ML031010240

Transmittal of Revision 6 of Davis-Besse Return to Service Plan, Revision 5 of Davis-Besse Restart Action Plan, Revison 5 of Davis-Besse Program Compliance Plan, & Revison 3 of Nuclear Operating Business Practice, Restart Readiness Review E

ML031010240
Person / Time
Site:	Davis Besse
Issue date:	04/06/2003
From:	Myers L FirstEnergy Nuclear Operating Co
To:	Dyer J NRC/RGN-III
References
1-1310
Download: ML031010240 (128)

Text

.%J FENOC ________

_ 5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 LewW. Abrs 419-321-7599 Chief Operating Officer Fax 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 April 6, 2003 Mr. James E. Dyer, Administrator United States Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351

Subject:

Transmittal of Revision 6 of the Davis-Besse Return to Service Plan, Revision 5 of the Davis-Besse Restart Action Plan, Revision 5 of Davis-Besse Program Compliance Plan, and Revision 3 of the Nuclear Operating Business Practice, Restart Readiness Review Extended Plant Outage (DBBP-VP-0002)

Dear Mr. Dyer:

On January 9, 2003 (Serial 1-1300), the FirstEnergy Nuclear Operating Company (FENOC) transmitted earlier revisions of Davis-Besse Return to Service Plan, Davis-Besse Restart Action Plan, and Davis-Besse Program Compliance Plan. The enclosed plans supercedes all previous revisions in their entirety. The revised plans continue to accomplish the original objectives and reflect the current revision of the Building Block Plans and development of implementing procedures. Additionally, the enclosed provides a copy of Revision 3 of the Nuclear Operating Business Practice DBBP-VP-0002, Restart Readiness Review Extended Plant Outage. This procedure provides the review process to ensure Davis-Besse's materiel condition, programs and processes, and organization, including the organization's safety culture are ready for plant restart and safe, reliable operation.

No commitments are identified in the enclosures. Also, it should be noted that FirstEnergy Nuclear Operating Company may periodically update these documents in the future, as necessary.

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

McCloskey, Manager - Regulatory Affairs, at (419) 321-8450.

Sincerely yours, GB/GH Enclosures AC)

Attachment

Docket Number 50-346 License Number NPF-3 Serial Number 1-13 10 Page 2 cc: USNRC Document Control Desk J. B. Hopkins, DB-1 NRCJNRR Senior Project Manager C. S. Thomas, DB-1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 Enclosure Revision 6 of the Davis-Besse Return to Service Plan

DAVIS-BESSE RETURN TO SERVICE PLAN Revision: 6 Date: March 31,2003 I Approvals:

L. W. Myers, OC Chief Operating Officer

Table of Contents Summary of Revision Changes ....................... 2

1. Introduction and Purpose .. 3 II. Restart Organization .. 4 III. Nuclear Quality Assessment Oversight .. 5 IV. Building Blocks .. 5 A. Reactor Head Resolution Plan .6 B. Containment Health Assurance Plan .8 C. System Health Assurance Plan .9 D. Program Compliance Plan .1 E. Management and Human Performance Excellence Plan .12 F. Restart Test Plan .14 G. Restart Action Plan .14 V. Confirmatory Action Letter Status .. 17 VI. Conclusions .. 20 Figures:

1. Davis-Besse Restart Building Blocks .21

2. Restart Organization .22 Appendix:

1. Correlation of Causal Factors versus Restart Building Blocks .23 l Page 1 of 26 Revision 6 March 31, 2003

Summary of Revision Changes Revision 6:

Section IV. Revised the System Health Assurance Building Block Owner from Joseph W. Rogers to Richard G. Mende.

Item B: Containment Health Assurance Plan Changes were made to the Charter and Description of this plan to reflect the changes made to Revision 6 of this Building Block Plan.

Item D: Program Compliance Plan Changes were made to the Charter portion of this section to match the wording in Revision 5 of this Building Block Plan.

Item E: Management and Human Performance Excellence Plan Changes were made to correct grammar and to match this Building Block Plan.

Item G: Restart Action Plan Changes were made to the Charter and Description of this plan to reflect the changes made to Revision 5 of this Building Block Plan.

Section V. Confirmatory Action Letter Status The Status of Items 1 and 4 of this section.

Figure 1: Davis-Besse Restart Building Blocks Changes were made to the owner of the System Health Assurance Plan.

Page 2 of 26 Revision 6 March 31, 2003 l

I. Introduction and Purpose 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 26 Revision 6 March 31, 2003 l

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.

II. 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 l) 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.

Page 4 of 26 Revision 6 March 31, 2003 l

III. Nuclear Oualitv Assessment Oversig-ht 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. Buildinj Blocks Each of the Building Blocks 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 Richard G. Mende James J. Powers I 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 26 Revision 6 March 31, 2003 l

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 I 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.

Page 6 of 26 Revision 6 March 31, 2003 l

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 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

/ Primary Water Stress Corrosion Cracking indications

/ Threaded and Bolted Connections

/ Fuel Reliability 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 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 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.

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.

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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 havc 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 ability to support the system risk significant functions, walkdowns, and reviews of Page 9 of 26 Revision 6 March 31, 2003 l

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 rcview 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 walkdowns being performed during the System Health Readiness Reviews and the Page 10 of 26 Revision 6 March 31, 2003 l

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. 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 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 We have identified the programs on Attachment I of the Program Compliance Building Block Plan to receive a Phase I or Phase 2 review described below. The programs receiving a Phase 2 review prior to restart that were 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 I 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.

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

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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.

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:

Management ineffectively implemented processes, and thus failed to detect and addressplant problems as opportunities arose.

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

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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 Page 13 of 26 Revision 6 March 31, 2003 l

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 thc Davis-Bcssc 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.

Restart Readiness Reviews are conducted prior to major plant evolutions in accordance with the Restart Readiness Review Extended Plant Outage Business Practice. This Business Practice includes detailed criteria for establishing the readiness of each Department or Section to support the specific restart activity. In addition, the Restart Readiness Review process performs an assessment of the safety culture of the Davis-Besse Organization using very specific criteria to allow Senior Management to monitor safety culture and determine what remedial actions must be taken for areas with unacceptable ratings.

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 Page 15 of 26 Revision 6 March 31, 2003 l

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.

Page 16 of 26 Revision 6 March 31, 2003 l

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. The area around Nozzle 3 was removed and shipped to the BWXT Laboratory in Lynchburg, VA for detailed analysis. A Root Cause Analysis Report was provided to the NRC on April 18, 2002 and a revised report was provided on September 23, 2002. Although the Root Cause Analysis Report is not expected to be revised, in order to support NRC research efforts as discussed 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, the material will be shipped to Argonne National Laboratory (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 17 of 26 Revision 6 March 31, 2003 i

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 an unused RPV Head from the Midland Plant in Michigan. NRC review of the unused head 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 used RPV Head will be transported off-site for disposal. CAL Issue No. 4 will remain open pending NRC review of successful completion of the reactor coolant system pressure test and control rod drive performance test.

Page 18 of 26 Revision 6 March 31, 2003 l

(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 I Return to Service Plan" to the NRC on September 23, 2002. 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 entering 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 19 of 26 Revision 6 March 31, 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 20 of 26 Revision 6 March 31, 2003 I

FIGURE 1 DAVIS-BESSE RESTART BUILDING BLOCKS Containment Health Restart Test Plan Management and Human System Health Assurance Reactor Ilea d Resolution Program Compliance Plan Assurance Plan Performance Excellence Plan Plan Plan Owner: T. Stallard Owner N Morrison Owner: T. Chambers Oversight: R. Fast Owner: R. Men4e Owner D B,iker Oversight: J. Powers Oversight B Schrauder Oversight. J Powers Oversight: R. Fast Owner: L Myers Desired Outcome - Return Oversight: NIA Desired Outcome - Identify to power with leaktiglt Desired Outcome - Identify Desired Outc onie - Ensure Desired Outcome - Ensure impacts of Boric Acid plant. Desired Outcome - Ensure and resolve safety system reactor head can perform applicable programs are in leakage into Containment Management and Human issues and ensure safety its safetvfunc ltion a condition to support the and ensure Containment is Performance issues are and reliability restart and safe operation ofDavis-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 ofRestart and Post-Restart

• Others Issues Program.

R~evision a Marrh 1.003 L~-_-, -,@--

n Page 21 of 26

FIGURE 2 Restart Organization Management &

Restart Action Human Plan Performance Excellence Plan

- Senior Management Team

- Restart Station Review Board March 31, 2003 I Page 22 of 26 Revision 6

APPENDIX I Page I of 4 CORRELATION OF CAUSAL FACTORS VERSUS RESTART BULDING BLOCKS Root and Contributing Causal Factor Building Block Action Less than adequate material selection. PWSCC of Reactor Head Resolution Plan Repair/Replace the RPV Head. (7.1.3, 7.1.4)

CRDM nozzle interface at the J-groove weld due to Program Compliance Plan Develop a plan to monitor CRDM leakage during material susceptibility in the presence of a suitable restart (7.1.1) environment resulted in: Containment Health Assurance Plan Review CRDM nozzle crack initiation/propagation

/ CRDM nozzle crack initiated against susceptibility (7.1.2)

/ CRDM nozzle crack propagation to through wall 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).

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

/ Plant returned to power with boron on the RPV Head after outages V Plant not identifying degradation of RPV Head base metal during 12RFO

/ Boric Acid Corrosion of the low-alloy steel RPV Head material (Root Cause: 5.1.2) Review of modification requests to identify Less than adequate Environmental conditions. Cramped System Health Assurance Plan 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)

/ 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.)

• Plant returned to power with boron on the RPV Head after outages

• Plant not identifying degradation of RPV Head base metal during 12RFO

/ Boric Acid Corrosion of the low-alloy steel RPV Head material.

(Contributing Cause: 5.2.1)

Revision 6 March 31, 2003 I Page 23 of 26

APPENDIX 1 Page 2 of 4 (novAD ATTJ CT NA T. FACTORS VERSUS RESTART BULDING BLOCKS

'AIn

%_Ij LqF I J LkktL Building Block SAction Root and Contributing Causal Factor testing. Corrective Restart Test Plan Inspect for any leaks (7.2.2)

Less than adequate maintenance and Maintenance did not promptly correct the problem with equipment condition (CRDM flange leakage) that resulted in:

V Plant not identifying the through wall crack/leak during System Health Assurance Plan Review of corrective maintenance, adequacy of PMs outages and CRs.

