesel Generators J. Otermat B. Hovland HVAC, Component Cooling Water F. Zurvalec B. Hovland HVAC, SBO Diesel Generator A. Wise B. Hovland Page I11 of 23 Revision 5 December 6, 2002 I

System Health Readiness Reviews 10 July 2002 Operations representatives will support system walkdowns and the interviews of Operations personnel.

Maintenance representatives will support system walkdowns and the interviews of Maintenance personnel.

Design representatives will act as points of contact to supply information requested by the System Engineers.

Page 12 of 23 Revision 5 December 6, 22002 1

I aSystem Health and Readiness Review Flow Path t No I Yes 1nitiate CR No Initiate 0350 Tracking No Yes Page 13 of 23 Revision 5 December 6, 2002 1

I Yes Page 14 of 23 Revision 5 December 6, 2002 1

Latent Issues Review Guideline Purpose The purpose of this review is to provide reasonable assurance that the Reactor Coolant System, Auxiliary Feedwater System, Emergency Diesel Generator System, Service Water and Component Cooling Water systems can perform their safety and accident mitigating functions.

A team of on-site engineers and outside experts will conduct the above reviews. Because the intent of this review is to be more comprehensive than other reviews and because the review is looking at systems that have already had multiple inspections, outside experts will be included who will question a condition that station personnel might feel is acceptable. Training for the teams will be performed prior to performing the reviews to ensure expectations are clear and review details are properly understood.

The review will be completed prior to restart and will include the following:

"* Identify system boundaries and key interfaces to ensure the scope of the review is complete.

"* Identify the safety and accident mitigating functions of the systems. Follow-on reviews will confirm the ability of the system to fulfill these required functions.

" Testing or reviews of other information (like trend data) that assesses the systems ability to support safety and accident mitigating functions.

" Review the probabilistic safety assessment (PSA) model for the system under review. This review should utilize the expertise of the PSA engineer. The reviews will confirm that the PSA model includes all the required components and follow on reviews and will confirm that preventive and predictive activities are commensurate with the related risk.

"* Review completed equipment CRs for the system initiated since 1995 to confirm that previously identified problems were adequately addressed. 1995 was selected because extensive reviews were conducted in the late 1980's and there was relatively little change in personnel turnover both from a management and worker level perspective between those reviews and 1995. The reviews will include verification that the specific problem was adequately identified, the determined cause is valid, the extent of condition was adequately determined, that corrective action adequately addressed the cause, and that the corrective action was implemented. Open CRs will be reviewed to ensure that all CRs that support the system's safety and accident mitigating functions will be resolved prior to restart.

"* Review corrective maintenance work orders of the system under review initiated since 1995. The purpose of this review is to identify reliability or recurring problems and consider the need for new preventive maintenance tasks, additional training for a maintenance group, or the need for a new or revised maintenance program or procedure. Open WOs will be reviewed to ensure that all WOs that support the system's safety and accident mitigating functions will be completed before restart.

Page 15 of 23 Revision 5 December 6, 2002 I

"* Review modifications initiated since 1990 to confirm that the modification adequately addressed the original problem, that a new problem was not introduced, that voided modifications had adequate justification for voiding and that outstanding modifications are properly prioritized. 1990 was selected because this was the timeframe in which the modification for the reactor head service structure inspection ports was identified and subsequently deferred. Additionally documents could have been initiated before 1995 but action taken after 1995.

"* Review applicable industry operating experience initiated since 1995 that supports the system's safety and accident mitigating functions to confirm that lessons learned have been adequately incorporated. The review will include applicable Owners Group activities, INPO OEs, NRC Generic Letters, NRC Bulletins, and NRC Notices.

"* Review preventive maintenance activities that monitor and assess the condition of components that support the system's safety and accident mitigating functions.

Verify that existing activities have a basis and that the activities adequately meet the basis.

"* Review the procedures that support the operation, testing and maintenance of the system and ensure their adequacy. Verify the procedures meet the present standards and all required change requests have been acted upon.

"* Review LERs, violations, and non-cited violations initiated since 1995 and verify the adequacy of the resolutions.

"* Equipment Operators and Reactor Operators shall be interviewed for their impression of how the system and system components are performing.

Maintenance personnel that have worked on components receiving repetitive corrective maintenance shall be interviewed. The technicians shall be questioned in a manner that will promote insight into potential problems and solutions.

The review will also include a system walkdown with operators and maintenance personnel to aid in assessing the materiel condition of the system. All Latent Issue Review Systems identified in this plan will be walked down per approved procedure EN-DP-01503. Walkdown attributes and the results of the walkdowns will be recorded.

Existing programs will be utilized to resolve conditions identified by the reviews.

Conditions (either individually or collectively) that could impact the system's safety and accident mitigating functions will be documented by CRs. Conditions identified as potential restart work, will be reviewed by the Restart Station Review Board for inclusion in the Restart Action List, and will be corrected prior to restart. CRs will be reviewed for collective significance across system boundaries. Such conditions identified as potential restart work, will be evaluated for inclusion in the Restart Action List, and will be corrected prior to restart. Corrective Maintenance will be scheduled and executed under the Work Management Program. Items that do not require immediate correction may be included in a post-restart tracking list.

Page 16 of 23 Revision 5 December 6, 2002 I

A report will be prepared by the System Engineer to identify the results of the review including specific items reviewed as well as specific items not reviewed with the related justification. The Plant Engineering Manager and the Engineering Assessment Board (EAB) will review this report. DBE-0001 identifies the roles and responsibilities of the EAB.

I Systems Selected for Review The five systems selected for Latent Issues Reviews include 3 systems (Reactor Coolant, Auxiliary Feedwater, and Emergency Diesel Generator) with identified weaknesses and two systems (Component Cooling Water and Service Water) chosen based on their importance. Thorough reviews of these five systems will provide the opportunity to identify significant programmatic and/or materiel issues that would require additional evaluation.

The scope of this review includes the following identified risk significant systems:

Responsible Engineer Oversight Oversight System D. Adams J. Cunnings Auxiliary Feedwater (includes Condensate Storage Tank, Motor Driven Feed Pump, and Startup Feedwater Pump) I J. Cunnings Component Cooling Water C. Hen~e J. Cunnings JCCunning Reactor Coolant System (includes S. Rowe J. Cunnings PORVs and PORV Block Valves) I fJ. Cunnings Service Water (includes Dilution P. Mainhardt J. Cunnings Pump)* o tni T 1 Emergency Diesel Generator (includes C. Gale 13. t-ovland Fuel Oil and Cathodic Protection on the Fuel Oil Lines) J ______________________________________________

Revision 5 December 6, 2002 I Page 17 of 23

Latent Issue Reviews 10 July 2002 the interviews of Operations representatives will support system walkdowns and Operations personnel. Operations representatives may also perform some review activities as directed by the System Engineers.

the interviews of Maintenance representatives will support system walkdowns and Maintenance personnel.

requested by Design representatives will act as points of contact to supply information the System Engineers.

December 6, 2002 I Page 18 of 23 Revision 5

Latent Issue Review Flow Path I

I Yes YesI Page 19 of 23 Revision 5 December 6, 200:21

S No Revision 5 December 6, 2002 1 Page 20 of 23

ATTACHMENT 1 SYSTEMS NOT BEING REVIEWED Freeze Protection/Heat Trace Dry Fuel Storage Dry Miscellaneous Liquid Radwaste Communications Gaseous Radwaste Screenwash/Chlorine Station Lighting Reactor Nuclear Instrumentation Nuclear Fuel Handling Turbine Plant Cooling Water Sumps Station Heating/Auxiliary Steam Main Turbine/Generator Water Treatment Containment Gas Monitoring/Purge/

HVAC (except Switchgear Rooms and Dilution/Recirculation/Spray Hydrogen ECCS Rooms) o Vibration Loose Parts Monitoring Plant Computer Seismic Monitoring Condensate/Deaerators Cranes Demineralized Water Core Flood Primary and Secondary Sampling Control Rod Drive Secondary Demineralizers Incore Instrumentation Boric Acid Addition Post Accident Monitoring Circulating Water/Cooling Tower I Extraction Steam/Feedwater Heaters Radiation Monitoring Clean Liquid Radwaste Reactor Vessel Internals Spent Fuel Pool and Cooling Stator Cooling Water Fire Protection (except Transformer Suppression)

Revision 5 December 6, 2002 1 Page 21 of 23

ATTACHMENT 2 COMPARISON OR REVIEWS MATRIX Tvne of Review Documentation/

Data Sources To Be Reviewed ORR SHRR LIR Quarterly System Health Reports x x x Information Associated With Window Colors Relative To MRule Performance Criteria x x x Recent Condition Reports x x x Known System/

Component Issues Representing Operational Mode Restraints x X xx Known Latent Issues y x X X Known Operating x Ix Experience Issues Risk Significant Functions xx

-Testing X X Preventive & Predictive x Maintenance Activities X t x

L 4 Closed Condition X x Rep ort Sb Closed C;orrective Maintena nce Work Orders Siince 1995 X X OpceraIn Open & Closed Modifical tions Since X X 1990 Industry Operating Experien ce Identified After 19995 X X Cited Vicolations And Non-Citeed Violations X X

-Since 19*95 Interview*s Of

-Operatio ns Personnel X X Interviev vs Of Maintenaance Personnel X X Design Basis

-Informa tion su chI as:______________

Safety A nd Acc ident

-Mitigaticon Func tions x P&IDs A*nd

-Element*ary/On Lines x Systemr Descrip tions x December 6, 2002 1 Page 22 of 23 Revision 5

Type of Review Documentation/

Data Sources To Be Reviewed ORR SHRR LIR Calculations X Safety Evaluations And Screenings X TMODS X Specifications And Standards X Equivalency Evaluations X Licensing Basis Information such as:

USAR, FSAR & SER Including Amendments X General Design Criteria

& FSAR Q&A X Commitments X Reg Guides X LERs & NOVs X Tech Specs & Bases X Other Data Sources such as:

Operating Procedures X Abnormal Operating Procedures X Emergency Operating Procedure X Alarm Procedures x

Surveillance and Periodic Test Procedures X Previously Conducted Audits, Assessments, (SSFIs, EDSFIss, QA) X NRC & INPO Inspections Reports X Generic Letters And Responses X NRC Notices and Notices X SOERs X SERs X B&W Information x Vendor Manuals X Operability Determinations X Operator Workarounds X PSA Information X Long Standing Clearance/Caution Tags X Revision 5 December 6, 2002 1 Page 23 of 23

Attachment 9 Management and Human Performance Excellence Plan Revision 3 January 7, 2003

Davis-Besse Management and Human Performance Excellence Plan Revision: 3 Date: January 7, 2003 Approve y e

Table of Contents Title Page Summary of Revision Changes ................................................................. 2 Executive Summary .............................................................................. 3 Charter ........................................................................................................ 4 Introduction .......................................................................................... 5 Root Causes and Assessments .............................................................. 6 Conclusions to Date ............................................................................... 9 Activities to Address the Areas Identified ......................................... 10 Management and Human Performancq Review and Action Plan Process ..................................................................... 11 Performance M onitoring ..................................................................... 12 Page I of 12 Revision 3 January 7, 2003

Summary of Revision Changes Revision 3 In addition to minor editorial changes, the following is a summary of the changes made in Revision 3 of this plan.

Added the performance of a Phase 2 Program Review for the Quality Assessment Program.

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Executive Summary A concise summary of the issue that led to the Davis-Besse Reactor Vessel Head degradation is as follows:

Managementineffectively implementedprocesses, and thusfailed to detect and addressplantproblems as opportunitiesarose.

Using data from all of the root cause reports associated with the head degradation, and other related assessments, the primary management contributors to this failure can be grouped into the following areas:

"* Nuclear Safety Culture

"* Management/ Personnel Development

"* Standards and Decision-Making

"* Oversight and Assessments

"* Programs/Corrective Action/Procedure Compliance Several procedural compliance and program implementation failures were identified in the Root Cause Reports, including the inadequate implementation of the Corrective Action Program. The actions to address the Program and implementation issues are being addressed by actions in this plan as well as actions from the Program Compliance Building Block. Actions will be initiated from the Management and Human Performance Improvement Plan to develop the proper focus, behaviors and teamwork throughout the entire organization. These actions will consist of restart actions and actions to be taken after restart.

The ultimate objective of the Building Block activities is to achieve and sustain excellence in operation of Davis-Besse. The overall goal of this Building Block is to initiate a substantive and demonstrative change in Davis-Besse management. FENOC realizes that achievement of this goal will take time, and not all will be accomplished prior to restart. The Building Blocks will ensure strong corrective actions are in-place for restart, however many actions must continue for the plant to have sustained performance.

FENOC's goal prior to restart is to ensure that the plant, programs, and organization are sufficient to support safe and reliable operation. Performance indicators monitoring the effectiveness of the actions taken will be used to demonstrate and track the desired changes needed for restart. Longer term corrective actions such as system reviews, program reviews and implementation of the Leadership In Action principles will continue well after restart.

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In accordance with the Program Compliance Plan building block activity, the station programs will be assessed for proper management Ownership, Standards, and Oversight.

The Program Compliance Plan performs a baseline assessment of applicable plant programs, as well as a more detailed program review for selected programs. Long term, follow-up assessments of the programs will be performed using the same criteria, and the resultant program health will be communicated through specific program indicators.

Reviews of specific departments will be done by way of Functional Area Reviews. These reviews will be performed in selected areas in order to assess restart readiness. Long term monitoring and indicator presentation of specific area or section health will be performed through the self-evaluation process.

The Management Observation Program will be used to monitor worker behaviors, performance, and plant conditions. This program will be updated to schedule management observations to monitor effectiveness of work activities and worker behaviors.

Review boards, such as the Corrective Action Review Board and the Engineering I Assessment Board will be used to monitor various work products for appropriate standards. Performance indicators will be used to monitor the resultant quality.