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: 5.2.2)

March 31, 2003 I Page 24 of 26 Revision 6

APPENDIX 1 Page 3 of 4 r'einrnI" ATTA1N% As AIRA T 1 FACTORS VERSUS RESTART BULDING BLOCKS

_nLtrlinuRnek

-_-u ContriutingvUusaageuULicii T I__

Root an Management Changes (8.i.p .a)

Less than adequate Nuclear Safety Focus (Root Lause: Managefomentc E u lllan9 hlan Management field presencelinvolvement to Performance Excellence Plan 6.1.1) improve management oversight montoa n Management Monitoring Process to moni nd tren oversight activities. (8.1.1.a)

Case Study T~raining (8. 1.1 .a)

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

_I I irrugTain

_. vilnnPPn" Detailed review of the Corrective Action Program Less than adequate implementation of the Corrective R_0111pllall%.U I J-11 (8.1.2)

Review of corretive action document evaluations to Action Program t-Management and Human (Root Cause: 6.1.2)

Performance Excellence Plan enforce higher standards for cause evaluations and effective corrective 'action (8. 1.2b)

I (Root -1Management and Human I Industry experience management review and establish Less than adequate analyses of safety implications the FENOC Hierarchy of Documents. (8.1.3)

Performance Excellence Plan Cause: 6.1.3)

_pltn__ nan Reinforce standards and expectations for procedure Less than adequate compliance with Boric Acid Program Cornpliance Plan compliance and the need for work practice rigor.

Corrosion Control (BACC) procedure and Inservice Test (8.1.4b)

Program process at Establish the FENOC Decision Making (Root Cause: 6.1.4) Establish the FENOC Decision Making process at Managemenit and Human Lack of Hazard Analyses. Davis-Besse including hazard analyses. (8.2.1 a)

Performance eExcellence Plan (Contributing Cause: 6.2.1) Detailed review of the Corrective Action Program Corrective Action Procedure Program Coimpliance Plan (8.2.2b)

(Contributing Cause: 6.2.2)

March 31, 2003 I Page 25 of 26 Revision 6

APPENDIX 1 Page 4 of 4 CORRELATION OF CAUSAL FACTORS VERSUS RESTART BULDING BLOCKS l-- DUUUIII D- I. -- it.--A Reactor Head Resolutivf rln Ifii t- n n_^AffTmeDeni_ I Ingnpect Thr ann leaks.

Restart lest raw l.

Reactor Head Resolution Plan Replace the head.

Boric acid corrosion of RPV Head (3.1.2)

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

Program Compliance Plan Review of Boric Acid and ISI Programs.

Boric acid corrosion control program (5.1)

Restart Test Plan Inspect for any leaks.

Reactor Coolant System leakage detection Program Compliance Plan Develop leak detection program (5.2)

Containment Health Assurance Plan Inspections in the Containment for other SSCs that Boric acid in Containment Air Coolers (5.3) may be affected by boric acid.

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

System Health Assurance Plan Review of modification requests to identify Delay of Modification of Service Structure (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.)

Restart Test Plan Inspect for any leaks.

Delay of Repair of CRDM Flange Leakage (5.2.2) ___

Revision 6 March 31, 2003 I Page 26 of 26

Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 Enclosure Revision 5 of the Davis-Besse Restart Action Plan

Davis-Besse Restart Action Plan Revision: 5 Date: March31, 2003 17*

er: C. A. Price Rec or Approval Senior Management Team Chairman: L. W. Myers Ap o y: L. W. Myers

Table of Contents Title Pare Summary 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 IMC 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 5 March 31, 2003 I

Summary of Revision Changes Revision 5 Deleted references to Restart Closure Summaries to be consistent with NG-VP-00100, Restart Action Plan Process. Closure documentation is provided solely by Action Item Closure Documents.

Add a description of the Restart Readiness Review Process, Extended Plant Outage Business Practice (DBBP-VP-0002).

Deleted the review of open Procedure Change Requests as a responsibility of the Restart Station Review Board.

Revised the general outline of the Integrated Restart Report to increase the flexibility of the report style, content and format.

Page 2 of 23 Revision 5 March 31, 2003 l

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 (IMC) 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.

Restart Readiness Reviews are conducted prior to major plant evolutions in accordance with the Restart Readiness Review Extended Plant Outage Business Practice. This Business Practice includes detailed criteria for establishing the readiness of each Department or Section to support the specific restart activity. In addition, the Restart Readiness Review process performs an assessment of the safety culture of the Davis-Besse Organization using very specific criteria to allow Senior Management to monitor safety culture and determine what remedial actions must be taken for areas with unacceptable ratings.

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.

Page 3 of 23 Revision 5 March 31, 2003 l

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.

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.

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.

Page 4 of 23 Revision 5 March 31, 2003 I

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 Readiness Reviews: A review process to ensure that Davis-Besse's materiel condition, programs and processes, and organization, including the organization's safety culture are ready for plant restart and safe, reliable operation. These reviews are conducted in accordance with DBBP-VP-0002, Restart Readiness Review Extended Plant Outage Business Practice.

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 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 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 5 March 31, 2003 l

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 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 5 March 31, 2003 l

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 closure packages to demonstrate to the NRC that restart items have been properly completed.

Page 7 of 23 Revision 5 March 31, 2003 l

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 1MC 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 1MC 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.

Responsibilities 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.

Page 8 of 23 Revision 5 March 31, 2003 l

• 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 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 Team and Restart Overview Panel.

• 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.

Page 9 of 23 Revision 5 Page 9 of 23March3,2003

• 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.

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 l 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 Work Orders and pending modifications for determination of restart activities.

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

The 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 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 [MC 0350 Restart List.

Page 10 of 23 Revision 5 March 31, 2003 l

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.

• Providing oversight and direction to the Senior Management Team.

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

Manaeement 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 Team.

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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 Action Item Closure Documents for items on the Davis-Besse IMC 0350 Restart List. The flow chart of the Restart Action Plan Process is shown in Figure 3.

The Restart Action Database tracks the status of items on the Davis-Besse Restart Action List and the Davis-Besse [MC 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.

The Building Block Teams generate action plans to evaluate either in-plant inspections of 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.

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

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

Page 12 of 23 Revision 5 March31,2003 l

NRC Inspection Interface Support for inspections by the NRC for the duration of the NRC IMC 0350 Reactor Oversight Process is coordinated by the Regulatory Interface Team. The Regulatory Interface Team assesses inspection activities as they are defined by the NRC Oversight Panel. Baseline inspections performed by the NRC may be assigned to the Compliance Unit to monitor, facilitate, and coordinate the inspection. Inspections related to Davis-Besse Return to Service activities and actions are coordinated by the Regulatory Interface Team. Larger team inspections 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 the inspection.

An Inspection Team Lead is assigned for each inspection. The lead coordinates all aspects of the 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 reference materials provided to the NRC, and logs Condition Reports generated during the inspection.

IMC 0350 Restart List Closure Process Closure packages are developed for restart items on the Davis-Besse IMC 0350 Restart List.

Closure packages include the necessary documentation to provide evidence that restart corrective actions have been satisfactorily completed. Closure packages are independently reviewed by the Validation Team and approved by the Building Block Owners or Responsible Director and then sent to the FENOC Chief Operation Officer for final concurrence, signifying that the restart item is ready for NRC Inspection.

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

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

Validation of Closure Packanes 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 Action Item Closure Documents. 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.

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Once approved, 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.

Restart Readiness Reviews Restart Readiness Reviews are conducted prior to major plant evolutions in accordance with the Restart Readiness Review Extended Plant Outage Business Practice. This Business Practice includes detailed criteria for establishing the readiness of each Department or Section to support the specific restart activity. In addition, the Restart Readiness Review process performs an assessment of the safety culture of the Davis-Besse Organization using very specific criteria to allow Senior Management to monitor safety culture and determine what remedial actions must be taken for areas with unacceptable ratings.

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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:

> Purpose of the Integrated Restart Report.

> 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.

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

> Summary of 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.

> Summary of the results of the Technical Root Cause Analyses Report, findings and corrective and preventative actions.

> Summary of corrective and preventive actions for root causes including:

• 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.

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

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• 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.

These summarizes 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, and demonstrate that the condition of the plant, programs, and organization are acceptable to support restart.

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

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Figure 1: Restart Organization Restart Overview Panel I

l Vice President -

Executive Vice Chief Operating Officer , - Oversight President - Engineering and Services - Independent Oversight V -

I Vice President - DB

. 4 Engineering Assessment Board r;

I-----------I --------------- r--------

I I

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rI ----------------------------

I I

I I

I J. _____________________________ 4 II I-"r I I I 1i- I I Management &

Program Containment Restart Test Reactor Head Restart Action Human System Health Compliance Health Plan Resolution Plan Plan Performance Assurance Plan Plan Assurance Plan Excellence Plan I

- Senior Management Team

- Restart Station Review Board Page 17 of 23 Revision 5 March 31, 2003 I

Figure 2: Restart Action Plan Team Oversight: Lew W. Myers Manager Owner: Clark A. Price Regulatory Affairs Restart Staton Senior Management Return To Service Validation Team Regulatory Interface Restart Team Action Process Review Board Team Plan Administrator Administrator Revision 5 March 31, 2003 I Page 18 of 23

Figure 3 Davis-Besse Restart Action Plan Process 1i1,I I__

___I __ __ _

"Scov" N~am Restart Sffen""

Da-Bsse Plant Stff Badng Sock Owners Restavt Station Review Board Reart Action Plan Team Regulatry Cvnenix Enginesig As mn Board Restart 9ation Review Board Interface Team Restmt Overview Panel (for TeaM Validation Team Resart Managerrent and Human Ndr~nc Excellence)

Mxaamen t paneq Team Page 19 of 23 Revision 5 March 31, 2003 I

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.

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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.)

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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 5 March 31, 2003 l

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 trackdng 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 5 March 31, 2003 l

Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 Enclosure Revision 5 of the Davis-Besse Program Compliance Plan

Davis-Besse Program Compliance Plan Revision: 5 Date: 3/31 2003 Owner: e11 A. Morrison Oversight: Jim Powers Recornmendd 1r Approval RSMT Chairman App Le W. Myers

Table of Contents Title Page Summary of Revision Changes ................................................. 2 Executive Summary ................................................. 3 Program Compliance Plan Charter ............................. 4...................4 Program Compliance Organization Chart ................................................. 5 Plan Description Phase 1: Program Readiness Baseline Assessments ...... 6 Plan Description Phase 2: Program Detailed Reviews .............................. 8 Attachment I Plant Programs to be Reviewed ........................................ 12 Page I of 14 Revision 5 March 25, 2003

Summary of Revision Changes Revision 5: The changes in Revision 5 include the discussion of the newly implemented procedure NG-EN-00386 (Program Assessment, Ownership, and Development)

Revision 0 for performing detailed program reviews at Davis-Besse. This procedure discusses the ongoing program review process, subsequent to restart from 13RFO. This procedure will assure that programs are selected for detail review and reviews are conducted on a periodic basis, commensurate with plant performance (e.g., results of QA Audits, Industry Experience, Regulatory Performance). The selection of the programs for review are included in Attachment 1 and normally, three programs will be assessed per year. The change in the scope of the ongoing process and schedule is also reflected in this revision.

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 5 March 25, 2003

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 1 or Phase 2 review described below. The programs receiving a Phase 2 review prior to restart that were 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 as discussed below.

Phase 1- Proaram 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 Proeram 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 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.

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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 5 March 25, 2003

Program Compliance Organization Chart Davis-Besse Program Compliance Plan Owner (Morrison)

Davis-Besse Liaison Progra am Review (McAllister)

BoaiAdreview (Phase I Recadiness Baseline Assessmre nts and Phase 2 Detailed Review Teams Dctailed RiD.-vw Qumiairy RrRports) ,

I Independent Program Owner Technical from other Reviewer FENOC facilities (as needed) (part time)

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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 6 of 14 Revision 5 March 25, 2003

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 using a comprehensive review process discussed in NG-EN-00386 "Program Assessments, Ownership, and Development" following restart and completion of the program development.

Additional programs may be designated for a Phase I Review based on the recommendation of the Program Compliance Plan Oversight to the Davis-Besse Senior Management.

Methodologv for Phase 1 - Proeram 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-Proaram 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.

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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.

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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.

Comprehensive reviews, selected from the programs listed in Attachment I, will be conducted as an ongoing effort as discussed in NG-EN-00386 "Program Assessment, Ownership, and Development".

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 5 March 25, 2003

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. Determnine 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 IO of 14 Revision 5 March 25, 2003

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 I11 of 14 Revision 5 March 25, 2003

I Attachment 1 Existing Programs to Receive Phase 1.

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 Primary Water Chemistry Monitoring & Control Program Procurement Program Page 12 of 14 Revision 5 March 25, 2003

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 Pro2rams 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 5 March 25, 2003

Programs Identified to be Developed I 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 5 March 25, 2003

Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 Enclosure Revision 3 of the Nuclear Operating Business Practice Restart Readiness Review Extended Plant Outage (DBBP-VP-0002)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____ ___ ___ ____ ____ ___ ____ ___ ____ ___D B B P-V P-0002 Tite. Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 1 of 55 RESTART READINESS REVIEW EXTENDED PLANT OUTAGE Approve 2  ? &

Effective Date APR -. 2 2003

NUCLEAR OPERATING BUSINESS PRACTICE Number.

DBBP-VP-0002 Tite: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 2 of 55 TABLE OF CONTENTS Page 1.0 PURPOSE ............. 3 2.0 APPLICABILITY ............. 3 3.0 RESPONSIBILITY ............. 3 4.0 DETAILS ............. 4 ATTACHMENT 1: RESTART READINESS REVIEW INDICATORS ..................... 7 ATTACHMENT 2: PLANT RESTART READINESS REVIEW INDICATOR MATRIX ........................................ 9 ATTACHMENT 3: RESTART READINESS REVIEW FOR PLANT SHUTDOWN ....................................... 12 ATTACHMENT 4: PLANT INSPECTION DOCUMENTATION SHEET .................. 13 ATTACHMENT 5: OPERATIONAL READINESS AFFIRMATION FORM .............. 14 ATTACHMENT 6: CORE CONFIGURATION AFFIRMATION FORM ................... 15 ATTACHMENT 7: REACTOR STARTUP AFFIRMATION FORM ......................... 16 ATTACHMENT 8: ASSESSMENT OF SAFETY CULTURE .................................. 17 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA ................ 19

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tide: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 3 of 55 1.0 PURPOSE The purpose of this Business Practice is to provide assurance that the Davis-Besse Nuclear Power Station is ready to restart following the extended plant outage. The framework detailed here establishes a review process for areas not addressed by the Restart Test Plan and DB startup procedures to ensure that Davis-Besse's materiel condition, programs and processes, and organization, including the organization's safety culture are ready for plant restart and safe, reliable operation.

2.0 APPLICABILITY This Business Practice applies to the first plant startup following this extended plant outage. It also applies to subsequent startups from this same outage and therefore shall be re-performed if the startup is halted resulting in an entry into a lower mode.

Adherence to this Business Practice is mandatory.

3.0 RESPONSIBILITY The Beaver Valley Vice President-Nuclear is responsible for initiating the Restart Readiness Review Process.

Each Section Manager and 0350 Restart List Responsible Individual is responsible for the accuracy and adequacy of the reviews performed, actions taken and action plans developed during the review process.

The Section Managers of Plant Engineering, Operations and Maintenance are responsible for ensuring plant walk-down inspections are conducted prior to power ascension.

The Manager-Operations is responsible for affirming: 1) the Operations Section has completed a review of operational readiness and is ready to support the safe and reliable startup and operation of the plant through the next operating cycle; 2) that the plant is in a condition of materiel readiness to support safe and reliable startup and operation and the operating crews are prepared and ready to startup and operate the plant in a safe and reliable manner through the next operating cycle.

The Supervisor-DB Reactor Engineering is responsible for: 1) following movement of fuel in the reactor core, changes to reactivity control components in the reactor core and/or changes to nuclear instrumentation in the reactor core, verifying that the reactor core is configured to support safe and reliable operation through the cycle.

This affirmation is required prior to installation of the reactor head; 2) prior to reactor startup, verifying that the required conditions exist to support a safe startup and power ascension.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____________________________________DBB P-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 l Page 4 of 55 Each Director is responsible for the final review of the assessment and action plans developed during the review process by the sections in his department.

The Vice President-Nuclear is responsible for final approval prior to plant restart.

4.0 DETAILS

1. The review process shall be initiated early enough to ensure it is completed prior to entry into Modes 6, 4 and 2. The review shall be completed by the milestone date as determined by the responsible Shift Outage Director. All Sections and 0350 Checklist Responsible Individuals, shall submit restart readiness reviews by the milestone dates; not all items have to be complete, provided bullet (4) in Step 3 is appropriately addressed.

2. The process consists of the review and assessment of the specified Restart Readiness Review Indicators. The matrix on Attachment 2 designates the minimum indicators from Attachment 1 that are applicable to each Section and/or 0350 Checklist Item. Each Section and 0350 Checklist Responsible Individual, shall address applicable indicators and should participate in the review and assessment of any indicator for which meaningful input can be provided.

3. The methodology for the review process consists of the following steps:

• Monitor plant system/component work activity progress during the outage

• Monitor emergent work/issues during the outage for shutdown concerns

• Monitor personnel and administrative issues during the outage for restart concerns

• Assess Restart Readiness Review Indicators as identified on Attachment 1, as applicable per Attachment 2.

• Assess Safety Culture as identified on Attachment 8, Page 18

• Identify items to be complete prior to the designated Mode (6, 4 or 2) that have not been completed as of the Shift Outage Director milestone date.

Ensure a reference is associated with each incomplete item that addresses completion of that item before needed in that mode.

4. Results of the individual indicator assessments, including the status of action plans to support plant restart, will be indicated on Attachment 1, and acknowledged by the signature of the Section Manager or 0350 Checklist Responsible Individual. Indicator assessments should be marked as Final (all conditions are acceptable to support plant restart) or Preliminary (one or more indicators are not currently complete or acceptable and action plans will support

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tite: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 5 of 55 plant restart when complete). Details on incomplete items and the status of action plans to eliminate them shall be attached.

5. Restart Readiness Review Indicators (Attachment 1) should be provided to the Restart Action Process Administrator at least two days prior to the meeting.

6. Restart Readiness Review Indicators shall be reviewed by the Senior Management Team and approved by the Vice President-Nuclear or Chief Operating Officer, as provided on Attachment 3.

7. Completed Attachments 1 and 3 shall be included with the documentation package assembled in accordance with this Business Practice.

8. Walk down inspections shall be completed prior to power ascension as described in this document and in accordance with EN-DP-01 503, System Walkdowns and Plant Engineering Policy PE-02, System Walkdown Checklist. Results of walkdown inspections shall be documented in Attachment 4 and submitted to the on-shift Engineering Manager.

9. The Shift Manager of each crew should:

a. Conduct reasonable and appropriate activities to accomplish the objective of attaining, demonstrating and affirming operational readiness. The Shift Manager should consider the following to support the affirmation of operating crew readiness:

-adequacy of staffing levels, personnel experience and qualification levels.

-assure no uneasiness remains among Operations personnel regarding the Station's ability to operate safely by eliciting any outstanding safety concerns from shift personnel and ensuring that the concerns are resolved.

-completion of appropriate personnel refresher training of shift personnel, including training on plant, procedures and process changes.

-completion of training of shift personnel on the startup and power ascension plan. This training shall include discussion on the expected behavior and characteristics of the core for this startup.

b. Affirm to the best of their knowledge and judgment that the plant is in a condition of materiel readiness to support safe and reliable startup and operation. The Shift Manager should consider the following:

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TMte: Revsion: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 6 of 55

-adequacy of the materiel condition of the plant, including the current status of operator work-arounds, to support safe and reliable restart and operation during the next operating cycle.

-all outage-related temporary fire suppression systems removed and fire protection requirements or commitments ready to support startup.

-temporary modifications, temporary power feeds, removed/MCCs restored, installed temporary power feeds, if applicable, reviewed to ensure they will not affect safety or operations.

c. Complete Attachment 5.

10. The Supervisor-DB Reactor Engineering shall, following movement of fuel, changes to reactivity control components and/or changes to nuclear instrumentation in the reactor core, verify that the reactor core is configured to support safe and reliable operation through the cycle. This affirmation is required prior to installation of the reactor head. Attachment 6, Core Configuration Affirmation Form, details the required review areas and documents the affirmation.

11. The Supervisor-DB Reactor Engineering, shall, prior to a reactor startup, verify that the required conditions exist to support a safe startup and power ascension.

Attachment 7, Reactor Startup Affirmation Form, details the required review areas and documents that affirmation.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

___________________________________DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 7 of 55 ATTACHMENT 1: RESTART READINESS REVIEW INDICATORS Page 1 of 2 Plant Section or 0350 Checklist Item Acceptable to Support Mode_ Restart?