A Management Monitoring Process will be used to monitor and trend the performance of specific management oversight activities taken on an individual basis. These will demonstrate the level of involvement of individual managers.

Charter Conduct a thorough assessment of the management and organizational issues surrounding the degradation of the reactor head.

Create a comprehensive leadership and organizational development plan for the site.

This plan will include actions to be taken prior to and after restart.

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Introduction The Management and Human Performance Excellence Plan consists of three elements:

1. Reviews and assessments as described in the Action Plan.

2. Collective significance reviews approved by the Restart Oversight Panel.

3. Specific Actions to take before and after restart to ensure changes are effectively implemented.

The activities from this plan will drive long-term changes, with some actions required before restart, and others occurring after startup. The Restart Overview Panel will review these actions.

As part of the First Energy Nuclear Operating Company (FENOC) initial assessment of the Davis-Besse event, several actions were taken to strengthen our management. These actions were put in place to provide long-term sustainable performance. To date, FENOC has made several management changes to ensure proper oversight:

" FirstEnergy has created the position of Chief Operating Officer (COO) within FENOC, and has assigned him full time to the Davis-Besse station to address the managerial and organizational issues. He will remain at the site, focused on these issues through restart. The Chief Operating Officer is the ultimate oversight and approval authority for this plan. The COO has also assumed the responsibilities of the site Vice President, Nuclear.

" A Vice President of Oversight position was created, and this individual is in charge of oversight activities at all FENOC facilities. Both external and internal oversight will be assessed for improvements.

" An Executive Vice President of Engineering and Services position was created, to further strengthen engineering management oversight at Davis-Besse. This individual is in charge of the Engineering activities at all FENOC sites.

" The Davis-Besse senior leadership team (site Vice President and directors) has been completely changed.

" Changes in the manager-level positions have been made, including new managers in the Engineering, Maintenance, Work Control, Corrective Action Program, and Quality Assessment sections.

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Root Causes and Assessments The following provides details of the assessment activities:

Several groups conducted a thorough assessment of the management and organization development needs of the Davis-Besse site. The assessment was performed by reviewing and integrating input from a variety of sources. A comprehensive leadership and organizational development plan (Management and Human Performance Improvement Plan) will be developed to address these issues and make recommendations for resolution. The assessments will continue post-restart as other building block activities feed into this plan. The following are the activities and sources of data:

Technical Event Root Cause The Event Root Cause Analysis Report of the significant degradation of the Reactor Pressure Vessel Head was performed by a combination of internal and external personnel. This report identified several managerial and organizational contributors to this event, as well as some recommended corrective actions. This team identified issues with management oversight of plant conditions, management standards, and program implementation.

NRC Augmented Inspection Team The Augmented Inspection Team identified several contributors to the head degradation including managerial and organizational contributors. Overall, the AIT concluded that management processes failed to identify and correct indicated plant problems.

FENOC Quality Assurance Review The initial Event Root Cause Analysis Report identified several condition reports that should have identified, corrected, and even prevented the head degradation problem.

These areas were characterized as missed opportunities. A FENOC Quality Assurance team was commissioned by the Vice President of Oversight to perform more in-depth investigation of these missed opportunities. This team reviewed the managerial and organizational factors associated with how the individual condition reports were dispositioned without identifying or resolving the head degradation. This information was then provided to the Root Cause Team investigating the failure to identify the degradation of the head.

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Formal Root Cause Analysis of Management and Organization Issues The Chief Operating Officer sponsored an independent Event Team to perform a formal root cause analysis of the management and organizational issues related to the failure to identify the Reactor Pressure Vessel Head degradation. This team gathered the information obtained through the various reviews to finalize the root causes and causal factors and to recommend corrective actions. Additionally, root cause analyses have been performed for the Corrective Action Program, Quality Assessment, and Operations.

Davis-Besse Functional Area Reviews Selected area managers will review their functional area. Functional area reviews will consist of the review of the operational readiness of the following Davis-Besse organizations: Plant Operations, Chemistry/Radiation Protection, Maintenance and Work Management. These reviews will assess attributes in the following areas:

• Personnel

• Management Monitoring

• Basic Expectations

• Backlogs and

• Continuous Improvement The results of the reviews will be documented in reports, and the managers will present their report to the Senior Management Team for review and approval.

Building Block Plans Input from the implementation of other building block plans relative to managerial and organizational issues will be factored into the comprehensive leadership and organizational development plan. As an example, the Program Compliance reviews will resulted in the generation of Condition Reports. Some of the causes and actions for these will be addressed through this plan.

Personnel Feedback Feedback relative to any management/organizational issues from the Case Study presentations, 4-Cs meetings, Town Hall meetings and other activities with on-site personnel will be solicited and used to further improve the comprehensive leadership and organizational development plan. The Case Study, which is one of the key activities of the plan, consisted of a review of the timeline of the event with site personnel, and the rollout of the standards. These presentations were conducted within working groups, and identified the decisions, actions and missed opportunities that led to the head degradation.

These sessions, provided by the management team are to ensure all personnel understand how the event happened, what barriers broke down, and what needs to be different in the future. Feedback from these sessions has been assessed, and the results factored back into the development plan. 4-Cs meetings are small group meetings facilitated by a consultant, where Communications, Compliments, Concerns and Changes are discussed openly and recorded for action. Town Hall meetings are small group meetings with station personnel where our actions and plans are communicated, and feedback and questions are received.

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Restart Overview Panel The Restart Overview Panel (ROP), comprised of industry experts and community representation, provides oversight for the various plans related to restart activities. The panel was formed to provide independent oversight and review of plant activities discovered or performed as part of the Davis-Besse Return to Service Building Blocks.

The panel advises company officials on matters relating to the safe resumption of operation of Davis-Besse and provides recommendations as appropriate. The Restart Overview Panel reviews the results of each Building Block and provides the oversight process for management issues.

Ouality Department Oversight Assessment Assessments of the FENOC and Davis-Besse oversight groups were performed to identify their contributions toward this event, and to determine opportunities for improvement. The Vice President of FENOC Oversight commissioned a team to assess both the corporate (FENOC) and the site specific oversight organizations. A separate root cause evaluation was performed in these areas using FENOC personnel as well some independent consultants. The oversight program itself will be assessed through the performance of a Phase 2 Quality Assessment Program review, done in accordance with the Program Compliance Building Block.

Nuclear Oversight Board Review The new owner of the FENOC off-site review board (Company Nuclear Review Board):

the newly appointed Vice President of Oversight, commissioned an independent review of this Nuclear Oversight Board. This was performed to look for improvement opportunities in the board's focus and processes which should have identified the weaknesses that led to this event.

Organizational Development Expertise Organizational development consultants were provided to assist in developing the Management and Human Performance Improvement Plan and facilitating information gathering. They are also involved in facilitating specific area improvement plans. The information obtained from the various assessments will be used to help facilitate the subsequent long-term organizational development activities.

Institute of Nuclear Power Operations Reviews The Institute of Nuclear Power Operations (INPO) provided an independent review of our management / human performance assessments. An organizational effectiveness individual reviewed the actions and conclusions from the root cause, and a human performance specialist was involved in the root cause preparation. INPO also facilitated the reviews of the Engineering and Operations departments.

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Conclusions to Date From the Root Causes and other assessments performed to date on the reactor vessel head degradation event, the summary of organizational performance relative to the Reactor Pressure Vessel Head degradation is:

Management ineffectively implementedprocesses, and thusfailed to detect and addressplantproblems as opportunitiesarose.

The key areas contributing to this failure have been identified as:

"* Nuclear Safety Culture

"* Management/ Personnel Development

"* Standards and Decision-Making

"* Oversight and Assessments

"* Programs/Corrective Action/Procedure Compliance

]Page 9 of 12 Revision 3 January 7. 2003

Activities to Address the Areas Identified Development Plan A comprehensive development plan (Management and Human Performance Improvement Plan) has been created. This plan includes actions to be taken both prior to and following restart. It also includes a long-term leadership development plan, and an organizational development plan. The goal of this plan is to bring focused attention to the high leverage actions that will transform the organization so that a new standard of organizational excellence is achieved and sustained. Methods to monitor the performance and success of implementation of the plan are also included. These include specific monitoring at the department/section level, program level, management team level and individual level, as well as monitoring of the overall effectiveness. The plan will ensure the individual root causes identified, as well as the overall following areas are addressed:

• Nuclear Safety Culture

• Management/ Personnel Development

• Standards and Decision-Making

• Oversight and Assessments

• Programs/Corrective Action/Procedure Compliance Page 10 of 12 Revision 3 January 7, 2003

Management and Human Performance Review and Action Plan Process Initial industry I

review of Root Cause Contributors Independent Root Cause team for failure to detect degradation I Management

& Human Performance Improvement Plan Actions Required for Program 7 ~RestartI Review input and Case Study feedback Other Root Actions (MgmtVHP Post -restart related) S~Actions Cultural Survey, SCWE survey and other assessment tool data FENOC QA oversight review Page 11 of 12 Revision 3 January 7, 2003

Performance Monitoring The Program Compliance Plan performs a baseline assessment of applicable plant programs, as well as a more detailed program review for selected programs. Long term, follow-up assessments will be performed using the same criteria, and the results will be communicated through specific program health indicators.

Reviews of specific departments will be done by way of Functional Area Reviews. These reviews will be performed in selected areas in order to assess and correct management ownership and oversight issues. Long term monitoring and indicator presentation of specific area or section health will be performed through the self-evaluation process.

The Management Observation Program will be used to monitor individual performance.

This program will be updated to schedule management observations to monitor effectiveness of work activities and worker behaviors. This process will also include the monitoring of engineering activities. Examples of attributes to be assessed include the following:

Quality of pre-job briefs Proper safety practices and equipment use Effective communications Adequate supervisory behaviors Procedureor document use Use of station error prevention tools Data from these attributes will be used to create performance indicators to measure effectiveness of this plan.

Review boards, such as the Corrective Action Review Board and the Engineering Assessment Board are being used to monitor various work products for appropriate standards. These boards provide indicators to monitor performance, based on product acceptance rate.

A Management Monitoring Process will be used to monitor and trend the performance of specific management oversight activities taken on an individual basis. These will demonstrate the level of involvement of individual managers. Examples of monitoring activities and performance indicators to be used are:

Training observations Field observations of activities Coaching opportunities taken Oversight activities provided Plant / Containment tours Other sources of data to be used for monitoring effectiveness and creation of performance indicators are:

Corrective action process Management Observation / involvement plan Training Review Committee indicators and feedback.

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Attachment 10 Management and Human Performance Plan Revision 0 September 5, 2002

FirstEnergy, DAVIS-BESSE NUCLEAR POWER STATION MANAGEMENT & HUMAN PERFORMANCE IMPROVEMENT PLAN DATE: September 5, 2002 Davis-Besse Sponsor:

Chief Operating Officer Approved by:

Robert F. Saunders President

Table of Contents Title Page No.

1.0 Executive Sum m ary ........................................................................................ 1 2.0 Purpose and Objectives ..................................................................................... 6 3.0 V ision and V alues ............................................................................................. 7 4.0 C ategories of C auses ........................................................................................ 8 5.0 Extent of C ondition ........................................................................................... 9 6.0 Actions to Achieve Excellence ....................................................................... 10 6.1 Improvements in Safety Culture .............................................................. 11 6.2 Improvements in Management / Personnel Development ........................ 14 6.3 Improvements in Standards / Decision-Making ........................................ 18 6.3 Improvements in Oversight / Assessments ............................................. 22 6.4 Improvements in Programs / Corrective Action/

Procedure Com pliance ............................................................................. 25 6.5 Summary of Department-Level Actions to Improve Performance .......... 31 7.0 Verification of Effectiveness ............................................................................ 32 7.1 Perform ance Indicators ............................................................................ 32 7.2 Other Measures ...................................................... 33 8.0 C onclusions ..................................................................................................... . . 34 i

Tables Title 1 Improvements in Safety Culture 2 Improvements in Management / Personnel Development 3 Improvements in Standards / Decision-Making 4 Improvements in Oversight / Assessments 5 Improvements in Programs / Corrective Action / Procedure Compliance 6 Summary of Department-Level Actions to Improve Performance ii

Figures Title

1. Davis-Besse Site Organization iii

Attachments Title

1. Correlation of Individual Causes with Corrective Actions iv

Acronyms BACC Boric Acid Corrosion Control CAP Corrective Action Program CAQ Condition Adverse to Quality CARB Corrective Action Review Board CNRB Company Nuclear Review Board COo Chief Operating Officer CR Condition Report DBNPS Davis-Besse Nuclear Power Station EAB Engineering Assessment Board EAC Employee Concerns Program FENOC FirstEnergy Nuclear Operating Company GET General Employee Training HPES Human Performance Evaluation System IMC NRC Inspection Manual Chapter INPO Institute of Nuclear Power Operations ISI In-service Inspection MCTM Management Communications and Teamwork Meeting NDE Non-Destructive Examination NOP Nuclear Operating Procedure NQA Nuclear Quality Assurance NRC Nuclear Regulatory Commission OE Operating Experience PCAQR Potential Condition Adverse to Quality Report PCR Procedure Change Request PM Project Manager PRC Project Review Committee PWR Pressurized Water Reactor PWSCC Primary Water Stress Corrosion Cracking QA Quality Assurance V

RCS Reactor Coolant System RFO Refueling Outage ROP Restart Overview Panel RPV Reactor Pressure Vessel RSMT Restart Senior Management Team SCAQ Significant Condition Adverse to Quality SCWE Safety Conscious Work Environment SRB Station Review Board SRO Senior Reactor Operator SSCs Systems, Structures and Components VP Vice President vi

Page 1 1.0 Executive Summary Significant degradation of the Davis-Besse reactor pressure vessel (RPV) head base metal was discovered during the thirteenth refueling outage (13RFO) in March 2002. In April 2002, a technical Root Cause Analysis Report was issued on the degradation of the Davis-Besse RPV head (Technical Root Cause Analysis Report). That Report also identified a number of overall management issues that set the genesis for this report. It concluded that station personnel had failed to identify corrosion of the base metal of the RPV head over a period of years despite several opportunities to do so. A follow-up Root Cause Analysis was performed to specifically identify the causes and contributing causes of the issues associated with the failure to identify the corrosion of the RPV head. Several root cause analyses and other assessment performed from the Management and Human Performance Building Block Plan have identified weakness in the following areas:

"* Nuclear Safety Culture

"* Management / Personnel Development

"* Standards and Decision-Making

"* Oversight and Assessments

" Programs, Corrective Action and Procedure Compliance Given these types of causes, other activities beyond those related to the degradation of the RPV head may be affected by the same causes. The Building Blocks were designed to provide actions needed for restart, and to ensure actions taken in the longer term will result in sustained performance. For example, the System Health and Program Reviews will continue to be a normal process after restart.