Yes/No/NA 1 All assigned outage work activities are complete to support plant restart and operations. This includes a reconfirmation that previous dispositions of nonconforming conditions or Preventive Maintenance deferrals continue to provide a justification for continued operation. (Attachment 2-a) 2 Outstanding Operability Evaluations, CR corrective actions and new CRs generated during the shutdown have been evaluated for operability concerns are either closed or determined to have no impact on operability. (Attachment 2-b) 3 Regulatory and internal commitments have been evaluated for operability concerns or restart restraints and are either closed or determined to have no impact on operability. (Attachment 2-c) 4 Housekeeping walkdowns utilizing the guidelines of NG-DB-00215, Material Readiness and Housekeeping Inspection Program are complete. (Attachment 2-d) 5 The Power Ascension Schedule has been reviewed for accuracy and adequacy ensuring: (Attachment 2-e)

• Post maintenance retest and special testing are identified and scheduled correctly with instructions in place.

• Planned walkdowns are scheduled appropriately 6 Personnel, materials and special test equipment necessary to support power ascension retest and walkdown activities have been identified and availability is ensured during power ascension. (Attachment 2-f) 7 Contingency plans are established for immediate response to plan and repair steam leaks or high-risk test failures. (Attachment 2-g) 8 Standing orders have been reviewed for continued applicability and system status sheets completed as required by DB-OP-0691 1, Pre-Startup Checklist. (Attachment 2-h) 9 System walkdowns have been performed by Plant Engineering and Maintenance, as directed by Operations, to ensure system readiness for restart.

10 Operating Experience reports have been reviewed to ensure no potential operability concerns 11 Procedure alterations/PCRs are ready for mode change or restart.

12 Work around and burdens identified prior to or during shutdown and not corrected have been confirmed acceptable. (Attachment 2-i)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 8 of 55 ATTACHMENT 1: RESTART READINESS REVIEW INDICATORS (Continued)

Page 2 of 2 Acceptable Plant Section or 0350 Checklist Item to Support Restart?

Mode Yes/No/NA 13 All Management and Human Performance Improvement Plan items required for restart are complete. (Attachment 2-j) 14 All 0350 Discovery Action Plan milestones identified as required for restart are complete. (Attachment 2-k) 15 All 0350 Implementation Action Plan milestones identified as required for restart are complete. (Attachment 2-1) 16 All Condition Reports and corrective actions, work orders, modifications (including EWRs and ECRs) categorized as 0350 are completed. (Attachment 2-m, n, o) 17 All Condition Reports and corrective actions, work orders, and modifications (including EWRs and ECRs) designated as required for restart by the Restart Station Review Board are completed. (Attachment 2-q, r, s) 18 Any required for restart Condition Report or corrective action, work order or modification (including EWRs and ECRs), which cannot be completed prior to restart, has a written exemption from the RSRB. (Attachment 2-u) 19 All pending allegations have been reviewed and determined not to affect the restart of the plant. (Attachment 2-v) 20 Integrated Restart Report per NG-VP-00100 signed by the SMT. (Attachment 2-w)

Check one Preliminary: I have reviewed the assessment of the Restart Readiness Review Indicators as indicated above and confirm that the attached plans will support plant restart when complete.

Final: I have reviewed the assessment of the Restart Readiness Review Indicators as indicated above and concur that the current conditions support plant restart.

Section Manager or 0350 Checklist Individual (Please Print Your Name)

Signature: Date Section Manager or 0350 Checklist Individual

NUCLEAR OPERATING BUSINESS PRACTICE Number.

____ ___ ___ ___ ____ ____ ___ ____ ___ ___D BB P-V P-0002 TiUe: Revision. Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 9 of 55 ATTACHMENT 2: PLANT RESTART READINESS REVIEW INDICATOR MATRIX Page 1 of 3 0 a)

CL On E L9, C)Cf E

e C .cm . G oA E 2-U) E 0 _ E><

0 0a))0 Ola Plantn Operations X X X X X X X X X X RP X X X X X X X X Chemistry X X X X X X X Training X . X X Safety X . X X X Work Management FIN X X X X X Mechanical X X X X X X E&C X X X X X X Maint. Serv. X X X X X QC and Work Mgmt X X X X X Assessment Work Control X X . X X X Outage Management X X X X X X Projects and Facilities X X X X X X Engineering Plant Engineering X X X X X X X X Design Engineering X X X X X Project Management X X X X X RRT X X X X Computer X X X Support Services Performance X X X Improvement Regulatory Affairs X X X X X X Quality Services X X Security =- X X Other Departments OPID/QA X X X X X X Nuclear Fuels X X X X X X X Supply Chain X X X Client Services X X Business Services X X Human Resources X X

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tile: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 10 of 55 ATTACHMENT 2: PLANT RESTART READINESS REVIEW INDICATOR MATRIX Page 2 of 3 0350 CHECKLIST ITEM RESTART READINESS REVIEW INDICATOR MATRIX C

S WM0 UCU .CD 0 0 OW a c~j o ,,

J. Esela Poer D. L .

0350 Checklist Item ___

Systems and aeA CoDnns-D

1. Adequacy of Root Cause Determinations- X X X X S. Loehlein, W. Pearce, M. J.RoesJ Chmbrs Roder, D. Gudger, Ctlld C.

J. Powers, D. Eshelman, L. Myers* R. _____

2. Adequacy of Safety Significant Structures, X X X X X Systems and Components--D. Baker, A.

Stallard, T. Chambers, J. Rogers, J.

CunninPs*

3. Adequacy of Safety Significant Programs-N. X X X Morrison, D. Gudger, S. Loehlein, J.

Cunnings,_M._Shepherd,_J. GrabnaroR. Pel*

4. Adequacy of Organizational Effectiveness X X X X X and Human Performance--D. Eshelman, J.

Powers* ____

5. Readiness for Restart-C. Price, W. Pearce, X X J. Rogers, R. Schrauder, A. Stallard*

6. Licensing Issue Resolution-J. Powers, P. X X McCloskey*

7. Confirmatory Action Letter Resolution-L. X Myers, P. McCloskey*

• Or an approved designated alternate

NUCLEAR OPERATING BUSINESS PRACTICE Number DBBP-VP-0002 Tile: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 11 of 55 ATTACHMENT 2: PLANT RESTART READINESS REVIEW INDICATOR MATRIX Page 3 of 3 REQUIRED FOR RESTART READINESS REVIEW INDICATOR MATRIX CO co 0 to

.S i X aa)

Epy C) CD 9o c C EkEn e.-'O t E ~ 0<O E

1 a) WC V0 x Cu A= E) co rrcoua C. a)a a) a) 0 Cl) 0) x 0 Restart Station Review X X X X Committee ___

Company Nuclear Review X Board Restart Overview Panel X

NUCLEAR OPERATING BUSINESS PRACTICE NumberB

__________________________________DBBP-VP-0002 MTe: Revision Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 12 of 55 ATTACHMENT 3: RESTART READINESS REVIEW FOR PLANT STARTUP Restart Recommended By:

Plant Manager-Davis-Besse Nuclear Power Station Date Director-Davis-Besse Nuclear Engineering Date Director-Davis-Besse Work Management Date Director-Davis-Besse Support Services Date RESTART APPROVAL:

Vice President-Nuclear Date Chief Operating Officer Date

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TiUe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 13 of 55 ATTACHMENT 4: PLANT INSPECTIONIWALKDOWN DOCUMENTATION SHEET Page 1 of 1 ASSET LABEL:

Or AREA INSPECTED:

NOUN NAME:

LOCATION:

DESCRIPTION:

MAINTENANCE TAGIWORK ORDER #:

CONDITION REPORT INITIATED (#)_

SUBMITTED BY: DATE/TIME I (please print your name)

SIGNATURE:

NUCLEAR OPERATING BUSINESS PRACTICE Number.

____ ___ ___ ___ ____ ____ ___ ____ ___ ___D BB P-V P-0002

Title:

Revision. Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 14 ofS55 ATTACHMENT 5: OPERATIONAL READINESS AFFIRMATION FORM Shift Designator:

Shift Manager:

(Please Print)

Mode_

Review Summary:

The Shift Manager should initial each item below to affirm that he/she and the operating crew have completed the required actions:

Shift staffing levels, including personnel experience and qualification levels, are adequate.

No uneasiness remains among Operations personnel regarding the station's ability to operate safely. All safety concerns have been identified and addressed.

Appropriate refresher training of shift personnel, including training on plant, procedure and process changes, has been completed.

Appropriate training of shift personnel on the startup and power ascension plan, have been completed, including discussions on core behavior and characteristics for this startup.

The materiel condition of the plant, including the current status of operator work-arounds, is adequate to support safe and reliable restart and operation.

Affirmation:

Based upon an evaluation of the considerations set forth in Details, 4.0, and to the best of my knowledge and judgment, the plant is in a condition of materiel readiness to support the safe and reliable startup and power operation through the next operating cycle and the operating crew is ready to startup and operate the plant in a safe and reliable manner.

Shift Manager:

PrintlSignature/Date l l Reviews and Approvals:

Manager-Operations:

Print/Sianature/Date l l Remarks: (Attach a continuation sheet if applicable)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TiUe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 15 of 55 ATTACHMENT 6: CORE CONFIGURATION AFFIRMATION FORM Mode Review Summary:

The Supervisor-DB Reactor Engineering, should initial each item below to affirm that the required conditions exist following movement of fuel in the reactorcore, changes to reactivity control components and/orchanges to nuclearinstrumentationin the reactorcore. This affirmation is requiredpriorto installationof the reactorhead.

All new fuel assemblies loaded into the reactor core were inspected, as required, to ensure that the manufacturing and design specifications were met.

All irradiated fuel assemblies present in the reactor core were inspected, as required, and dispositioned as acceptable for operation through the cycle.

No fuel assemblies in the reactor core are known leaking assemblies.

A 10CFR50.59 Reload Safety Evaluation governing reactor core operation has been approved by the Plant Operating Review Committee (PORC)

The reactor core loading has been verified.

All reactivity control components in the reactor core will meet their design functions.

All nuclear instrumentation in the reactor core will meet their design functions.

Affirmation:

Based on my knowledge andjudgment, the requiredconditions exist and the reactorcore is configured to support safe and reliable operation through the cycle.

Supervisor-DB Reactor Engineering Print/Signature/Date Remarks: (Attach a continuation sheet if appropriate)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Title. Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 16 of 55 ATTACHMENT 7: REACTOR STARTUP AFFIRMATION FORM Mode_

Review Summary:

The Supervisor-DB Reactor Engineeringshould initial each item below to affirm that the requiredconditions exist prior to reactorstartup.

Estimated Critical Conditions have been prepared and independently verified.

Preparations are complete for any necessary Low Power Physics Testing (i.e. equipment, procedures, calculations, training)

Personnel are available, as required, to support reactor startup and power ascension to 100%.

Required training has been completed for Nuclear Fuels personnel.

Reactivity plans are available, as required, to support reactor startup and power ascension to 100%. These plans include expectations for reactor behavior with emphasis on any behavior that is different from recent plant operation.

The Core Monitoring System is operable.