Additionally, for each of these areas, FirstEnergy Nuclear Operating Company (FENOC) is taking action to improve its performance. In particular, in each of these areas, FENOC has identified objectives for improved performance, restart and non-restart actions to achieve those objectives, the managers responsible for implementing those actions, a schedule for the actions, and measures to verify the effectiveness of these actions. In summary:

Improvements in Safety Culture FENOC has the following objective for safety culture at Davis-Besse:

Nuclear, radiological, and personnel safety have the highest priority and take precedence over other objectives, such as cost and production. Personnel feel free to raise safety concerns without fear of retaliation, and concerns are investigated and resolved in a timely manner.

FENOC's actions to achieve this objective include the following:

• A policy will be established that incorporates FENOC's objective on safety culture.

Management & Human Performance Improvement Plan 1.0 Executive Summary

Page 2

"* The existing Leadership in Action training of management will be revised to include training on the need for a nuclear safety focus.

"* Management incentives will be realigned to place the most weight on safety and safe operation.

"* Management will ensure standards of excellence are communicated at all levels.

"* Case Study training will be given to groups throughout the site to ensure personnel understand how the event happened, what barriers broke down, and what needs to be different in the future.

"* We will continue to monitor safety culture with our safety culture surveys on a routine basis, and take corrective actions until high performance standards are achieved.

Improvements in Management / Personnel Development FENOC has the following objective for its management of Davis-Besse:

Managers are experienced, have high safety standards, and are involved in directing and overseeing plant activities.

FENOC's actions to achieve this objective include the following:

• FENOC has created three executive positions which have been filled by highly qualified individuals who have had substantial nuclear experience outside of the FENOC system.

• The top two levels of management at Davis-Besse (site Vice President (VP) and plant directors) have been entirely replaced, and much of the third level (managers) have been replaced. The new management team is largely drawn from outside of Davis-Besse, and several proven performers from plants outside of the FENOC system.

• Evaluations will be performed of supervisors and managers to assess their competence for their current positions, including the adequacy of their nuclear safety focus.

• Leadership training will be implemented for the management team to set the standards for how the management team will be expected to conduct business.

• The Operations Section has initiated an improvement plan to become the lead organization at Davis-Besse.

• A Management Monitoring Process will be established and implemented to monitor and trend the performance of the management observation activities of individual management personnel.

Improvements in Standards and Decision-Making FENOC has the following objective for decision-making and technical assessments at Davis Besse:

Decision-making and technical standards have a nuclear safety focus, have technical rigor, account for operating experience, and seek to correct problems rather than justifying acceptance of the problems.

FENOC's actions to achieve this objective include the following:

Management & Human Performance Improvement Plan 1.0 Executive Summary

Page 3

"* FENOC will establish written technical expectation for its staff.

"* FENOC will make improvements to the Industry Operating Experience program to ensure appropriate actions identified from other plants or sources of information are properly tracked and implemented.

"* FENOC stations (including Davis-Besse) will share assistance and expertise among themselves and Davis-Besse will augment its engineering staff with outside personnel to provide new insights and experiences.

"* The common processes at FENOC's Beaver Valley and Perry plants will be applied to Davis Besse.

"* Training on the FENOC Decision-Making Model and technical standards will be provided to personnel.

"* A Management Observation Program will be established and implemented to monitor individual performance and ensure that high standards are being implemented by personnel.

Improvements in Oversight and Assessments FENOC has the following objective for oversight and assessments at Davis-Besse:

Davis-Besse has provisions for oversight and assessments, which are effective in identifying and obtaining correction of problems before they adversely affect safety.

FENOC's actions to achieve this objective include the following:

"* A Restart Oversight Panel (ROP) has been established, utilizing industry experts and community leaders, to provide an independent oversight and review of plant activities performed for restart of Davis-Besse. This panel will remain in effect for four months after restart.

"* An Engineering Assessment Board (EAB) has been established, consisting largely of experienced outside consultants and some FENOC employees, to review engineering and technical products. This board will consist of FENOC personnel in the long-term, and is designed to be a permanent change to the Davis-Besse process.

"* Davis-Besse has established a Restart Senior Management Team (RSMT) to review restart reports for items on the Davis-Besse 0350 Restart Checklist.

"* The Nuclear Quality Assurance organization has performed a root cause analysis of its activities and is improving its activities to address the causes.

"* The effectiveness of the Company Nuclear Review Board (CNRB) has been reviewed and changes made to improve its safety focus.

"* The Project Review Committee (PRC) charter and membership has been changed to ensure proper level of management decision-making and to ensure items required for safe and reliable operation are not deferred.

"* A formal restart readiness review process will be developed for future plant restart activities.

This process will provide the structure and rigor for assessing the readiness of the plant to be restarted.

"* Davis-Besse will perform periodic system walk-downs and program reviews using criteria similar to those being used under the existing Building Block Plans. This is a long-term change that will remain in effect after startup.

Management & Human Performance Improvement Plan 1.0 Executive Summary

Page 4 Improvements in Corrective Actions FENOC has the following objective for corrective actions at Davis-Besse:

Adverse conditions (including adverse trends) are promptly identified and documented.

The root causes of significant conditions adverse to quality are identified, actions are taken to preclude recurrence of the conditions, and the preventive actions are effective FENOC's actions to achieve this objective include the following:

" As part of the Program Compliance Plan, FENOC is conducting a detailed review by independent consultants of the corrective action program and its implementation.

"* Davis-Besse is taking several actions to improve reviews of the operability of structures, systems, and components (SSCs) with degraded and nonconforming conditions.

"* The criteria for categorization of adverse conditions will be upgraded to ensure that conditions receive categorizations commensurate with their safety significance.

"* Cause evaluations will be restricted to those demonstrably qualified, and the corrective action procedure will be revised to require the use of formal cause determination techniques for conditions in the more significant categories.

"* The guidance on reviews of the effectiveness of corrective actions will be improved to focus on verifying that causes have been fixed.

"* FENOC will develop and implement an effective site wide equipment trending program.

"* The Corrective Action Review Board (CARB) will be improved to provide additional leadership, and the reviews performed by the CARB will be expanded to enforce higher standards for cause evaluations and effective corrective action.

Improvements in Programs and Procedure Compliance FENOC has the following objective for programs and procedure compliance at Davis-Besse:

Programs comply with NRC regulations, incorporate applicable operating experience, and are effectively implemented. Personnel take ownership of programs within their scope of responsibility, and program owners ensure that the objectives of their programs are achieved. Personnel comply with procedures as written or obtain appropriate revisions to procedures.

FENOC's actions to achieve this objective include the following:

"* FENOC has established and is implementing the Program Compliance Building Block Plan to provide for a two-phase review of programs.

"* On a long-term basis, follow-up assessments of programs will be performed using the same criteria as the Phase 2 restart program reviews. This process will become a standard review of our programs.

"* Based upon the assessments of the RPV head degradation and other events, FENOC has made improvements in the Boric Acid Corrosion Control Program and Inservice Inspection Management & Human Performance Improvement Plan 1.0 Executive Summary

Page 5 Program.

"* Refinements to the Ownership Model and indicators will be made to provide effective continuous assessment of the various station processes.

"* A qualification process will be developed for program ownership.

"* Davis-Besse will be reinforcing standards and expectations for procedure compliance and the need for work practice rigor.

"* FENOC is establishing a Management Observation Program to provide direct management observation of procedure compliance by employees.

Upon completion, these actions will ensure that FENOC will ready for safe and reliable operation of Davis-Besse and ultimately to achieve excellence in performance.

Management & Human Performance Improvement Plan 1.0 Executive Summary

Page 6 2.0 Purpose and Objectives In March 2002, FirstEnergy Nuclear Operation Company (FENOC) discovered significant degradation of the reactor pressure vessel (RPV) head at Davis-Besse as a result of boric acid corrosion. As result, FENOC initiated a number of analyses and other assessments to determine the causes of that event and related performance problems.

The purpose of this Plan is to address those causes. This Plan identifies the various categories causes as identified in recent root cause analyses and other assessments, identifies actions to address those causes (including identification of the managers responsible for implementing the actions and schedules for those actions), and identifies performance measures for assessing improvements in performance.

The ultimate objective of this Plan is to achieve and sustain excellence in operation of Davis Besse. FENOC realizes that achievement of this goal will take time, and will not be accomplishment prior to restart. FENOC's goal prior to restart is to ensure that the plant, programs, and organization are sufficient to support safe and reliable operation. As a result, the actions identified in this Plan are designated either as actions that will be completed prior to restart or non-restart actions (actions that may be initiated or completed after restart).

This Plan focuses on the actions needed to achieve excellence in management and the Davis Besse organization. The Return to Service and Building Block Plans provide actions intended to ensure the adequacy of programs and plant structures, systems, and components. This Plan references and relies upon the other Building Block Plans as appropriate. Together, this Plan and the Building Block Plans provide a comprehensive set of actions to ensure the safety of the plant and achieve excellence in performance.

Management & Human Performance Improvement Plan 2.0 Purpose and Objectives

Page 7 3.0 Vision and Values For the past three years, FENOC has had a common vision, mission, and fundamental building blocks for all of its nuclear plants:

Vision OPERATIONAL EXCELLENCE Mission Peopleproviding safe, reliableand cost effective nuclear generation CriticalSuccess Areas Safety, People,Reliability and Cost In summary, the safe operation of Davis-Besse is the first priority of FENOC. The actions described in this Plan are designed to ensure that this goal is achieved.

Management & Human Performance Improvement Plan 3.0 Vision and Values

Page 8 4.0 Categories of Causes Following the discovery of the degradation of the RPV head, FENOC initiated a number of analyses and assessments of the causes of the performance problems of the event and other problems involving boric acid at Davis-Besse. These include the following: Root Cause Analysis Report of Significant Degradation of the Reactor Pressure Vessel Head (April 15, 2002); Root Cause Analysis Report of Failure to Identify Significant Degradation of the Reactor Pressure Vessel Head (August 13, 2002); Root Cause Analysis Report of Failure of Quality Assurance Oversight to Prevent Significant Degradation of Reactor Pressure Vessel Head to (pending); Nuclear Quality Assurance Examination of Five Closed Nonconformances Related the Reactor Pressure Vessel Head (June 13, 2002); and Davis-Besse 8/2002 Safety Conscious Work Environment Survey. The causes and other observations in the analyses and assessments are listed in Attachment 1.

The causes and observations (as they pertain to the management and organization for Davis Besse) can be placed into the following categories:

"* Nuclear Safety Culture

"* Management / Personnel Development

"* Standards and Decision-Making

"* Oversight and Assessments

"* Programs / Corrective Action / Procedure Compliance Section 6 identifies the actions that FENOC is taking for each of these categories. Additionally, Attachment 1 correlates the causes and observations identified in the analyses and assessments with the corrective actions identified in Section 6, and demonstrates that each of the causes and observations has associated corrective action.

Management & Human Performance Improvement Plan 4.0 Categories of Causes

Page 9 5.0 Extent of Condition Given the types of causes discussed in Section 4, other activities beyond those related to the degradation of the RPV head may be adversely affected by the same causes. Therefore, Davis Besse is conducting comprehensive reviews to determine whether other hardware, functions, and programs have been impacted by these causes.

Currently, the Davis-Besse Building Block Plans include reviews to assess the adequacy of systems, organizations, and programs to support safe and reliable operation. Specifically:

"The System Health Assurance Plan provides for a series of reviews of systems. These reviews include the following checks: reviews of Condition Report s (CRs) initiated since 1995 affecting the risk significant functions to verify the adequacy of corrective actions; reviews of Corrective Work Orders initiated since 1995 affecting risk significant functions to verify that degrading trends are not developing; reviews of modifications initiated since 1990 to address deficiencies of the system to support risk significant functions to ensure identified problems were properly resolved; reviews of industry operating experience identified after 1995 on risk significant functions to verify incorporation of lessons learned; elicitation of concerns by operators and maintenance personnel related to how the systems and system components are performing; and system walkdowns to assess the materiel condition of the system.

" The Management and Human Performance Excellence Plan includes a series of reviews of functional areas (organizations). These reviews include checks of: whether there are clear lines of authority and responsibly within the organization; whether staffing levels and resources are sufficient to handle assigned responsibilities; whether individuals have a clear description of their assigned responsibilities; whether individuals satisfy regulatory requirements and commitments for certification, qualification, and experience; whether the training of individuals is current; whether programs within the responsibility of the organization have an individual who is assigned as the owner; whether there are effective methods for communicating safety information within the organization; whether interfaces with other organizations are clearly defined; whether corrective actions and improvements for assessment related to the organization findings within the last two years have been effective; whether the organization has appropriate performance indicators or other goals and objectives; and whether the organization satisfies any other applicable regulatory requirements and commitments.

" The Program Compliance Plan provides for a series of reviews of programs, including: the interfaces with other programs or work groups are controlled; the program appropriately implements operating experience; the program has an appropriate level of management involvement; the program has an owner who is properly qualified; and the roles and responsibilities for program implementation are clearly defined and appropriately implemented.

These reviews will be sufficient to identify any significant impacts on the plant, organization, or programs that may have resulted from the types of causes identified in Section 4.

Management & Human Performance Improvement Plan 5.0 Extent of Condition

Page 10 6.0 Actions to Achieve Excellence For each of the categories of causes identified in Section 4, the following sections identify FENOC's objectives for improved performance, restart and non-restart actions to achieve those objectives, the managers responsible for implementing those actions, and a schedule for the actions. Additionally, each section contains measures to verify the effectiveness of these actions.

The actions listed in the categories below will be reviewed by cross-functional teams (headed by the identified owner). These teams are chartered to review the recommended actions and decide if these actions, when taken together, constitute a long-term fix to the specific causes identified in the technical and management root cause reports. Alternative actions may be recommended if needed and will be added to the plan in the categories below.

The site-wide actions to address the categories outlined below are a portion of the management excellence activities going on at the site. In addition, organizational development plans within key departments are being created. Operations, Engineering, Maintenance, and the Radiation Protection/Chemistry departments will have development plans. Each of these departments will have External Organizational Effectiveness consultants supporting the development and implementation of these plans. These plans will:

"* create alignment between this plan and the department level plans,

"* address safety related issues,

"* improve organizational structure and processes,

"* assess/develop leadership, and

"* solve key issues.

These plans will integrate and customize site-wide efforts to meet the particular development needs within these critical departments. They will result in movement to organizational excellence. These actions are summarized in Section 6.6 below.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 11 6.1 Improvements in Safety Culture Objective FENOC has the following objective for safety culture at Davis-Besse:

Nuclear, radiological,andpersonnel safety have the highestpriority and take precedence over other objectives, such as cost andproduction.Personnelfeelfree to raisesafety concerns withoutfear of retaliation,and concerns are investigatedand resolved in a timely manner.

Actions FENOC is taking the actions listed in Table 1 to achieve its objectives for safety culture. In summary, FENOC will be taking actions at all levels to improve its safety culture. Clear communications regarding safety culture will be provided to station personnel, and activities will be put in place to solicit feedback regarding our performance in this area. Open communications through several different avenues will be used to communicate and assess the desired behaviors These improvements range from establishing a clear policy that gives safety pre-eminence, establishing a new management team that embodies this safety policy, ensuring that incentives support safety, communicating the safety policy to employees and training employees on the policy, monitoring to ensure that employees are adhering to the safety policy, and improvements in the safety conscious work environment at the site. These improvements are described in more detail below.

" FENOC Policy on Safety - As part of the Business Plan, a policy will be established that will emphasize that nuclear, radiological, and personnel safety have the highest priority and take precedence over other objectives, such as cost and production. The policy will be incorporated into procedures, guidelines, job descriptions and performance evaluations, as appropriate.

" New FENOC Executive Team and new Davis-Besse Management with High Safety Standards As discussed in more detail in Section 6.2, extensive changes have been made in the officers, directors, and managers responsible for Davis-Besse, including establishment and appointment of a new Chief Operating Officer (COO), Executive Vice President, and Vice President of Oversight; changes in the site Vice President; and changes in each of the plant directors. These new individuals bring outside experience and high safety standards.

" Training of Management on Nuclear Safety Focus - The existing Leadership in Action training of management will be revised to include training on nuclear safety focus. Lessons learned regarding manager / supervisor behaviors that led to the RPV head degradation will be factored in to this module.

" Business Plan Alignment of Incentive Programs to Promote Safety - Incentives for management positions at the station (e.g., Site Vice President (VP) and below) will be realigned to place the most weight on safety and safe operation of the station. The new incentive program will help promote a nuclear safety focus at the site.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 12

" Meetings with Employees to Communicate Safety Focus - Management will ensure standards of excellence are communicated at all levels. This includes town-hall meetings in which management can demonstrate first-hand its commitment to nuclear safety in both its presentations and responses to employee questions. Additionally, FENOC is holding "4-Cs" meetings between the COO and small groups of employees. At these meetings, employees can anonymously express "compliments, communications, concerns, and changes" to a facilitator who then relays them to the COO. The COO then communicates his response (including communicating the need for high safety standards) directly back to all employees. The results of these meetings are also communicated to the employees through the site newsletter. Finally, the Restart Oversight Panel will be interviewing employees to help evaluate their nuclear safety focus, and the results of these interviews will be used to develop actions to improve the nuclear safety focus of employees in general.

" Case Study Training on Nuclear Safety - Case Study training will be given to groups throughout the site. This training will consist of a review of the timeline of the RPV head degradation event with site personnel to ensure personnel understand how the event happened, what barriers broke down, and what needs to be different in the future.

" Improvements in Management Oversight of Safety - As discussed in more detail in Section 6.3, a Management Observation Program will be developed for increased presence of management in the field during outages and normal operation. This will help ensure that personnel in the field have the proper safety focus. Additionally, a Management Monitoring Process will be used to monitor and trend the performance of specific management oversight activities taken on an individual basis. These will demonstrate the level of involvement and safety focus of individual managers.

" Improvements in Safety Conscious Work Environment (SCWE) - A plan has been developed to improve SCWE at Davis-Besse. This plan includes provisions for training on SCWE for supervisor and managers, communications to employee emphasizing the importance of SCWE, establishment of a "people team" to evaluate the appropriateness of proposed significant adverse action against employees before the action is taken to help detect and prevent the potential for retaliation for raising safety concerns, development of a process for resolving issues raised by employees, creation of employee concerns program that reflects best industry practices, and monitoring SCWE performance and attitudes.

Table 1 also documents other actions being taken in this area. These comprehensive actions will help ensure that a nuclear safety focus is instilled and sustained for the long-term throughout the Davis Besse site.

Verification of Effectiveness FENOC will be taking the following steps to verify that its actions to improve the safety culture at Davis-Besse are effective:

• Performance Indicators - FENOC will use the following performance indicators to measure improvements in safety culture:

> Self-Identification of Adverse Conditions - This indicator calculates the percent of CRs that are self-identified. CRs originated as a result of Quality Assurance (QA), Institute of Nuclear Power Operations (INPO), or Nuclear Regulatory Commission (NRC) or as a result of a self-Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 13 revealed issue are not considered to be self-identified. The goal for restart is to have 80% or more of the CRs as self-identified.

Assessments - FENOC will perform the following assessments to measure performance in the area of safety culture:

SSelf-Assessments - Each group performs self-assessments at least 4 times per year. At least one of these assessments will include an evaluation of the safety focus of the group.

SManagement Observations - As discussed above, management will be performing regular observations of activities in the plant to verify that personnel have the proper nuclear safety focus.

) SCWE Assessments - FENOC will conduct monitoring and periodic assessments of SCWE at Davis-Besse. The goal for restart is to have an improving trend in SCWE.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 14 6.2 Improvements in Management / Personnel Development Objective FENOC has the following objective for its management of Davis-Besse:

Managers are experienced,have high safety standards,and are involved in directingand overseeingplant activities.

Actions Since degradation of the RPV head was discovered in March 2002, FENOC has created three executive positions to provide new leadership for Davis-Besse and its other nuclear plants. Each of these positions has been filled by highly qualified individuals who have had substantial nuclear experience outside of the FENOC system. These positions are as follows:

" Chief Operating Officer (COO) - The new COO is Lew Myers. Prior to his assignment as COO, he was the Vice President of Beaver Valley and Perry. He has also held senior management positions at the South Texas Project and Browns Ferry plants.

"* Executive Vice President - A new Executive Vice President has been created with responsibility for engineering. Gary Leidich has been assigned to this position. He has over 20 years of nuclear experience, including three years at the INPO prior to his current position.

"* Vice President of Oversight - The new Vice President of Oversight is Bill Pearce, who has a strong operational background. Most recently, he was plant manager at Beaver Valley and prior to that at Quad Cities, St. Lucie and Turkey Point.

In addition, substantial changes have been in the top three levels of management at Davis-Besse since December of 2001. The top two levels (site VP and plant directors) have been entirely replaced, and much of the third level (managers) have been replaced. The new management team is largely drawn from outside of Davis-Besse, including plants outside of the FENOC system. Specifically:

"* Site Vice President - The site VP has been replaced, and the new COO will also be performing the duties of the site VP.

" Plant Manager - The new Plant Manager is Randy Fast, who has a strong leadership background from South Texas Project and Beaver Valley to his assignment at Davis-Besse.

" Director of Nuclear Engineering - The new Director of Engineering is Jim Powers, who was an Engineering Manager at Perry prior to his assignment at Davis-Besse.

" Director of Technical Support - The new Director of Technical is Bob Schrauder, who has been a Plant Manager and Engineering Director at Perry prior to his assignment at Davis-Besse.

" Director of Maintenance - The new Director of Maintenance is Mike Stevens, who has a strong Engineering, Operations and Maintenance background from his experience at several utilities.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 15 New managers - Of the 14 managers, half are new, including the Manager of Chemistry and Radiation Protection, Manager of Plant Operations, Manager of Maintenance, Manager of Regulatory Affairs, Manager of the Performance Improvement Organization, Manager of Quality Assessment, and Manager of Design Basis Engineering. Five of these individuals have come from plants outside of Davis-Besse.

Figure 1 depicts the management team at Davis-Besse and clearly shows that most of the team (including all of the upper levels of the team) are new.

FENOC is also taking other actions listed in Table 2 to achieve its objectives in the area of management and personnel development. These actions are comprehensive and range from identification of standards for management, evaluation of current management against those standards, communicating and providing training to management in those standards, and periodically assessing management against the standards. These actions have been developed with assistance from experts in organizational development, including Lincoln Consulting and RHR consulting. Some of these are described below:

" Standards for Management - Davis-Besse will establish a common set of standards for management personnel. These standards will stress the need for management to set and communicate the proper safety values and expectations for their personnel; to personally observe the performance of personnel to ensure that they are meeting expectations; to measure performance of personnel, systems, and programs within their areas of responsibility; and take action to correct and prevent recurrence of performance problems.

" Operations Improvement Plan - The Operations Section has developed an improvement plan to achieve the following goals:

)' Operations is recognized as the lead organization at Davis-Besse.

) Continuous improvement is expected, demonstrated and embraced in the Operation Section

> Operations ownership of equipment deficiencies, nuclear fuel performance, and plant chemistry is strong

> Operations Management communicates, demonstrates, and reinforces desired performance standards to operate the facility at desired levels, and

> Shift management consistently demonstrates leadership to staff, craft, and oversight personnel

" Supervisory Evaluations - Evaluations will be performed of supervisors and managers to assess their competence for their current positions, including the adequacy of their nuclear safety focus.

These evaluations will be performed using attributes associated with the applicable causes identified in the RPV head degradation root cause analysis reports.

" Leadership in Action - Leadership training will be implemented for the management team.

Customized and focused Leadership in Action training will be provided to communicate the learning opportunities from the RPV head degradation event. This training will include lessons learned from the issues or attributes identified in the Root Cause Analysis Report on the failure to identify the degradation of the head. This leadership training will set the standards for how the management team will be expected to conduct business. This training will include managerial and supervisory personnel.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 16

" Foundations for Leadership - Foundations for Leadership is one of the initial supervisory training programs. Employees who desire to become supervisors and who have management approval are started in an initial training program. This program trains on supervisory and management skills.

This program will be reviewed to ensure the correct focus is on the right behaviors, such as coaching, reinforcing expectations and communicating openly.

" Ownership for Excellence - Ownership for Excellence is the individual performance monitoring and evaluating tool used at Davis-Besse. This is the program that sets and communicates individual employee accountabilities, and is used to provide follow-up evaluation and appraisal of performance.' Merits are assigned based on meeting the documented expectations, so putting the proper focus and attributes in the Ownership for Excellence will help foster the correct behaviors.

New Ownership for Excellence accountabilities will be established for all Directors and Managers.

" Management Monitoring Process - A Management Monitoring Process will be established and implemented to monitor and trend the performance of the management observation activities of individual management personnel. Examples of performance indicators to be used are:

STraining observations

>Field observations of activities

> Coaching opportunities taken

> Oversight activities provided

> Plant / Containment tours In total, tIbe new leadership team, along with these actions will help ensure going forward that management personnel have high safety standards and are actively involved in directing and overseeing plant activities.

Verification of Effectiveness FENOC will be taking the following steps to verify that its actions to improve the management and personnel at Davis-Besse are effective:

• Performance Indicators - FENOC will use the following performance indicators to measure improvements in management and personnel:

> Management Monitoring - As discussed above, FENOC will be establishing performance indicators for management under the Management Monitoring Process. Restart goals will be established for each of the attributes under this process.

> Individual Errors - This indicator measures the personnel error rate per 10,000 person-hours worked. The goal for restart is 0.50.

> Repeat Events - This indicator measures the number of CRs that document a repeat of a Significant Condition Adverse to Quality (SCAQ). This is a long-term indicator. It will help measure whether management is placing the proper emphasis on preventing recurrence of problems.

> Accept As-Is - This indicator measures the percent of CRs whose disposition is accept as-is.

The goal at restart is to have a percent that is 10 % or less. This indicator will help measure whether management is placing the proper emphasis on fixing problems rather than living with problems.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 17 Assessments - FENOC will perform the following assessments to measure performance in the area of management and personnel:

> INPO Assist Visit - FENOC will request an INPO assistance visit to assess management in the fourth quarter of 2002.

> Restart Oversight Panel - As discussed in Section 6.4, FENOC has established a Restart Oversight Panel (ROP), which provides assessments and recommendations of management actions for restart. The plant will not restart without the approval of the ROP.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 18 6.3 Improvements in Standards and Decision-Making Obiective FENOC has the following objective for decision-making and technical assessments at Davis-Besse:

Decision-makingand technicalstandardshave a nuclearsafety focus, have technical rigor, accountfor operatingexperience, and seek to correctproblems rather thanjustifying acceptance of the problems.