All reactivity control systems will meet their design functions.

Sufficient nuclear instrumentation is available to safely startup and operate the reactor core.

There are no outstanding reactivity management issues impacting the safe operation of the reactor core.

Affirmation:

Based on my knowledge andjudgment, the required conditions exist and the reactorcore is ready to support a safe startupand power ascension.

Supervisor-DB Reactor Engineering PrintlSignature/Date Remarks: (Attach a continuation sheet if appropriate)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TlUe: Remsion: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 17 of 55 ATTACHMENT 8: ASSESSMENT OF SAFETY CULTURE Page 1 of 2 ASSESSMENT OF SAFETY CULTURE Assessment Summary:

Improving safety culture is a long-term activity that will be constantly monitored by Davis-Besse senior management. For Restart Readiness, it is important to show an improving safety culture, however not every assessed area must be white or green to ensure an adequate safety culture. Some areas may be yellow, however none of the three major areas (Policy or Corporate Commitment, Plant Management Commitment or Individual Commitment) will be red.

Remedial actions will be taken for any red indicators. Condition Reports will be written for all red and yellow indicators with corrective actions to identify an existing or new plan for improvement. Corrective Actions may take credit for already existing activities. Red indicator corrective actions will be formally presented to the Senior Management Team.

The criterion for ratings follows in Appendix A. These criteria are guidelines. Management may consider other factors and adjust the ratings accordingly. If other factors are considered, they shall be documented in an attachment to the Rating sheet. The ratings are based on convergent assessment such as: performance indicators, management observations, demonstrated performance during critical plant conditions ad hoc surveys, training and feedback from independent safety culture reviews and Nuclear Quality Assurance Assessments.

Safety Culture Commitment Area Ratings:

Green: all major areas are acceptable with a few minor indicator deviations White: all major areas are acceptable with a few indicators requiring management attention Yellow: all major areas are acceptable with several indicators requiring prompt management action Red: several major areas do not meet acceptable standards and require immediate management action Each Section manager will provide a Rating sheet (Attachment 8, Page 18,) with the Final Restart Readiness Indicators. At the final Restart Readiness Review meeting for any mode, a site-wide Rating sheet will be prepared by the Management Team using the individual section ratings as a guideline.

The final Rating sheet will be signed by the Vice President-Nuclear and maintained with the other Restart Readiness documentation.

Determination of the individual indicator or the commitment area color will be based on the following:

Red=0 points Greater than one red attribute or indicator means the indicator or commitment area can be no more than yellow 3 Yellow=1 point Rd<7 White=2 points Red=<.75 White=23 points Yellow= >.75 to <1.75 Green= 3 points White =>1.75 to <2.5 Green= >2.5

NUCLEAR OPERATING BUSINESS PRACTICE Number

___ _______ ___ ___ ___ ___ ___D B B P-V P-0002 TiWe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 18 of55 ATTACHMENT 8: ASSESSMENT OF SAFETY CULTURE Page 2 of 2 Rating Safety Culture Mode_

Item Color

1. Policy or Corporate Commitment Area

a. Policies on Safety Culture and Safety Conscious Work Environment clearly state that safety is a core value and are understood by the organization

b. Management values are clearly reflected in the Business Plan and are understood by the organization

c. Resources are available or can be obtained to ensure safe, reliable operations

d. Self-Assessment is a tool used to monitor, assess and improve our performance

e. Independent Oversight is a tool used to validate acceptable performance and identify areas for improvement or corrective action

2. Plant Management Commitment Area

a. There is a visible commitment to safety: nuclear, industrial, radiological and environmental

b. Goals and roles are clear and teamwork is reinforced

c. Ownership and accountability is evident

d. Training and Qualification are valued

e. Commitment to continuous improvement is evident

f. Cross functional work management and communication

g. Creating an environment of engagement and commitment

3. Individual Commitment Area

a. Drive for excellence-nuclear assets of people and plant are continuously improved to enhance margins of safety

b. Questioning attitude-challenges are welcomed

c. Rigorous work control and prudent approach-performing activities in a quality manner is the standard

d. Open communications-associates are comfortable in voicing opinions, issues and concerns

e. Nuclear Professionalism-persistence and urgency in identification and resolution of Problems is prevalent I have reviewed the Rating of Safety Culture as indicated above and concur that the current conditions I I support readiness for mode change.

Section Manager (Please Print Your Name)

Signature: Date_ _

Section Manager Adjustments to ratings from the standard criteria should be documented and attached to this page.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____ ____ ___ ____ ___ ___D B B P-V P-0002 Tite: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 19 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 1 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO STATEMENT OF SAFETY POLICY Policies on Safety Culture and Safety Conscious Work Environment clearly state that safety is a core value and are understood by the organization ATTRIBUTE RED YELLOW WHITE GREEN Policy There is no policy. Policy statement is Policy statement Policy statement is statement on issued but only issued and is issued and is Safety Culture occasionally frequently continuously reinforced reinforced by reinforced by by management.

management. management.

Policy There is no policy. Policy statement is Policy statement is Policy statement issued statement on issued but only issued and is and is strong statement Safety occasionally frequently of safety conscious Conscious reinforced by reinforced by work environment and Work management. management. often reinforced.

Environment (SCIWE)

Making Policy statements Policy statements Policy statements Policy statements are employees simply issued as distributed are communicated communicated to aware of policy part of FENOC separately to by at least two employees and statements Business Plan. employees in memo. means. (e.g., hard emphasized regularly in copy distribution, meetings and face to newsletters, group face communication.

meetings, training, stand down).

Employee Surveys/linterviews Surveys/linterviews Surveys/interviews Surveys/interviews understanding indicate that most indicate that more indicate that more indicate that more than ofpolicies employees do not than 50%of the than 75% of 90% of employees understand the employees employees understand the policies policies. understand the understand the and consider safety a policies and policies and FE value and the consider safety a FE consider safety a normal way to do value. FE value. business.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____ ____ ___ ____ ___ ___D BBP-V P-0002 Mlte: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 20 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 2 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO MANAGEMENT VALUES Management values are clearly reflected in the Business Plan and are understood by the organization ATTRIBUTE RED YELLOW WHITE GREEN Corporate values There is no There is a There is a corporate There is a corporate corporate level corporate level level statement of level statement of statement of statement of commitment to commitment to safety.

safety values. commitment to safety. FirstEnergy FirstEnergy FirstEnergy safety. management meets management meets management FirstEnergy occasionally with frequently with plant does not management plant personnel to personnel to express its express its meets express its safety safety values.

safety values to infrequently with values.

plant personnel. plant personnel to express its safety values.

Statement of There is no The statement of The statement of The statement of mission, vision, statement of Mission, Vision, Mission, Vision, and Mission, Vision, and and values Mission, Vision, and Values Values places Values emphasizes and Values and places some approximately equal safety over production employees weight on safety weight on safety and and profits.

believe focus is but greater production/profits.

on production weight on and profits. production or profits.

FENOC Business Business Plan Business Plan Business Plan Business Plan contains Plan contains no contains few contains Critical Critical Success Area Critical Success Critical Success Success Area Initiatives on safety and Area Initiatives Area Initiatives on Initiatives on safety all are being fully on safety. safety. with implementation implemented.

plans.

Incentive program The Safety The Safety The Safety Culture The Safety Culture Culture Culture Assessment value is Assessment Value is Assessment Assessment 60-80%. above 80%.

value is40% or value is40-60%.

less.

NUCLEAR OPERATING BUSINESS PRACTICE Number

___________________________________ 0B BP-VP-0 002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 21 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 3 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO RESOURCES Resources are available or can be obtained to ensure safe, reliable operations ATTRIBUTE RED YELLOW WHITE GREEN Adequacy of More than five More than five Five or less All management management manager or above supervisor or supervisor or above positions are filled with resources positions are not above positions positions are filled ANSI qualified FENOC 3

filled with ANSI are not filled with with ANSI qualified individuals.

qualified FENOC ANSI qualified FENOC individuals.

individuals. FENOC individuals.

Adequacy of More than four Three or four One or two sections Each section has a full personnel sections do not have sections do not do not have sufficient complement of resources sufficient personnel have sufficient personnel to perform personnel (minus to perform their personnel to their assigned normal attrition) to assigned perform their responsibilities. perform its assigned responsibilities. assigned responsibilities.

responsibilities.

Adequacy of Necessary activities, A number of Several identified Sufficient funding exists funding to improve nuclear identified improvements to to perform safety, as defined by improvements to improve nuclear improvements, as the Senior improve nuclear safety, as identified identified by the PRC in Management Team safety, as by the PRC in the plant, programs and and Project Review identified by the plant, programs, or other activities to Committee (PRC) PRC in the plant, other activities, are improve nuclear safety.

are not being programs, or not completed in a completed in a other activities, timely manner due to timely manner due are not lack of funding.

to lack of funding completed in a that was requested timely manner and rejected by due to lack of FENOC Executive funding.

Management.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tite: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 22 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 4 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO RESOURCES (continued)

Resources are available or can be obtained to ensure safe, reliable operations Adequacy of tools, Many necessary A number of Several scheduled Sufficient tools and material and tasks (PMs, scheduled tasks tasks (PMs, Work equipment exist to equipment Work Orders, (PMs, Work Orders, ECRs and perform its assigned ECRs and Orders, ECRs projects) are not tasks , for PMs, Work projects) are not and projects) are being completed in a Orders, ECRs and 3 being completed not being timely manner due to projects.

in a timely completed in a lack of tools, material manner due to timely manner or equipment.

lack of tools, due to lack of material or tools, material or equipment. equipment.

NUCLEAR OPERATING BUSINESS PRACTICE Number B

____________________________________DB BP-V P-0002 Tile: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 23 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 5 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO SELF-ASSESSMENT Self-Assessment is a tool used to monitor, assess and improve our performance ATTRIBUTE RED YELLOW WHITE GREEN Use of Nuclear Less than 60% of Between 60-75% of Between 75-90% of More than 90% of the Quality the sections have the sections have the sections have sections have used Assurance as used NQA as part used NQA as part used NQA as part of NQA as part of the self-part of the self- of the self- of the self- the self-assessment assessment process.

assessment assessment assessment process.

process process. process.

Self- Most sections are Sections are Sections are Each section is 3 assessments not routinely routinely performing routinely performing routinely performing performing self- scheduled self- scheduled self- scheduled self-assessments. assessments but assessments with assessments with there are many some findings, which findings that are fully findings and they are partially implemented.

are not effectively implemented.

implemented.

Performance Performance A number of Several performance Performance indicators Indicators indicators related performance indicators do not exist and are being to safety and indicators do not exist (or need to be regularly updated for quality do not exist (or need to be improved) for important activities exist. improved) for important activities affecting safety and important activities affecting quality and quality.

affecting quality and safety.

safety.

Personnel The performance The performance The performance The performance Performance appraisal program appraisal program appraisal program appraisal program Appraisals does not include includes includes includes assessments assessments of assessments of assessments of of safety and quality of safety or quality of safety or quality of safety or quality of performance and the performance. performance but performance but appraisals are being most employee some appraisals performed in timely appraisals have not have not been manner and all been performed. performed in timely employees have a manner and some current appraisal.

employees do not have a current appraisal.

NUCLEAR OPERATING BUSINESS PRACTICE Number.

____ ___ ____ ___ ____ ___D B B P-V P-0002 Tile: Revsion: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 24 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 6 of 37 POLICY COMMITMENT AREA CRITERIA RELATED TO OVERSIGHT Oversight is a tool used to show acceptable performance and identify areas for improvement and corrective actions.

ATTRIBUTE RED YELLOW WHITE GREEN Nuclear The Nuclear The Nuclear The Nuclear The Nuclear Committee Committee of Committee of the Committee Committee has has safety as a part of Board of Board has little occasionally safety as a part of the agenda every Directors focus on safety in discusses safety the agenda at least meeting.

the agenda. as a topic in the once per quarter.

agenda.

Company The CNRB has not The CNRB has not The CNRB has The CNRB has Nuclear Review implemented any implemented a implemented all but implemented the Board (CNRB) of the number of the one or two of the recommendations from recommendations recommendations recommendations the independent from the from the from the assessment of the independent independent independent CNRB.

assessment of the assessment of the assessment of the CNRB. CNRB. CNRB. The CNRB agenda has a safety discussion every The CNRB rarely The CNRB The CNRB agenda meeting.

has a safety agenda has a has a safety assessment safety discussion discussion two out of discussion on the only once per three meetings per agenda. year. year.

Nuclear Quality NQA is not A number of NQA NQA audits or NQA is regularly Assurance performing audits audits or assessments were performing audits and (NQA) or assessments of assessments were performed when assessments of important safety not performed required, but several important safety activities. when required or a important safety activities and identifying number of activities were not key issues for finding.

important safety subject to audits or activities were not assessments.

subject to audits or assessments.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tile: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 25 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 7 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO SAFETY There is a visible commitment to safety: nuclear, industrial, radiological and environmental ATTRIBUTE RED YELLOW WHITE GREEN Management There is no There is a There isa There is a observations management management management management performed as observation observation program observation program observation program scheduled program. and more than 50% and more than 75% and more than 90%

of management are performed as are performed as observations are scheduled. scheduled.

performed as scheduled.

Management Management More than 50% of More than 75% of the More than 90% of the observations observations are the management management management are self critical not self-critical. observations observations observations performed are self- performed are self- performed are self-critical and critical and corrective critical and corrective corrective actions actions implemented. actions implemented.

implemented.

Management No method has One method has Two means have Multiple means have emphasis on been used in the been used in the last been used in the last been used by safety to last month to month to provide month to provide management in the employees; provide emphasis emphasis on safety emphasis on safety to last month to provide questioning on safety to to employees (e.g., employees (e.g., town emphasis on safety to attitude employees (e.g., town hall meetings, hall meetings, 4 Cs employees (e.g., town town hall 4 Cs meetings, meetings, hall meetings, 4 Cs meetings, 4 Cs newsletters, and newsletters, and meetings, newsletters, meetings, training). training). and training).

newsletters, and training).

Leadership in Leadership in Leadership in Action Leadership in Action Leadership in Action Action Action does not includes discussions includes discussions includes discussions include on safety culture on safety culture on safety culture discussions on safety culture Leadership in Action Leadership in Action Leadership in Action training has been training has been training has been Leadership in completed for more completed for more completed for more Action training than 50% of than 75% of than 90% of has not been supervisors and supervisors and supervisors and above available for most above within 12 above within 12 within 12 months of supervisors and months of new months of new new appointment.

above. appointment. appointment.

NUCLEAR OPERATING BUSINESS PRACTICE Number.

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 26 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 8 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO SAFETY (continued)

There is a visible commitment to safety: nuclear, industrial, radiological and environmental Problem solving A problem Inseveral cases, With one or two The problem solving solving process the problem exceptions, the process, NOP-EN-3001 exists but there solving process problem solving has been properly isno use of the NOP-EN-3001 process, NOP-EN- implemented for document. has not been 3001 has been applicable conditions.

properly properly implemented for implemented for applicable applicable conditions. conditions.

Decision making Safety Safety significant Safety significant Safety significant significant decisions are decisions, with few decisions are made with decisions are made with exceptions, are adequate information, made in isolation minimal made with adequate oversight, involvement without information, information, and peer checking.

adequate oversight, oversight, information, involvement and involvement and oversight, peer checking. peer checking.

involvement and peer checking.

Improvements in None of the Most of the Most of the All improvements in safety margin improvements in improvements in improvements in safety margin are safety margin safety margin are safety margin are complete (e.g.

are complete not complete complete (e.g. emergency sump, cavity (e.g. emergency (e.g. emergency emergency sump, seal, decay heat pit sump, cavity sump, cavity seal, cavity seal, decay modification, seal, decay heat decay heat pit heat pit modification, refurbishment of reactor pit modification, modification, refurbishment of coolant pumps, Flus refurbishment of refurbishment of reactor coolant monitors, diesel air reactor coolant reactor coolant pumps, Flus starting system).

pumps, Flus pumps, Flus monitors, diesel air monitors, diesel monitors, diesel starting system).

air starting air starting system). system).

Plant activities Significant plant Condition Significant plant Significant plant receive proper event occurs Adverse to activities have activities have a management due to lack of Quality CR management management plan with a attention and management written due to oversight plan management sponsor safety focus attention or lack of scheduled for the and management safety focus. management duration of the oversight scheduled for attention or lack activity. the duration of the of safety focus. activity.

NUCLEAR OPERATING BUSINESS PRACTICE Number

____ ___ ___ ___ ____ ____ ___ ____ ___ ___D B B P-V P-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 4 03 Page 27 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 9 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO ROLES AND TEAMWORK Goals and roles are clear and teamwork is reinforced ATTRIBUT RED YELLOW WHITE GREEN E

Understanding Ad hoc surveys Ad hoc surveys Ad hoc surveys show Ad hoc surveys show that safety is show that less than show that 50-75% that 75-90% of that more than 90%

highest priority 50% of employees of employees employees of employees 3 understand that understand that understand that understand that safety is the highest safety is the highest safety is the highest safety is the highest priority. priority. priority. priority.

Program The majority of Some programs do With one or two All programs have ownership programs do not not have assigned exceptions, all assigned owners. In have assigned owners and a programs have general, program owners and many program assigned owners. owners are program owners owners are not With several implementing their are not implementing their exceptions, program assigned implementing their assigned owners are responsibilities.

assigned responsibilities. implementing their responsibilities. assigned responsibilities.

Ownership of More than 5% of Between 2-5% of Less than 2% of There are no SCAQ corrective SCAQ remedial SCAQ remedial or SCAQ remedial or remedial and actions and preventive preventive preventive corrective preventive corrective 3 corrective actions corrective actions actions and between actions overdue and and more than 10% and 5-10% of CAQ 2-5% of CAQ less than 2% of CAQ of CAQ remedial remedial and remedial and remedial and and preventive preventive preventive corrective preventive corrective corrective actions corrective actions actions are overdue actions are overdue are overdue for the are overdue for the for the previous for the previous previous quarter previous quarter quarter quarter Ownership of The quality of The quality of The quality of The quality of engineering engineering engineering engineering products engineering products products as products as products as as measured by the as measured by the measured by measured by the measured by the EAB is between 2.0 EAB is 1.0 or less.

the Engineering EAB is greater than EAB is between 3.0 and 1.1.

Assessment 3.0. and 2.1.

Board (EAB)

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 28 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 10 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO ROLES AND TEAMWORK (continued)

Goals and roles are clear and teamwork is reinforced Effectiveness of The individual The individual The individual error The individual error rate supervision of error rate is >0.5 error rate is <0.31 rate is<0.29 is<0.26 individual errors individuals individual errors individual errors individual errors per per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per 10,000 per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked.

hours worked. worked. worked.

Intra-department Ad hoc survey Ad hoc survey Ad hoc survey Ad hoc survey indicates teamwork and indicates there is indicates there is indicates alignment alignment and teamwork alignment no alignment minimal is improving and are obvious in all and little alignment and teamwork can be activities at the site. 3 teamwork some teamwork seen in some key among among activities.

managers. managers.

Expectations There are Although there There are There are statements of statements of are statements of statements of expectations for each expectations for expectations for expectations for section and managers individual some sections, most sections, and are reinforcing and sections but they are weakly they are being ensuring employees employees implemented. implemented. understand and routinely ignore implement them.

them.

Trust, openness 4Cs surveys 4Cs surveys 4Cs surveys show 4Cs surveys show more and focused show less than shows 30-60% of 60-90% of than 90% of employees commitment 30% of employees feel employees feel that feel that work groups employees feel that work groups work groups display display high levels of that work groups display high high levels of trust, trust, openness and display high levels of trust, openness and commitment.

levels of trust, openness and commitment.

openness and commitment.

commitment.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____ ___ ___ ____ ____ ___ ____ ___ ____ ___D BBP-V P-0002

Title:

Resion: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 29 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 11 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO ROLES AND TEAMWORK (continued)

Goals and roles are clear and teamwork is reinforced Clear goals and No clear goals Goals and Goals and priorities Most employees are priorities and priorities priorities exist but exist at most levels clear about goals and have been are not and some priorities as well as how established. adequately employees their role contributes to understood and understand and own achieving them.

owned by them.

employees.

Input and No employees Only managers Managers and Employees are involvement input and and supervisors supervisors appropriately involved in involvement are involved in occasionally request developing the occurs in the the development input/involvement in department business development of of department the development of plan, setting goals and department business plan, department business establishing work business plan, setting goals and plan, setting goals priorities.

setting goals establishing work and establishing and establishing priorities. work priorities.

work priorities.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Title. Remsion: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 30 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 12 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO OWNERSHIP AND ACCOUNTABILITY Ownership and accountability is evident ATTRIBUTE RED YELLOW WHITE GREEN Performance Less than 50% Between 50-74% Between 75-89% of More than 90% of appraisals of performance of performance performance performance appraisals appraisals are appraisals are appraisals are are completed on completed on completed on completed on schedule. 3 schedule. schedule. schedule.

Development Less than 50% Between 50-74% Between 75-89% of More than 90% of plans of managers of managers and managers and managers and and supervisors supervisors have supervisors have supervisors have have development development plans. development plans.

development plans.

plans.