Actions FENOC is taking the actions listed in Table 3 to achieve its objectives in the area of standards and decision-making. In summary, FENOC will be taking actions at all levels to improve its standards and decision-making. These improvements range from establishment of high standards for decision making, training of personnel in the new standards, and monitoring to ensure that the standards are being implemented. These improvements are described in more detail below.

" Establish Technical Staff Expectations - FENOC will establish written technical expectation for its staff. For example, Engineering has already issued expectations for its technical staff, including expectations for Nuclear Safety, Rigor, Compliance and Ownership. Other departments at Davis Besse will also establish and implement technical expectations for their staffs. Data from the corrective action system, review groups and the observation programs will be used to provide information to monitor for proper implementation 6f these standards.

" Improvements in Use of Operating Experience - Improvements to the station benchmarking program will be made to promote taking action on good practices observed elsewhere. This program allows station personnel the opportunity to visit and assess programs at several different stations and will help ensure that Davis-Besse is aware of and using best industry practices.

FENOC will also make improvements to the Industry Operating Experience program to ensure appropriate actions identified from other plants or sources of information are properly tracked and implemented. These improvements will include issuance of expectations on when to seek information on operating experience for use in proposed plant activities, where to seek the information, how to determine the validity of the information, and how to track the information for future updates and use.

" Increased Resource Sharing with FENOC Plants - FENOC stations (including Davis-Besse) will share assistance and expertise among themselves. This will promote sharing of information and practices. Additionally, FENOC will rotate assignments for management personnel to prevent isolation from other stations.

" Augmentation of the Engineering Staff- FENOC will augment the Engineering staff with personnel from outside of Davis-Besse to provide new insights and experiences to the Engineering staff. Communication and reinforcement of new standards by the added personnel will help raise performance.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 19

" Apply the FENOC Hierarchy of Documents to Davis-Besse - FENOC has established common processes that it uses at its Beaver Valley and Perry plants (and to some extent at Davis-Besse).

These common process documents will also be applied to Davis-Besse to ensure consistent policies and standards at all FENOC plants, including standards for analyses of safety issues. The FENOC Common Process program will ensure benchmarking and good industry practices are sought out and used at all three FENOC sites. For example, the Perry and Beaver Valley plants have successfully used a standard process for decision-making, called the Tech- 19 process, which provides a safety oriented and methodical approach to decision-making. This process will be brought to Davis-Besse to improve decision-making, including hazard analyses. Expectations for hazards analyses will identify when hazards analyses should be performed, the method for performing the analyses, and the qualification requirements for personnel performing the analyses.

"* Operations Shift Manager Role - Expectations and standards from senior management will be provided to the Shift Managers.

"* Operations Oversight Executive - A highly experienced individual (Operations Manager and Plant Manager background) from another utility has been brought into the Operations department to help establish the proper standards and behaviors.

"* Operations Excellence Plan - As described in section 6.2, Operations is improving their standards, and will lead the changes in site standards.

" Plant Labeling Improvements and Equipment Upgrades - The condition of the plant and equipment demonstrates management standards. Improvements in plant equipment are being made that will increase safety margins and improve the station assets. The following are some of the improvements or equipment being improved:

Reactor Cavity Seal Containment Painting Decontamination of Containment Reactor Coolant System Valves Diesel Air Start System Reactor Vessel Head Containment Sump Condenser Tube Sheet Coating Reactor Coolant Pumps Feedwater heater # 6 CTMT Air Coolers Plant Labeling FENOC will be providing training to ensure that personnel are aware of and implement the new standards. For example:

" Case Study Training - Training on the RPV head degradation event will be provided to station personnel. The Case Study will consist of a review of the timeline of the event with station personnel. These presentations will be done in small working groups, and will identify the decisions, actions and missed opportunities that led to the head degradation. These sessions will be provided by the site leadership team. The purpose is to ensure all personnel understand how the event happened, what barriers broke down, and what needs to be different in the future.

"* Decision-Making Training - Training on the FENOC Decision-Making Model will be provided to applicable personnel. This model ensures the right safety focus, and prompts a questioning attitude.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 20

• Training on Technical Standards -FENOC will provide initial and follow-up training within the next 12 months to reinforce technical standards and problem solving skills of the technical staff.

FENOC is taking a number of actions to ensure that its high standards are being met. These include the following:

Creation of a Management Observation Program - A Management Observation Program will be established and implemented to monitor individual performance and ensure that high standards are being implemented by personnel. This program will be adapted from the programs that have been successfully used at Perry and Beaver Valley, and will upgraded for use at Davis-Besse to schedule management observations on a weekly basis. This program will monitor effectiveness of work activities and worker behaviors, and will include the monitoring engineering activities.

Examples of attributes to be assessed include the following:

SQuality of pre-job briefs

> Proper safety practices and equipment use

> Effective communications

> Adequate supervisory behaviors

) Procedure or document use

> Use of station error prevention tools Data from these attributes will be used to create performance indicators to measure effectiveness of this plan.

Establishment of an Engineering Assessment Board (EAB) - As discussed in more detail in Section 6.4, FENOC has established an EAB, consistently largely of independent personnel with high standards. The EAB will be used to review and reinforce higher standards for engineering and other selected technical documents. The EAB's critical reviews of products, along with feedback to the supervisor, reviewers and preparers, will raise standards of Davis-Besse personnel.

In summary, FENOC is taking extensive actions to establish new standards for decision-making, training of personnel in the new standards, and monitoring to ensure that the standards are met.

Verification of Effectiveness FENOC will be taking the following steps to verify that its actions to improve standards and decision making at Davis-Besse are effective:

• Performance Indicators - FENOC will use the following performance indicators to measure improvements in the area of standards and decision-making:

> EAB Indicators - FENOC has established an indicator to measure the score for quality of Engineering products as assigned by the EAB. The score is based on an assessment of quality in the following areas: Procedural Performance/Implementation, Rigor in Problem Solving, Team Approach, Analysis/Evaluation/Design, Design Basis Maintenance, and Licensing Basis Maintenance. The score ranges from 0 to 4 with 0 being the best possible score and 4 being the worst. The goal at restart is to achieve an average score of 1.0 or less.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 21 SManagement Observation Indicators - The results of management observations will be tracked in the FENOC Observation Card Database, and will consist of both non-specific and focused or targeted observations in Field Activities, Operations, and Training.

>Repeat Events - This indicator measures the number of CRs that document repeat SCAQ. This is a long-term indicator.

> Accept As-Is - This indicator measures the percent of CRs whose disposition is accept as-is.

The goal at restart is to have a percent that is 10% or less.

> Open Control Room Deficiencies - This indicator measures the total number of open control room deficiencies. The goal is to have zero at restart.

> Open Operator Work Arounds - This indicator measures the total number of Operator Work Arounds. An Operator Work Around is defined as any equipment deficiency or plant condition which, during abnormal or emergency conditions, will increase operator burden or impede effective operator response. The goal is to have zero at restart.

> Open Temporary Modifications - This indicator measures the total number of temporary modifications. The goal is to have zero at restart.

Assessments: FENOC will perform the following assessments to measure performance in the area of standards and decision-making:

> EAB Assessments - As discussed above, the EAB will perform assessments of engineering products and other selected technical documents.

> Management Observations - As discussed above, management will regularly perform observations of plant activities to ensure conformance with management's expectations and standards.

SQuality Assurance Assessments - In contrast to past practices, QA will routinely be performing performance-based assessments of plant and engineering activities. Management observations, monitoring of technical quality documents, and FENOC assessments will ensure the effectiveness of the actions taken.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 22 6.4 Improvements in Oversight and Assessments Objective FENOC has the following objective for oversight and assessments at Davis-Besse:

Davis-Besse has provisionsfor oversight and assessments, which are effective in identifying andobtaining correction ofproblems before they adversely affect safety.

Actions FENOC is taking the actions listed in Table 4 to achieve its objectives in the area of oversight and assessments. In summary, these improvements are designed to provide additional assurance of ongoing work to support restart of Davis-Besse, as well as to achieve permanent improvements in oversight of Davis-Besse activities. In particular, FENOC has established the following oversight groups to ensure the adequacy of restart activities:

" Creation of a Restart Oversight Panel (ROP) - A ROP has been established, utilizing industry experts and community leaders, including former NRC senior managers and industry executives and representatives. The panel was formed to provide independent oversight and review of plant activities discovered or performed as part of the Davis-Besse Building Block Plans. The panel will advise company officials in any matter relating to the safe resumption of operation of Davis-Besse and provide recommendations as appropriate. The plant will not restart without ROP approval.

The ROP will continue to function after restart for a limited time.

" Establishment of an Engineering Assessment Board (EAB) - An EAB has been established, consisting largely of experienced outside consultants and some FENOC employees. The EAB is reviewing engineering products and the results of program, system, and other reviews to ensure the readiness of Davis-Besse to restart. These reviews are helping to ensure the adequacy of these products, as well as raising the standards of Davis-Besse employees who prepare the products. In addition to its role in overseeing readiness to restart from the current outage, the EAB will be made a permanent feature at Davis-Besse, and will gradually transition to use primarily Davis-Besse employees. The permanent responsibility of the EAB will include monitoring various engineering work products for appropriate standards. The EAB will use indicators to show performance at the section level, based on product reject rate and feedback.

" Creation of a Restart Senior Management Team (RSMT) - Davis-Besse has established a RSMT, which includes the site Vice President, the Plant Manager and other plant directors, and an independent consultant. The Restart Senior Management Team is responsible for reviewing and recommending approval of Building Block Plans and revisions; periodically reviewing the decisions to ensure items identified as restart and post-restart are consistent with senior management's expectations; reviewing restart reports for items on the Davis-Besse IMC 0350 Restart Checklist; periodically reviewing the overall implementation status of the Davis-Besse Return to Service Plan and Building Block Plans; and review and concurrence of Restart Closure Packages.

In addition, FENOC is taking action to permanently strengthen existing groups with oversight responsibility for Davis-Besse.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 23

" Improvements in Quality Assurance (QA) - The Nuclear Quality Assurance organization performed a root cause analysis to determine the adequacy of its audits and surveillances with respect to the boric acid degradation events. Based upon the results of that analysis, Quality Assurance process changes will be made. An example is increased QA oversight of Engineering activities. Other actions include raising the standards of the QA organization, increased use of performance based assessments, and ensuring that issues raised by QA are elevated to senior management in cases where the staff has not taken effective corrective action.

" Improvements in the Company Nuclear Review Board (CNRB) - The effectiveness of the CNRB is being reviewed by an experienced independent contractor under the QA organization, and changes are being made to improve its safety focus. In particular, the CNRB will place less emphasis on status of plant activities and license amendment requests and will engage in more review of key technical and safety issues, including reviews of the adequacy of activities during outages as well as operation. Additionally, the interval between CNRB oversight visits will be reviewed and changed if necessary.

" Improvements in the Project Review Committee - This group is the decision-making body for budget and scheduling of activities, including budget approval and scheduling for modifications.

The Project Review Committee charter and membership has been changed to ensure proper level of management decision-making. In particular, the changes will provide for director-level decision-making, to ensure items required for safe and reliable operation are not deferred.

Finally, FENOC is establishing new assessments as permanent activities at Davis-Besse, and is taking other actions to improve its existing assessment activities. For example:

"* Restart Readiness Reviews - A formal restart readiness review process will be developed for future plant restart activities. This process will provide the structure and rigor for assessing the readiness of the plant to be restarted.

" Periodic System and Program Reviews - As discussed in Section 5, FENOC has established System Health Assurance and Program Compliance Building Block Plans to assure the adequacy systems and programs prior to restart. These reviews will be institutionalized and made a permanent activity at Davis-Besse. In particular, Davis-Besse will perform periodic system walk downs and program reviews using criteria similar to those being used under the existing Building Block Plans.

" Improvements in Self-Assessments - Davis-Besse will make more aggressive use of outside peers for self-assessments and the use of INPO peer assist visits in the future. For example, QA personnel from Beaver Valley and Perry are being used in QA audits conducted at Davis-Besse to help ensure that audits are rigorous and to help raise the standards of Davis-Besse QA auditors.

"* Improved Expectations and Standards for Oversight - Improved expectations will be established for oversight by groups such as QA, EAB, and the Plant Operations Review Committee.

" Weekend Duty Oversight - New responsibilities have been created for the duty management team.

This includes the requirement for management presence at the site on weekends and holidays, as well as providing oversight of activities on those days. Besides the normal Monday through Friday morning meetings, morning meetings and a phone conference has been set up for weekends and holidays, and it is expected that a member of the duty management team run these.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 24 In summary, FENOC is taking action to provide for additional oversight to ensure the adequacy of restart activities and the readiness of plant to resume operations. Additionally, for the long-term, Davis-Besse is improving its oversight and assessment activities to ensure that they are effective in identifying and obtaining correction of problems before they adversely affect safety.

Verification of Effectiveness FENOC will be taking the following steps to verify that its actions to improve oversight and assessments at Davis-Besse are effective:

" Performance Indicators - FENOC will use the following performance indicator to measure improvements in oversight and assessments:

• Quality Assurance will track the number of CRs its prepares. This number should increase initially, but may be expected to decrease over time as overall plant performance improves.

> Quality Assurance will track the number of CRs its prepares that involve a repeat of previous conditions identified by QA. This number should increase initially, but may be expected to decrease over time as overall plant performance improves.

" Assessments - FENOC will perform the following assessments to measure performance in the area of oversight and assessments:

> FENOC will request INPO or independent contractors to perform an assessment of the oversight and assessment functions at Davis-Besse in the fourth quarter of 2002.