Restart Readiness There is no A restart A restart readiness A restart readiness Reviews restart readiness readiness review review process review process exists review process. process exists exists and is and is implemented but implemented with efficiently and with implementation is the majority of strong management poor as shown by management participation.

lack of participation.

management participation.

Willingness to Ad hoc surveys Ad hoc surveys Ad hoc surveys Ad hoc surveys show raise safety show that less show that show that between that more than 95 %of 3 concerns than 75% of between 75-85% 85-95% of personnel personnel are willing to personnel are of personnel are are willing to raise raise safety concerns.

willing to raise willing to raise safety concerns.

safety concerns. safety concerns.

SRO reviews for Less than 75% Between 75-85% Between 85-95% are More than 95% are Operability are were completed are completed completed within 24 completed within 24 performed in a within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. hours. hours.

timely manner

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 31 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 13 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO OWNERSHIP AND ACCOUNTABILITY (continued)

Ownership and accountability is evident System None of the Most of the Most of the The improvements in assessments improvements in improvements in improvements in safety are complete (e.g.

safety are safety are not safety are complete emergency sump, cavity complete (e.g. complete (e.g. (e.g. emergency seal, decay heat pit emergency emergency sump, cavity seal, modification, sump, cavity sump, cavity seal, decay heat pit refurbishment of reactor seal, decay heat decay heat pit modification, coolant pumps, Flus pit modification, modification, refurbishment of monitors, diesel air refurbishment of refurbishment of reactor coolant starting system).

reactor coolant reactor coolant pumps, Flus pumps, Flus pumps, Flus monitors, diesel air monitors, diesel monitors, diesel starting system).

air starting air starting system). system).

NQA field NQA field NQA field NQA field NQA field assessments assessments assessments assessments assessments show show that managers and show that show that that managers and supervisors are managers and managers and supervisors are generally effective.

supervisors are supervisors are generally effective, generally generally with a few ineffective. effective, with exceptions.

several noteworthy exceptions.

Management Less than 50% Between 50-74% Between75-89% of More than 90% of observations of management of management management has management has held a leading to has held a has held a held a coaching coaching session in the coaching coaching coaching session session in the last last month.

session in the in the last month. month.

last month.

Timeliness of Less than 50% Between 50% Between 75% and More than 90% of corrective actions of corrective and 74% of 89%of corrective corrective actions actions corrective actions actions designated designated as required 3 designated as designated as as required for for restart, are required for required for restart, are completed on schedule restart are restart are completed on without extensions.

completed on completed on schedule without schedule without schedule without extensions.

extensions. extensions.

NUCLEAR OPERATING BUSINESS PRACTICE Numberl

__________________________________DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 32 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 14 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO TRAINING AND QUALIFICATION Training and Qualification are valued ATTRIBUTE RED YELLOW WHITE GREEN Supervisory Most supervisors Between 50-74% Between 75-89% of More than 90% of evaluations and managers of supervisors supervisors and supervisors and have not been and managers managers have been managers have been evaluated to have been evaluated to assess evaluated to assess assess their evaluated to their competence for their competence for competence for assess their their current their current positions.

their current competence for positions.

positions. their current positions.

Restart training Most required Between 50-74% Between 75-99% of 100% of required restart training is of required restart required restart restart training is 3 not complete. training is training is complete. complete.

complete.

Initial Operator Less than 70% of Between 70-84% Between 85-95% of More than 95% of new training new operators of new operators new operators operators passed their passed their passed their passed their initial initial license initial license initial license for license examination examination for the examination for the most recent for the most recent most recent class.

the most recent class class.

class. examination.

Requalification Less than 70% of Between 70-84% Between 85-95% of More than 95% of the training licensed of the licensed the licensed licensed operators have operators have operators have operators have passed their passed their passed their passed their requalification training.

requalification requalification requalification training. training. training.

Root cause Less than 50% of Between 50% Between 75% and More than 90% of root training root cause and 74% of root 89% of root cause cause evaluation evaluation cause evaluation evaluation personnel personnel have personnel have personnel have have received training received training on received training received training on TapRoot. TapRoot.

on TapRoot. on TapRoot.

NUCLEAR OPERATING BUSINESS PRACTICE NumberB

____ ___ ___ ____ ____ ___ ____ ___ ____ ___D B B P-V P-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 33 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 15 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO TRAINING AND QUALIFICATION (continued)

Training and Qualification are valued Operability Less than 50% of Between 50-74% Between 75-90% of More than 90% of determination applicable of applicable applicable operators applicable operators training operators and operators and and engineers have and engineers have engineers have engineers have received training on received training on received training received training operability operability on operability on operability determinations. determinations.

determinations. determinations.

Trainingon Less than 50% of Between 50% Between 75% and More than 90% of SCWE managers, and 74% of 89% of managers, managers, supervisors, supervisors, and managers, supervisors, and and operators have 3 operators have supervisors, and operators have received training on received training operators have received training on SCWE.

on SCWE. received training SCWE.

on SCWE.

Training on Less than 50% of Between 50-74% Between 75-89% of More than 90% of decision making applicable of applicable applicable personnel applicable personnel process personnel have personnel have have received training have received training received training received training on the decision on the decision making on the decision on the decision making process. process.

making process. making process.

Training on Less than 50% of Between 50-75% Between 75-90% of More than 90% of standardsand applicable of applicable applicable personnel applicable personnel expectations personnel have personnel have have received training have received training received training received training on standards and on standards and on standards and on standards and expectations. expectations.

expectations. expectations.

Continuing Less than 50% of Between 50-74% Between 75-89%of More than 90% of trainingidentified scheduled of scheduled scheduled training scheduled training by Curriculum training identified training identified identified by the CRC identified by the CRC is Review by the CRC is by the CRC is is completed in a completed in a timely Committee (CRC) completed in a completed in a timely manner. manner.

timely manner. timely manner.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 34 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 16 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CONTINUOUS IMPROVEMENT Commitment to continuous improvement is evident ATTRIBUTE RED YELLOW WHITE GREEN Improvements in No open About 50% of About 75% of open At least 85% of open management requisitions for open requisitions requisitions for requisitions for staffing management for management management management positions positions have positions have positions have been have been filled in the been filled in the been filled in the filled in the past past month.

past month. past month. month.

Restart Overview The ROP does The ROP has The ROP has The ROP issatisfied 3 Panel (ROP) not believe DB is expressed expressed some with DB progress to ready to restart. concerns over DB minor concerns and restart.

restart. believes DB can restart.

Corrective Action There are no The CARB has The CARB has been The CARB has been Review Board directors on the been enhanced enhanced with enhanced with director-(CARB) CARB. with director-level director-level level personnel.

personnel. personnel.

The backlog of The backlog of documents The backlog of The backlog of documents awaiting awaiting CARB documents documents awaiting CARB review is less review is more awaiting CARB CARB review is less than one week.

than four weeks. review is less than two weeks.

than four weeks.

Engineering The backlog of The backlog of The backlog of The backlog of Assessment documents documents documents awaiting documents awaiting Board (EAB) awaiting EAB awaiting EAB EAB review is less EAB review is less than review is greater review is less than two weeks. one week.

than four weeks. than four weeks.

Benchmarking Most of the Between 50-74% Between 75-89% of More than 90% of the against industry programs have of the programs the programs have programs have been standards not been have been been benchmarked benchmarked against 3 benchmarked benchmarked against industry industry standards.

against industry against industry standards.

standards. standards.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 35 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 17 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CONTINUOUS IMPROVEMENT (continued)

Commitment to continuous improvement is evident Operator crew Less than 50% of Between 50% Between 75% and More than 90% of the benchmarking the operators and 74% of the 90% of the operators operators have visited have visited other operators have have visited other other plants to plants to visited other plants to benchmark benchmark Davis-benchmark Davis- plants to Davis-Besse Besse operations.

Besse operations. benchmark operations.

Davis-Besse operations.

Management There is no A management A management A management observations management observation observation program observation program observation program has has been established. has been established.

program and been established. More than 75% of More than 90% of management More than 50% of management management does not regularly management observations are observations are conduct observations are performed as performed as observations of performed as scheduled and most scheduled and contain field activities. scheduled., but are considered quality information.

observations are acceptable.

weak.

Temporary There are more There are 11 or There are 8 or less There are 5 or less modifications than 11 temporary less temporary temporary temporary modifications. modifications. modifications. modifications.

Number of There are more There are 4 There are 2 operator There are 1 or less Operatorwork- than 4 operator operator workarounds. operator workarounds.

arounds workarounds. workarounds.

Number of There are more There are more There are more than There are less than 2 Control Room than 5 Control than 3 Control 2 Control Room Control Room deficiencies Room Room deficiencies. deficiencies.

deficiencies. deficiencies.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TilUe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 36 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 18 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CONTINUOUS IMPROVEMENT(continued)

Commitment to continuous improvement is evident Training on Less than 50% of Between 50-74% Between 75-85% of More than 90% of SCWE managers, of managers, managers, managers, supervisors supervisors and supervisors and supervisors and and operators have operators have operators have operators have received training on 3 received training received training received training on SCWE.

on SCWE. on SCWE. SCWE.

Licensed Less than 70% of Between 70-84% Between 85-95% of More than 95% of new operator pipeline new operators of new operators new operators operators passed their passed their initial passed their passed their initial initial license license initial license for license examination examination for the examination for the most recent for the most recent most recent class.

the most recent class class.

class. examination.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TiUe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 37 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 19 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CONTINUOUS IMPROVEMENT(continued)

Commitment to continuous improvement is evident SAFETY CONSCIOUS WORK ENVIRONMENT (SCWE)

CRITERIA RELATED TO SCWE REVIEW TEAM (SCWERT)

ATTRIBUTE RED YELLOW WHITE GREEN Use of SCWERT Less than 75% of Between 75- 85% Between 85-95% of More than 95% of disciplinary action of disciplinary disciplinary action disciplinary action 3 against action against against employees against employees and employees and employees and and contractors is contractors is reviewed contractors is contractors is reviewed by by SCWERT prior to reviewed by reviewed by SCWERT prior to the the action.

SCWERT prior to SCWERT prior to action.

the action. the action.

Effectiveness of There are more There are less There are 2 There are 1 or fewer SCWERTin than 3 allegations than 3 allegations allegations of allegations of avoiding of discrimination of discrimination discrimination discrimination discrimination submitted to the submitted to the submitted to the NRC submitted to the NRC claims NRC per year. NRC per year. per year. per year.