> FENOC will work with the Joint Utility Management Audits or other independent contractor to develop more rigorous annual assessments of the oversight and assessment functions at Davis Besse.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 25 6.5 Improvements in Programs / Corrective Action / Procedure Compliance Objective FENOC has the following objective for programs, corrective action and procedure adherence at Davis Besse:

Programscomply with NRC regulations, incorporateapplicable operatingexperience, andare effectively implemented. Adverse conditions (including adverse trends) arepromptly identified and documented. The root causes of significantconditionsadverse to quality are identified, actions are taken to preclude recurrence of the conditions,and the preventive actions are effective. Personnelcomply with proceduresas written, or obtainproper revisions as needed.

Actions FENOC is taking the actions listed in Table 5 to achieve its objectives. In summary:

Actions to Improve Programs FENOC has established and is implementing the Program Compliance Building Block Plan. This Plan provides for a two-phase review of programs. Phase 1 consists of a baseline assessment of more than 60 plant programs to determine if the programs are in a condition to support the restart and safe operation of Davis-Besse. In this review, the program owner assesses the program by completing a standardized questionnaire. The program owner then presents the results of the assessment to a Program Review Board, which includes independent, external personnel. The Program Review Board reviews the program utilizing a screening form. Condition Reports are generated to document and correct program deficiencies, and the CRs are evaluated to determine whether the corrective action should be identified as a restart restraint. Phase 2 consists of an in-depth systematic review of the Probabilistic Safety Assessment Program, Boric Acid Corrosion Control Program, In-service Inspection Program, Plant Modifications Program, Corrective Action Program, Reactor Coolant Unidentified Leakage Program, and Operating Experience Program. Additionally, after restart, another 14 programs will receive a Phase 2 review. This process evaluates programs in depth to ensure that the programs are fulfilling required obligations, including interfaces and handoffs, and are sufficient to support the restart and safe operation of Davis-Besse. The reviews include elements to ensure that each program has an owner, and that the owner is properly qualified.

On a long-term basis, follow-up assessments of programs will be performed using the same criteria as the Phase 2 restart program reviews. The results will be communicated through specific program health indicators.

FENOC is also taking wide-ranging action to ensure that each program has a qualified owner who ensures that the program achieves its goals. For example:

Program Ownership - The Program Compliance Plan and the functional area reviews under the Management and Human Performance Excellence Plan include reviews of plant programs to ensure appropriate ownership of the programs. The reviews include elements to ensure that each program has an owner, and that the owner is properly qualified. Additionally, in the Phase 1 Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 26 program reviews, an independent Program Review Board assess the adequacy of self-assessments performed by program owners of their owners, thereby helping to foster greater ownership by the program owners.

"* Expectations for Program Ownership - Clear expectations for program and process ownership will be provided.

" Improvements to the Ownership Model - The Ownership Model provides for the assignment of ownership to plant programs and processes and defines the responsibilities of the owners, Under this Model, performance indicators are established by the owner to measure and communicate the health of the individual programs. Refinements to the Ownership Model and indicators will be made to provide effective continuous assessment of the various station processes.

"* Qualification Process for Owners - A qualification process will be developed for program ownership. This will be used to ensure that the current, as well as any future program owner, has the proper training, understanding, and background in the program to ensure its success.

" Improvements to the Self-Assessment Program - This program provides the means to perform critical assessments of processes or activities, and to ensure standards and performance in the areas assessed are proper. The self-assessment program will be benchmarked and changed to provide a tie to the Ownership Model. The tie to the Ownership Model will provide the means to monitor and communicate the overall process or activity health.

Actions to Improve Program/Procedure Compliance FENOC is taking the following actions to ensure personnel are aware of FENOC's standards for procedure compliance, and that the management ensures that these standards are met.

"* Reinforcing Standards for Procedure Compliance - Davis-Besse will be reinforcing standards and expectations for procedure compliance and the need for work practice rigor.

"* Emphasis on Procedure Compliance at Morning Meetings - The need for procedure compliance will be discussed regularly at the morning meeting of managers.

"* Management Observations - As discussed in Section 6.3, FENOC is establishing a Management Observation Program to provide direct management observation of and guidance to workers. This program will include observations of procedure compliance by employees.

Additionally, FENOC is making improvements in specific programs. Based upon FENOC assessments of the RPV head degradation and other events, FENOC is making improvements in the following programs:

• Boric Acid Corrosion Control (BACC) Program - FENOC is making a number of improvements in its BACC Program. These improvements include the following:

>FENOC will establish a Boric Acid Nuclear Operating Procedure for its pressurized water reactors (PWRs), including Davis-Besse.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 27

> The BACC Program Manual lists the CRDM nozzles as one of the probable locations of leakage.

> The scope of reactor coolant system (RCS) leakage inspection plans will be upgraded to include systems that carry borated water and provide mitigating type functions that help to preserve the Reactor Coolant Pressure Boundary during plant transients and/or accidents.

> The BACC procedure will be revised to require the retention of the Boric Acid Corrosion Control Inspection Checklists.

> The Boric Acid Corrosion Control Program Owner and System Engineer will be required to document his review and concurrence with boric acid disposition activities

> The BACC procedure will be upgraded to require that boric acid "shall" be removed from affected areas and the affected area inspected to identify any signs of potential corrosion.

" In-service Inspection (ISI) Program - FENOC is making a number of improvements in its ISI Program as it pertains to inspections for RCS leakage. These improvements include the following:

> A hard link will be established between the ISI Program and the BACC Program that will require the groups responsible for both of these programs to approve the close out of a Boric Acid Corrosion Control Inspection Checklist.

> The text descriptions of the areas to be inspected will be improved, including sketches of the areas.

> Pre-job briefs will be required prior to inspecting bolted connections for leakage during plant heat up.

> The ISI Program will be revised to reinforce the obligation to protect and preserve the RCS pressure boundary, including addressing boric acid deposits on the RCS pressure boundary even in cases deposits are identified in specific areas that were not included in the original inspection plan.

" Corrective Action Program - As part of the Program Compliance Plan, FENOC is conducting a detailed review by independent consultants of the corrective action program and its implementation. This review will benchmark the corrective action procedure against industry standards. Additionally, the corrective action program will be reviewed to identify whether it contains appropriate provisions for ensuring the timely resolution of conditions. As a result of this review, FENOC will be taking appropriate corrective actions for any identified weaknesses. In addition, based upon its other assessments, FENOC has already determined to make the following improvements:

Operability Reviews - Davis-Besse is taking several actions to improve reviews of the operability of structures, systems, and components (SSCs) with degraded and nonconforming conditions. First, Davis-Besse has changed its terminology from "operability justification" to "operability determination" to reflect the plant's change in focus from justifying the acceptability of adverse conditions to determining whether there is sufficient information to warrant the continued operability of SSCs. Second, operations is using Engineering resources more in their initial Operability determination.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 28

" Categorization of Adverse Conditions - The criteria for categorization of adverse conditions will be upgraded. These criteria will be sufficient to elevate repeat Condition Adverse to Quality (CAQ) failures (including repeat equipment failures to a Significant Condition Adverse to Quality (SCAQ) categorization, which requires utilizing of a higher evaluation method. Additionally, the number of categories will be expanded to enable conditions to receive greater attention and evaluation without requiring the condition to be categorized as a SCAQ. FENOC will also be conducting a review existing long-standing issues for possible SCAQ categorization and use of root cause evaluation techniques to obtain resolution of the issues.

" Improvements in Cause Determinations - A Problem Resolution Process used at other FENOC stations will be implemented at Davis-Besse. Cause evaluations will be restricted to those demonstrably qualified. Proficiency in cause training will be maintained by a smaller group of personnel who have the knowledge, skills and ability to perform good cause evaluations. The corrective action procedure will be revised to require the use of formal cause determination techniques for conditions in the more significant categories to ensure that analytical rigor is applied to the analysis. A tiered approach to the number and type of techniques applied will be developed. Additionally, training requirements will be defined and implemented for cause evaluations, especially for equipment analysis. Finally, to provide assurance of the adequacy of apparent cause evaluations, FENOC will provide periodic independent reviews and self-assessments of those evaluations.

" Improvements in Corrective Actions - The guidance on reviews of the effectiveness of corrective actions will be improved to focus on verifying that causes have-been fixed, and training will be provided on the revised guidance. Additionally, the procedure will be revised to require the use of safety precedence sequence (e.g., corrective actions are determined with a preference for using design to minimize hazard; then safety devices; then safety warning; then procedures; and finally training and awareness) for correcting root causes. Ensure that the case study of this and other events includes emphasis on the need to find and address the causes of adverse conditions and the potential consequences of failures to do so.

" Improvements in Trending - FENOC will develop and implement an effective site wide equipment trending program. This program will define what is to be trended periodically (e.g. vendor, failure mode, failure mechanism, environmental, material issues).

Additionally, to ensure that outage-related issues receive appropriate evaluation, trending will also be performed for issues that occur only during outages.

" Improvements in the Corrective Action Review Board (CARB) - The CARB is used to oversee the adequacy of corrective actions. The CARB will be improved in several ways.

First, to provide additional leadership, the CARB is now being chaired by the Plant Manager or other plant director-level individual. Additionally, the reviews performed by the CARB will be expanded to enforce higher standards for cause evaluations and effective corrective action. The CARB will use indicators to show performance at the section level, based on product reject rate.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 29 In addition, at the FENOC level, both Perry and Beaver Valley will perform assessments of their management / human performance quality based on the lessons learned from the Davis-Besse root cause.

Verification of Effectiveness FENOC will be taking the following steps to verify that its actions to improve programs at Davis Besse are effective:

" Performance Indicators - FENOC will use the following performance indicators to measure improvements in programs:

); Individual programs will have a program health indicator.

> Davis-Besse has a performance indicator for Program and Process Errors, which measures undesirable situations caused by the lack of information in programs or processes for the performer to complete the task or evolution successfully. The goal for restart is 0.7 per 10,000 person-hours

"* Assessments - As discussed above, FENOC will be performing periodic detailed reviews of programs to assess the adequacy of programs.

FENOC will be taking the following steps to verify that its actions to improve program / procedure compliance at Davis-Besse are effective:

"* Performance Indicators - FENOC will use the following performance indicators to measure improvements in procedure compliance:

> FENOC will track the number of CRs (both CAQs and SCAQs) due to failure to follow procedures. Initially, it is expected that this number will increase because the station is sensitized to identification of adverse conditions, including procedure noncompliance. Over time, this number should level off and then decrease as station performance improves.

> As discussed above, management observations will include reviews of procedure compliance.

Management observations of procedure compliance will be trended. The trend should be similar to the trend of CRs involving procedure non-compliance.

"* Assessments - FENOC will perform the following assessments to measure performance in the area of procedure compliance until it is satisfied with performance in this area:

> Quality Assurance will perform detailed audits of the adequacy of procedure compliance on a semiannual basis.

> On a semiannual basis, FENOC will perform an evaluation using human performance evaluation system (HPES) techniques to determine the causes of procedure noncompliance and develop actions to improve performance.

> Quality Assurance routinely performs surveillances of plant activities. These surveillances will include checks for procedure compliance, and the results of the surveillances will be trended.

FENOC will be taking the following steps to verify that its actions to improve corrective actions at Davis-Besse are effective:

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 30

" Performance Indicators - FENOC will use several performance indicators to measure improvements in performance of corrective actions. These indicators are as follows:

> Categorization - This indicator measures the percentage of categorizations presented to CARB that were approved by that board. The goal is to have 95% or better.

> Root Cause Quality - This indicator measures the cumulative percentage of Root Cause Determinations and Effectiveness Reviews presented to the CARB that were fully approved by that board. For restart, a preliminary goal of 90% or better has been established.

> Corrective Action Adequacy - This indicator measures the adequacy of corrective actions as determined by CARB. For restart, the goal is 90% of better.

> Repeat Events - This indicator measures the number of CRs that document repeat SCAQ. This is a long-term indicator.

> Timeliness of Corrective Actions - This indicator measures the ability to appropriately schedule and meet the schedule for corrective actions. The goal for restart is an improving trend at restart.

" Assessments - FENOC will perform the following assessments to measure performance in the area of corrective actions:

> On an ongoing basis, the EAB will be reviewing a sample of engineering products, including engineering assessments of and proposed corrective actions for adverse conditions.

>Until FENOC is satisfied for the adequacy of its corrective actions, FENOC will arrange for an independent assessment of the adequacy of corrective actions on a semiannual basis.

> Quality Assurance will performed detail audits of the adequacy of corrective actions on an annual basis.

Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 31 6.6 Summary of Department-Level Actions to Improve Performance In addition to the actions described above, the following Departments are creating group specific Improvement Plans:

Operations Radiation Protection / Chemistry Maintenance Engineering The Operations Section has developed an improvement plan to achieve the following goals:

)> Operations is recognized as the lead organization at Davis-Besse.

> Continuous improvement is expected, demonstrated and embraced in the Operation Section

> Operations ownership of equipment deficiencies, nuclear fuel performance, and plant chemistry is strong

> Operations Management communicates, demonstrates, and reinforces desired performance standards to operate the facility at desired levels, and

> Shift management consistently demonstrates leadership to staff, craft, and oversight personnel Management & Human Performance Improvement Plan 6.0 Actions to Achieve Excellence

Page 32 7.0 Verification of Effectiveness 7.1 Performance Indicators Section 6 describes the performance indicators for each category of issues related to Management and Human Performance. In addition, FENOC has established ten performance indicators to measure its overall improvement in performance under the Return to Service Plan. These indicators are as follows:

" Self-Identification of Adverse Conditions - This indicator calculates the percent of CRs that are self-identified. CRs originated as a result of QA, INPO, or NRC or as a result of a self-revealed issue are not considered to be self-identified. The goal for restart is to have 80% or more of the CRs as self-identified.

"* Open Control Room Deficiencies - This indicator measures the total number of open control room deficiencies. The goal is to have zero at restart.

"* Open Operator Work Arounds - This indicator measures the total number of Operator Work Arounds. An Operator Work Around is defined as any equipment deficiency or plant condition which, during abnormal or emergency conditions, will increase operator burden or impede effective operator response. The goal is to have zero at restart.

"* Open Temporary Modifications - This indicator measures the total number of temporary modifications. The goal is to have zero at restart.

"* Root Cause Quality - This indicator measures the cumulative percentage of Root Cause Determinations and Effectiveness Reviews presented to the CARB that were fully approved by that board. For restart, a preliminary goal of 90% or better has been established.

"* EAB Indicators - FENOC has established an indicator to measure the score for quality of Engineering products as assigned by the EAB. The score is based on an assessment of quality in the following areas: Procedural Performance/Implementation, Rigor in Problem Solving, Team Approach, Analysis/Evaluation/Design, Design Basis Maintenance, and Licensing Basis Maintenance. The score ranges from 0 to 4 with 0 being the best possible score and 4 being the worst. The goal at restart is to achieve an average score of 1.0 or less.

"* Total Maintenance Backlog - This indicator measures the number of open Work Orders which are awaiting implementation. The goal for restart is less than 500.

"* Open Modifications - This indicator measures the total number of open Modifications. The goal for restart is less than 200.

"* Open Procedure Change Request - This indicator measures the number of Procedure Change Requests (PCRs) which are awaiting incorporation into Davis-Besse procedures. A PCR is considered completed when it is incorporated into an effective procedure or when the PCR is cancelled. The above count does not include category/priority 4 PCRs as these PCRs are restrained by plant modifications, license amendment requests, etc. and cannot be closed until these restraints are completed. The goal for restart is less than 250.

"* Restart Training - This indicator measures the number of permanent Davis-Besse employees who have not completed the required restart training. The goal for restart is zero.

Management & Human Performance Improvement Plan 7.0 Verification of Effectiveness

Page 33 As indicated above, and in Section 6, FENOC has established goals for restart. These goals are not prerequisites and are not sufficient, in and of themselves, to enable FENOC to reach a restart determination. Instead, FENOC will consider all relevant factors, including whether the indicators show an improving trend, and the results of the assessments discussed in the next section, to make a restart determination. Additionally, in accordance with the NRC's Confirmatory Action Letter, NRC approval will be required for restart of Davis-Besse.

In addition to these performance indicators, Davis-Besse has a Monthly Performance Report that monitors other performance indicators that pertain to the overall quality and safety of performance of the plant. These indicators include the following:

"* INPO Performance Indicator Index

"* Collective Radiation Dose

"* Risk Performance Indicator

"* Maintenance Rule Safety Significant Reliability

"* High Pressure Injection Safety System Performance

"* Auxiliary Feedwater Safety System Performance

"* Emergency AC Power Safety System Performance

"* Corrective Action Program Effectiveness

"* Training Program Performance Indicator

"* Individual Errors

"* Program and Process Errors

"* Event Free Clock

"* Unplanned Automatic Scrams

"* Forced Loss Rate

"* NRC Performance Indicators In general, each of these indicators has an assigned goal.

7.2 Other Measures Section 6.4 describes the various oversight groups and the assessments they are performing.

Management & Human Performance Improvement Plan 7.0 Verification of Effectiveness

Page 34 8.0 Conclusions As a result of its analyses and assessments, FENOC has identified several categories of causes of its management and organizational performance problems. For each of these areas, FENOC has identified:

"* objectives for obtaining improved performance in the area;

" restart and post-restart actions for achieving improved performance, including identification of the responsible managers and schedules for the actions; and

"* measures to verify the effectiveness of those actions.

Additionally, FENOC has identified measures to verify overall improvement in performance.

Upon completion, these actions will ensure that FENOC will ready for safe and reliable operation of Davis-Besse and ultimately to achieve excellence in performance.

Management & Human Performance Improvement Plan 8.0 Conclusions

Page 35 Tables Table 1 Actions to Achieve Improvement in Safety Culture No. Action Restart Responsible Start End Action? Manager Date Date Create a FENOC Safety Policy Y New FENOC Executive Team Complete New Senior Team for Davis-Besse Complete Safety Focus Training through

• Leadership in Action Provide Case Study Training Y Business Plan Alignment of Safety / N Values Revise Performance Incentives N 4-C's meetings Y Town Hall Meetings Y Restart Overview Panel (ROP) Employee Y Meetings Implement the Management Observation Y,

• Program Implement the Management Monitoring Y,

• Program Safety Conscious Work Environment Complete (SCWE) Survey Implement "People" Team Y Communicate Standards of Excellence Y Implement FENOC Decision-making Y process Evaluate current Directors / Managers on Y alignment, Safety # 1 Implement the SCWE Improvement Plan *

(see plan on next page)

• Actions will continue past startup Management & Human Performance Improvement Plan Figures

Page 36 SCWE Improvement Plan Sub- Item Responsible Due Task Task Person Date 1.0 LWP 8/19 Present Action Plan to ROP 2.0 LM/LWP 8/19 Appoint Project Manager 3.0 Conduct Training 3.1 Train Directors and Managers PM 3.2 Incorporate SCWE training into "Leadership in PM / Trng.

Action" Course Dept 3.3 Train Supervisors, including Contractors PM 3.4 Augment GET on SCWE principles PM / Trng.

Dept 4.0 Develop/Implement Site Communication Plan 4.1 Publicize Survey and SCWE Action Plan 4.2 Develop External Communication Plan 14.3 Add SCWE Elements to Davis-Besse Case Study 4.4 Expand "Great Catch" Program 14.5 Add SCWE Elements to "4C's" Program 5.0 Implement "People Team" 5.1 Create Charter 5.2 Appoint Members 5.3 Adopt Emergency Response Process 5.4 Communicate to Site 6.0 Develop and Implement "Issue Management Process" 6.1 Create NOP (and Reference Guide) or Site-Specific Procedure 6.2 Assure CAP Interfaces and Requirements Are Maintained (Operability / Reportability) 6.3 Communicate to Site 7.0 Create ECP/Ombudsman Contingency Plan 7.1 Re-evaluate SCWE Policy and Ombudsman Charter (Including Confidentiality, Scope, and Mission) 7.2 Borrow and Implement Best Practices and Tools 7.3 Designate and Train Cadre of Investigators (including Off-site Reserve Investigators) 7.4 Communicate to Site 8.0 Monitor Site SCWE Performance Management & Human Performance Improvement Plan Figures

Page 37 Sub- Item Responsible Due Task Task Person Date 8.1 Perform Second-Level Analysis of August 2002 SCWE Survey Data to Identify Trends / Pockets 8.2 Conduct Periodic Surveys (including Targeted Questions) 8.3 Develop / Implement / Track SCWE Performance Indicators 9.0 Develop Regulatory Communications Strategy 9.1 NRC Region 9.2 0350 Process 9.3 Resident Inspector Management & Human Performance Improvement Plan Figures

Page 38 Table 2 Actions to Achieve Improvement in Management / Personal Development No. Action Restart Responsible Start End Action? Manager Date Date (New FENOC Executive Team) Complete (New Senior Team at Davis-Besse) Complete Management/Supervisor Evaluations Leadership in Action Revision and

• implementation Revised Ownership for Excellence for Y directors and managers Review of Foundations for Leadership N Training for improvements Requalification training on Ownership N for Excellence Plan Establish an Operations Leadership Plan Y Management Monitoring Program Y (Evaluate current Directors / Managers Y on alignment, Safety # 1)

Management & Human Performance Improvement Plan Figures

Page 39 Table 3 Actions to Achieve Improvement in Standards and Decision-Making No. Action Restart Responsible Start End Action? Manager Date Date Establish technical staff expectations Complete Powers Improve Industry Operating Experience Y Program (OE)

FENOC Resource Sharing N Augment Engineering staff Y Apply FENOC hierarchy of documents Y Implement the Engineering Assessment Complete Board (EAB)

Decision Making model and training Y implementation (Case Study Training) Y Issue Weekend duty requirements Y (New Management Team with high Complete standards)

(Create a Management Observation Y Program)

(Create a Management Monitoring Y Program) &

(Communicate Standards of Excellence) Y Addition of an Operations Oversight Complete Executive Equipment Upgrades

• Plant Labeling Improvements

• Issue Operations Shift Manager Role Y Letter Follow-up technical training N (Establish an Operations Leadership Y Plan)

Integrate Operations into Decision- Y making, promote ownership Apply FENOC Common Processes N Re-baseline standards, issue (all groups) Y Management & Human Performance Improvement Plan Figures

Page 40 Table 4 Actions to Achieve Improvement in Oversight and Assessments No. Action Restart Responsible Start End Action? Manager Date Date Institutionalize Program Reviews N Institutionalize System Walk-down N Reviews Improve Self Assessment Program N CNRB Safety Focus Improvements Y Functional Area Reviews N Increase Quality Oversight of Y Engineering CNRB Program Reviews online and N outages Establish the Restart Oversight Panel Y (ROP)

Create a Restart Senior Management Complete Team (Strong Operational Focus Senior Team) Complete Establish the Engineering Assessment Complete Board (EAB)

Improve Corrective Action Review Complete Board (CARB) oversight Quality Oversight (QA) improvement

• plan Improve Project Review Committee Complete (PRC) oversight Weekend Duty Oversight requirements Establish a Restart Readiness Review N Strengthen Procedure Adherence through N Management Oversight (Management Observation Program) Y,*

Improved Expectations for Oversight N (QA, PORC, EAB)

Management & Human Performance Improvement Plan Figures

Page 41 Table 5 Actions to Achieve Improvement in Programs / Corrective Action I Procedure Compliance No. Action Restart Responsible Start End Action? Manager Date Date Implement Program Compliance

• Morrison Building Block Plan Provide Ownership Expectations Y Improve Cause Determinations Y Improve Categorization of CRs Y Improve Operability Reviews Y Improve Corrective Actions Y Improve Trending Y Improve Effectiveness Reviews N (Improve CARB) Complete Improve Boric Acid Corrosion Control Y (BACC) program Improve In-Service Inspection (ISI) N program Improve Self Assessment Program N (Improve Industry Experience Program (OE))

(Case Study) to communicate need to Y Eshelman find/address causes Reinforce Procedure Adherence Y standards via case study Improve Benchmarking Program N SMT review of all root causes Y Independent reviews of apparent causes N Provide apparent cause training N MCTM Changes to discuss procedure Y compliance Refine Ownership Model and indicators N Implement a Program Ownership N Qualification Process (Management Observation Program) for procedure compliance Management & Human Performance Improvement Plan Figures

Page 42 This page intentionally left blank

Page 43 Figures Davis-Besse Site Organizat'ion, VICE PRESIDERT FE CHIEF EXECUTITk-'E VICE FENOC OVERSIGHT Fp ý10'1-'

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Page 44 Attachments Attachment 1 Correlation of Individual Causes with Corrective Actions Cause or Observation Reference to Applicable Action in Section 6 Root CauseAnalysis Report of SignificantDegradation of the Reactor Pressure Vessel Head (April15, 2002)

PWSCC cracking in the CRDM nozzle interface at the J-groove weld due N/A - part of to material susceptibility in the presence of a suitable environment. Reactor Head resolution plan Boric Acid Corrosion Control and ISI programs and program 6.5 implementation regarding the RPV head.

Environmental conditions, cramped conditions due to the design and high N/A - part of radiation at the RPV head. Reactor Head resolution plan Equipment condition due to uncorrected CRDM flange leakage N/A - no actions (especially at nozzle 31 due to its close proximity to nozzle 3). required (corrected)

Management monitoring of field activities did not identify problems. 6.1, 6.2, 6.3 Management monitoring of activities did not identify changes in 6.1, 6.2, 6.3 conditions.

Technical standards. 6.3 Oversight. 6.4 Previous industry and in-house experience were not effectively used to 6.3, 6.5 prevent problems.

Execution of the Condition Report Program 6.5

"*Appropriate categorization of CR

"*Over sight of CR responses for technical accuracy and license impacts

"*Discussions with persons indicate that standards for initiating CRs may not be aligned with program expectations Root Cause Analysis Report of Failureto Identify SignificantDegradationof the Reactor Pressure Vessel Head (August 13, 2002)

Less than Adequate Nuclear Safety Focus - A production focus 6.1 established by management, combined with taking minimum actions to meet regulatory requirements, resulted in acceptance of degraded conditions on the RPV head and other components affected by boric acid.

Less than Adequate Implementation of the Corrective Action Program - 6.5 Implementation of the Corrective Action Program was less than adequate, as indicated by the following:

Management & Human Performance Improvement Plan Attachments

Page 45 I

"* Addressing Symptoms Rather Than Causes

"* Low Categorization of Conditions

"* Less than Adequate Cause Determinations

"* Less than Adequate Corrective Actions

• I

• than Adenirnte. Trending Less than Adequate Analyses of Safety Implications - Failure to integrate 6.3 and apply key industry information and site knowledge/experience, effectively use vendor expertise, and compare new information to baseline knowledge led to less than adequate analyses and decision making with regard to the nuclear safety implications of boric acid on the reactor vessel head and in the containment.

Less than Adequate Compliance with Boric Acid Corrosion Control 6.5 (BACC) Procedure and Inservice Test Program - Contrary to these programs, boric acid was not completely removed from the RPV head.

The affected areas were not inspected for corrosion and leakage from nozzles and the sources of the leakage were not determined.

Lack of Hazard Analyses - Evaluations and decisions were made without 6.3 hazards analyses that may have led to the identification of the nozzle leakage.

Corrective Action Procedure - The Corrective Action Procedure has 6.5 provisions that do not reflect state-of-the-art practice in the industry, which may have allowed less than adequate corrective actions.

Design - The design failed to prevent leaks of boric acid. The Alloy 600 N/A - part of material used in the original design of the CRDM nozzles was Reactor Head susceptible to cracking and leakage, and the original gaskets in the resolution plan CRDM flanges were susceptible to leakage.

Training - Training was not provided to the ISI VT-2 inspector on boric 6.3 acid corrosion, and training on inspections was not provided to the engineers who conducted the inspections of the RPV head for boric acid in 1ORFO and 11 RFO. The training provided following the RC-2 event was less than adequate.

Coordination of Boric Acid Control Activities - The RPV head 6.5 inspection activities and resolution of the corrective action documents on the head were not coordinated through the BACC Coordinator.

BACC Procedure - The BACC Procedure does not specifically reference 6.5 the CRDM nozzles as one of the probable locations of leakage.

Untimely Corrective Action - Condition reports associated with the boric 6.5 acid issues tended to stay unresolved until significant degradation occurred.

Quality Assurance - There was little evidence of QA's involvement in 6.4 this area, and the documented findings by QA were of mixed quality.

Incentive Program - The FENOC monetary incentive program rewards 6.1 production more than safety at senior levels of the organization.

Policies on Safety - The written policies have been inconsistent and 6.1 incomplete in their treatment of employee and nuclear safety and do not support a strong safety focus.

Management & Human Performance Improvement Plan Attachments

Page 46 Operations Involvement - Operations had minimal involvement in 6.3 resolution of boric acid issues.

Management Observations - Management had minimal entries into 6.1, 6.3 containment and observation of conditions in the containment.

Root Cause Analysis Report of Failureof Quality Assurance Oversight to Prevent SignificantDegradationof ReactorPressure Vessel Head Historically, corporate nuclear safety values, behaviors and expectations 6.1, 6.4 were inadequate to enable oversight to effect needed positive change in station operations.

The training for the RC-2 event was ineffective in improving the 6.3 recognition of and the significance of corrosive conditions. This contributed to the failure of the audit team to raise a concern when auditing the Boric Acid Corrosion control Program during 12RFO.

The process for providing oversight of the oversight function was less 6.4 than adequate, feedback provided was mixed, and corrective actions were sometimes ineffective.

For a period of time, the management of the audit/evaluation process was N/A- QA is now not independent from the management of the corrective action process. independent Implementation of the Corrective Action Program was ineffective 6.5

"* Failure to identify issues

"* Failure to evaluate identified issue

"* Failure to identify causes

"* Failure to correct the issues

"* Failure to prevent recurrence of issues

"* Lack of timeliness of corrective actions

"* Failure to evaluate effectiveness of corrective actions Lack of management and supervisory ownership 6.1, 6.5 Aggressive management style 6.1 Lack of Engineering rigor 6.3 Nuclear QualityAssurance Examination of Five Closed Nonconformances Related to the Reactor Pressure Vessel Head (June 13, 2002)

Minimal role of Operations 6.3 Procedure non-compliance 6.5 Inadequate communications and teamwork 6.1, 6.3 Davis-Besse 8/2002 Safety Conscious Work Environment Survey Employee willingness to report concerns 6.1 Confidence in the Employee Concern/Ombudsman Process 6.1 Management support for Concern Reporting 6.1 Effectiveness of the Corrective Action Process 6.1 Management's effectiveness in detecting & preventing retaliation 6.1 Management & Human Performance Improvement Plan Attachments

Attachment 11 Restart Test Plan Revision 2 January 9, 2003

Davis-Besse Restart Test Plan Revision 2 Date: January 9, 2003 Sner: Tony Stallard ves

• Randy Fast Restart Senior Management Team Chairman Approved by: Vw Myers

Table of Contents Title Page Summary of Revision Changes ............................................................ 2 Executive Summary ............................................................................. 3 Charter .......................................................................................... 4 Plan Description .................................................................................... 4 Reactor Coolant System Leakage Testing .................................... 4 Containment Leakage Rate Testing ............................................. 6 Evaluation of Post Maintenance and Post Modification Testing ...... 7 Integrated Restart Procedure ........................................................ 7 Page I of 7 Revision 2 January 9, 2003

Summary of Revision Changes Revision 1 This is a total rewrite to increase the scope of this plan. The following activities have been added to the plan:

"* Integrated leakage rate testing of containment

"* An evaluation of testing on systems and components that may have been affected by RCS leakage and boric acid deposits

"* Development of an integrated restart procedure to provide a mechanism to control restart of the plant by ensuring all applicable restart actions have been completed prior to mode ascension.

This revision also eliminates the evaluation of the RCS Leakage Management Program.

This evaluation is now included in the Program Compliance Plan, therefore, the title of this plan has been changed to eliminate post restart activities.

Revision 2 Revised the reference to the "Restart Senior Management Team" to "Senior Management Team" to be in accordance with the revised charter.

Added operator training requirements on the Integrated Restart Procedure prior to restart.

Added the RCS pressure for Mode 5 leak testing.

Clarified the composition of the inspection team for RCS leakage tests.

Added the expectation of "lowest attainable value" for the RCS leakage tests.

Added walk downs and inspections during RCS heat up to resolve an INPO comment.

Addressed incore nozzle leakage concerns by adding a stay time at normal operating pressure in Mode 3 and then cooling down to perform a visual inspection of the reactor head and reactor bottom nozzles.

Clarified insulation status during RCS leakage tests.

Added references to assist in the evaluation of uncorrected boric acid leakage.

Deleted reference to "as left" photographs since this is not part of the BACC program.

Page 2 of 7 Revision 2 January 9, 2003

Executive Summary This plan has four key elements to ensure that comprehensive testing is performed prior to and during restart, and that restart activities have been completed to ensure Davis Besse Nuclear Power Station is in a condition to support sustained, safe, and reliable operation. These elements include:

" Testing the Reactor Coolant System (RCS), including components within the Reactor Coolant Pressure Boundary (RCPB) and associated piping exposed to full RCS pressure, to ensure integrity following replacement of the Reactor Vessel Head and maintenance of RCS piping and components. The leakage inspections will include the reactor vessel head Control Rod Drive nozzles and the reactor vessel bottom incore nozzles.

"* Testing the Containment by performing an Integrated Leakage Rate Test in accordance with 10CFR50, Appendix J (Type A test) to ensure the integrity of containment following restoration of the containment pressure vessel.

"* Evaluating the adequacy of proposed post-maintenance and post-modification testing on systems and components affected by RCS leakage and boric acid deposits and to determine if additional testing is required.

"* Developing an Integrated Restart Procedure to ensure required restart activities, tests, and inspections have been performed prior to mode ascension.

The Integrated Restart Procedure shall identify the sequence of critical steps, procedures, and tests that must be performed to safely restart Davis-Besse Nuclear Power Station.

This procedure shall also include the necessary administrative controls required to authorize mode changes during plant restart. In addition to the normal procedure approvals, the Integrated Restart Procedure shall be reviewed by the Engineering Assessment Board and receive concurrence from the Senior Management Team. Final authority to restart the plant resides with the FENOC Chief Operating Officer.

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Charter Perform Restart Testing necessary to ensure the integrity of the Reactor Coolant Pressure Boundary and the Containment Pressure Vessel, and to evaluate proposed testing of systems and components affected by RCS leakage and boric acid deposits.

In addition, develop an Integrated Restart Procedure to ensure that proper sequencing of required restart activities be accomplished prior to mode ascension. Provide operator training on this procedure to ensure this infrequently performed test/evolution is conducted in a safe, controlled manner.

Plan Description Reactor Coolant System Leakage Testing Two separate RCS leakage tests are included in the scope of this plan. The first test will occur after initial fill and vent and the RCS pressurized to approximately 250 psig. RCS temperature will remain less than 200'F during the first test (Mode 5). The second test will occur at the normal operating pressure of approximately 2155 psig (Mode 3). For both tests, RCS temperature will be maintained as required by the pressure-temperature curve limits and other equipment restrictions.

Inspections will be performed on the following with the systems in their normal lineup:

"* Reactor Coolant Pressure Boundary piping and components.

"* RCS piping and components that are subjected to RCS pressure during normal operation.

"* Portions of the makeup and letdown system, instrumentation and sampling piping and components connected to the RCS that are subjected to RCS pressure during normal operation.

"* Piping systems outside containment, such as normal makeup and letdown that are pressurized to RCS pressure during normal operation.

A cross-disciplinary team of qualified inspectors will perform the leak testing inspections of the RCS and associated piping. These inspections will be conducted using approved procedures and /or inspection plans. Inspections will be performed on the external surfaces and low points of insulated and uninsulated piping and components for evidence of active RCS leakage. Insulation was removed from mechanical joints and Alloy 600 welds to perform containment health inspections of boric acid containing systems. This insulation will be re-installed to support the RCS heat up except at suspected welds and mechanical joints that may require additional inspections.

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Areas within the scope of these inspections include, but are not limited to:

"* Reactor Vessel flange

"* Reactor Head CRDM nozzles penetrations

"* Reactor Head CRDM flanges

"* Reactor Vessel Incore Detector penetrations

"* Steam Generator and Pressurizer manways and hand-holes

"* Reactor Coolant Pump covers

"* Reactor Coolant Pump seal area

"* Pressurizer Heaters

"* Pressurizer Safety and Relief Valves

"* Body to bonnets on RCS Valves and packing glands

"* Bolted connections and flanges The goal of the RCS low-pressure leakage test is to have the lowest attainable RCS leakage prior to going to Mode 4. Any identified leakage shall be documented on Condition Reports designated as Mode 4 restraints requiring resolution prior to performing RCS heatup to normal operating temperature and pressure.

Following the evaluation of Condition Reports and completion of required corrective actions, the RCS will begin heat up to Mode 3. As the pressure and temperature increases, cross-disciplinary teams will conduct walk downs and inspections in accordance with the Plant Heatup Procedure. RCS shall be heated as required by the pressure-temperature curve limits and pressurized to approximately 2,155 psig (Mode 3).

The RCS Leakage Test Procedure (DB-PF-03010), modified to include the additional required inspections, will be used to perform the system leakage test. The systems/components within the normal scope ofDB-PF-03010 will be inspected in accordance with ASME Section XI, Code, IWA-5000, Pressure Testing to satisfy the RCS leak test following each refueling outage. The leakage test will be performed with the insulation installed as allowed by the code. Insulation required to be removed to support inspections will be listed in the leak test procedures. The RCS will be maintained at normal operating pressure for up to seven days. Following the completion of all leakage inspections at this pressure, the plant will be cooled down and depressurized to Mode 5 to permit visual inspections of the reactor vessel head and reactor vessel bottom for leakage. This inspection will be performed using the Reactor Vessel Inspection Procedure (EN-DP-01500).

Any identified leakage shall be documented on a Condition Report and shall require resolution prior to ascending to Mode 2. The Engineering Assessment Board and the Senior Management Team shall review and concur with the evaluation and corrective actions associated with these Condition Reports prior to ascending to Mode 2.

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If evidence of boric acid leakage exists, photographs will be taken to document the "as found" condition of any observed leakage identified, including boric acid deposits on surrounding equipment. Where evidence of RCS leakage exists, the source of the leak and the leak path must be traced to ensure that there is no wastage of the RCS pressure boundary.

All identified leakage should be corrected. The goal of the RCS leakage tests is to have the lowest attainable RCS leakage. Leakage that is not corrected shall be evaluated for impact on surrounding systems and components in accordance with the following:

"* For non-RCS pressure boundary components, use NOP-ER-02001, Section 4.4, BACC Program.

"* For RCS Class 1 and Class 2 pressure boundary components, use ASME IWA-5250 and Code Case N-566-1 as approved by Relief Request Al0 The evaluations will be documented in a report and presented to the Engineering Assessment Board. After review and concurrence by the Engineering Assessment Board, the Senior Management Team will provide final concurrence, or may require additional repairs and leakage tests to be performed. This report will be sent to the Restart Overview Panel.

Depending on the extent and type of repairs required, additional leakage testing may be required. Following satisfactory completion of these leakage tests, any insulation removed to support the tests/inspections will be reinstalled.

Containment Leakage Rate Testing Following restoration of the temporary opening to permit movement of the replacement Reactor Pressure Vessel Head into containment, the Containment Pressure Vessel will be subjected to an integrated leakage rate test in accordance with 10CFR50, Appendix J (Type A test). (Ref. DB-PF-103 10)

During this integrated leakage test, while the containment pressure vessel is pressurized, the weld associated with the closure of the temporary opening in the pressure vessel will be visually inspected in accordance with ASME Section XI, IWA-5240. A VT-2 qualified inspector will perform this inspection. (Ref. DB-PF-00204 and DB-PF-03065)

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Evaluation of Post Maintenance and Post Modification Testing Proposed post-maintenance and post-modification testing shall be evaluated for selected systems by identifying systems and components affected by RCS leakage and boric acid deposits. A report will be generated that assesses the overall adequacy of planned test activities on the affected systems and components. The assessment report shall be reviewed by the Engineering Assessment Board. Additional testing may be scheduled if necessary to demonstrate that systems and components are capable of performing their intended functions. Any additional required testing will be added to the integrated schedule, including the required mode constraints and other system test considerations.

Integrated Restart Procedure An Integrated Restart Procedure shall be developed to control restart of the plant. This procedure shall include the identification of required tests and inspection activities necessary to ensure a safe and reliable return to service. This procedure is not intended to include routine surveillance testing.

This procedure shall include the sequencing and identification of restart activities that must be performed prior to ascension to the applicable mode. This will include restart items in the Davis-Besse Restart Database. The Integrated Restart Procedure shall include the necessary administrative hold points and management approvals required to be satisfied during plant heat-up through power operation. Operators will receive training on this procedure to ensure this infrequently performed test/evolution is conducted in a safe, controlled manner.

In addition to the normal procedure approvals, the Integrated Restart Procedure shall be reviewed by the Engineering Assessment Board and receive concurrence from the Senior Management Team.

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