Valid There are one or There are no There are no There are no harassment, more substantiated substantiated substantiated intimidation, substantiated allegations of allegations of allegations of retaliation, and allegations of harassment, harassment, harassment, 3 discrimination harassment, intimidation, intimidation, intimidation, retaliation, reports intimidation, retaliation, and retaliation, and and discrimination per retaliation, and discrimination per discrimination per year and the trend of discrimination per year and the year. allegations is improving.

year. trend of allegations is not improving.

ECP concerns More than 50% of Between 40-50% Between 30-40% of Less than 30% of ECP that request ECP concerns per of ECP concerns ECP concerns per concerns per year -

confidentiality or year request per year request yearrequest request confidentiality anonymity confidentiality or confidentiality or confidentiality or or anonymity.

anonymity. anonymity. anonymity.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 38 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 20 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CROSS-FUNCTIONAL WORK MANAGEMENT AND COMMUNICATION Commitment to cross functional work management and communication is evident ATTRIBUTE RED YELLOW WHITE GREEN Cross-functional No cross-functional Some cross- Cross-functional Cross-functional teamwork teamwork is functional teamwork frequently teams are constantly evident. teamwork exists occurs, enabling forming/reforming but work issub- efficient and effective around the best way optimized. workflow. to get work done.

Department Many process Some process Minimal process Department interfaces breakdowns occur breakdowns breakdowns and interfaces are with extensive occur with rework occur with seamless; work flows amounts of rework frequent effective and efficient efficiently between needed. amounts of resolution of departments rework needed. emergency issues. throughout the entire organization.

Performance to Less than 50% of Between 50- Between 75-90% of More than 90% of schedule work iscompleted 75% of work is work is completed on work is completed on on time, as completed on time, as scheduled, time, as scheduled, scheduled, causing time, as with minimal within current major scheduled, with adjustments to resource capacity.

consequences to major resource capacity overall site adjustments to required to improve performance. resource performance.

capacity required to improve performance.

Interdepartmental Information that Information that Information that Information that communication impacts impacts impacts downstream impacts downstream downstream downstream implementation is implementation is implementation is implementation frequently shared on a communicated as not shared, causing is inconsistently timely basis, enabling soon as it's known, significant negative shared, which department to enabling all consequences to keeps proactively plan and departments to work other departments. departments in a respond. proactively on a reactive mode. consistent basis.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 39 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 21 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CROSS-FUNCTIONAL WORK MANAGEMENT AND COMMUNICATION (continued)

Commitment to cross functional work management and communication is evident Interdepartmental Problem solving Cross-functional Cross-functional Cross-functional problem solving and decision stakeholders are stakeholders are stakeholders are and decision making occurs in seldom involved frequently involved consistently involved making isolation; non- when problems when problems are when problems are involvement of are being solved being solved and being solved and other department and decisions are decisions are made. decisions are made.

stakeholders. made.

Systemic learning Things are broken Discrete problems Attention is focused Streamlining and down, focus ison are fixed with on learning and improving systems the pieces and minimal discovering and process is discrete problems understanding of fundamental constant to resolve are fixed with no interdependencies solutions to resolving long-standing and/or understanding of . long-standing and/or complex problems.

interdependencies. complex problems.

Incorporating Industry operating There is less than There is full Operating Experience industry experience is not adequate compliance with the is consistently and Operating actively evaluated implementation Operating fully utilized in every Experience and used to and minimal Experience department and is enhance site compliance to our Program. well integrated into performance. Operating everyday activities to Experience enhance plant Program. performance.

NUCLEAR OPERATING BUSINESS PRACTICE Number.

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 40 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 22 of 37 1 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CREATING AN ENVIRONMENT OF ENGAGEMENT AND COMMITMENT An environment of engagement and commitment is evident ATTRIBUTE RED YELLOW WHITE GREEN FENOC values, FENOC values, FENOC values, FENOC values, basic Most management basic principles basic principles and basic principles principles and personnel have and leadership leadership and leadership leadership strategies internalized and are strategies strategies are not strategies are are frequently living the FENOC used by inconsistently demonstrated by some values, basic management demonstrated by management principles and personnel. some personnel. leadership strategies management as demonstrated in personnel. their day to day actions.

Quality of Employees openly Employee Employees Concerns Employee Concerns 3 management and express fear of Concerns Program, Quality Program, Quality employee retaliation and will Program, Quality Assessment and 4Cs Assessment and 4Cs relationships not raise safety Assessment and survey data indicates survey data indicate concerns with 4Cs survey data that more than 50% of most employees raise management. indicates that employees will bring issues directly with less than 50% of concerns to management, work employees will management. collaboratively to bring safety resolves issues and concerns to reflect favorable management. improvement.

Organizational Management Management Management Management commitment and focuses on what is occasionally frequently supports consistently supports shared success in the best interest supports what is doing what is in the doing what is in the criteria of their department in the best best interest of the best interest for the at the expense of interest of their whole organization whole organization what is in the best department rather than what is in rather than what is in interest of the without the best interest of the best interest for whole organization. consideration to their department. their department.

what is in the best interest of the whole organization.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 41 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 23 of 37 MANAGERS' COMMITMENT AREA CRITERIA RELATED TO COMMITMENT TO CREATING AN ENVIRONMENT OF ENGAGEMENT AND COMMITMENT (continued)

An environment of engagement and commitment is evident Employee job The Safety The Safety The Safety The Safety satisfaction Conscious Work Conscious Work Conscious Work Conscious Work Environment survey Environment Environment survey Environment survey dimension around survey dimension dimension around dimension around job job satisfaction around job job satisfaction satisfaction indicates indicates less than satisfaction indicates 60-90% is above 90%.

30%. indicates 30-60%.

Ownership for Less than 50% of Between 50-74% Between 75-89% of More than 90% of 3 Excellence performance of performance performance performance Performance appraisals are appraisals are appraisals are appraisals are Appraisals completed on completed on completed on completed on schedule. schedule. schedule. schedule.

Ownership for Less than 50% of Between 50-74% Between 75-89% of More than 90% of Excellence managers and of managers and managers and managers and Development supervisors have supervisors have supervisors have supervisors have Plans development plans development plans development plans development plans

NUCLEAR OPERATING BUSINESS PRACTICE Number.

_ DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 42 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 24 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO DRIVE FOR EXCELLENCE Nuclear assets of people and plant are continuously improved to enhance margins of safety ATTRIBUTE RED YELLOW WHITE GREEN Maintenance Rule There are more There are two or There is one Red There are zero Red (a)(1) Systems than four Red three Red (a)(1) (a)(1) system. (a)(1) systems.

(a)(1) systems. systems..

Number of There are more There are 4 There are 2 operator There are 1 or less Operator than 4 operator operator workarounds. operator workarounds.

workarounds workarounds. workarounds.

Number of Control There are more There are more There are more than There are less than 2 Room deficiencies than 5 Control than 3 or less 2 Control Room Control Room Room Control Room deficiencies. deficiencies.

deficiencies. deficiencies.

Number of There are more There are 11 or There are 8 or less There are 5 or less temporary than 11 less temporary temporary temporary modifications.

modifications temporary modifications. modifications.

modifications.

Individual Error The individual The individual The individual error The individual error rate Rate error rate is error rate is rate is <0.29 is <0.26 individual errors

> 0.5 individual <0.31individual individual errors per per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> errors per errors per 10,000 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked.

10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> hours worked. worked.

worked.

Number of long There are more There are There are between 5 There are fewer than 5 standing than 20 long between 10 and and 10 long standing long standing equipment equipment standing 20 long standing equipment problems problems.

problems as equipment equipment defined by the problems. problems.

System Health Report

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Mte: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 43 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 25 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO DRIVE FOR EXCELLENCE (continued)

Nuclear assets of people and plant are continuously improved to enhance margins of safety Percent of self- Less than 80% 80% or more of 90%or more of the 95% or more of the CRs identified of the CRs the CRs CRs originated are originated are self-Condition Reports originated are originated are self-identified. identified.

(CRs) self-identified. self-identified.

Number of open Less than 80% of At least 80-90% At least 90% of All SCAQ evaluations Condition Report SCAQ of SCAQ SCAQ evaluations and 90% of CAQ 3 evaluations evaluations and evaluations and and 80-90% of CAQ evaluations were less than 70% of 70-80% of CAQ evaluations were completed on schedule CAQ evaluations evaluations were completed on for the previous quarter were completed completed on schedule for the on schedule for schedule for the previous quarter the previous previous quarter quarter Engineering The quality of The quality of The quality of The quality of Assessment engineering engineering engineering engineering products as Board (EAB) products as products as products as measured by the EAB is index measured by the measured by the measured by the 1.0 or less.

EAB is greater EAB is 3.0 or EAB is 2.0 or less.

than 3.0. less.

Performance More than one One significant Major plant Major plant evolutions during major plant significant event event has evolutions have have been performed as evolutions has occurred occurred during a been performed with planned.

during a plant plant evolution. some less than evolution. significant challenges or transients.

Operational transient is defined by INPO as a plant transient that occurs (reactor critical or while shutdown) and results in significant changes in primary or secondary plant parameters or results in 3 significant changes in mechanical or electrical lineups.

Significant is defined by INPO as an event which caused or had the potential to cause an appreciable reduction in plant safety or reliability, excessive radiation exposure, the discharge of radioactivity offsite or serious harm to individuals. The significance of a particular event (including the discovery of a serious deficiency, lies in the actual or potential consequences of the event or in the likelihood that it is a precursor to a more serious event.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

Title:

Revision, Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 44 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 26 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO QUESTONING ATTITUDE Challenges are welcomed ATTRIBUTE RED YELLOW WHITE GREEN Quality of pre-job Management Management Management Management briefs observations and QA observations and observations and QA observations and field observations QA field field observations QA field show that most pre-job observations show show that, with some observations show briefs are not that most pre-job exceptions, pre-job that pre-job briefs in acceptable. briefs are briefs are acceptable. general are acceptable. acceptable.

Percent of CRs Less than 13% of Between 13-15% Between 15-17% of More than 17% of per person per individuals wrote CRs of individuals individuals wrote CRs individuals wrote group during the past 30 wrote CRs during during the past 30 CRs during the past days. the past 30 days. days. month.

Number of The number of The number of The number of The number of programmatic programmatic CRs programmatic CRs programmatic CRs programmatic CRs CRs indicates that indicates that most indicates that a large indicates that individuals in general individuals are majority of individuals individuals in are reluctant to write willing to write CRs are willing to write general are willing CRs on programmatic on programmatic CRs on to write CRs on and management and management programmatic and programmatic and issues. issues. management issues. management issues.

Program and >0.48 program and <0.48 program <0.30 program and <0.27 program process error rate process errors per and process errors process errors per and process errors 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked. per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked. per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked. worked.

Raising problems Management Management Management Management observations and NQA observations and observations and observations and field observations NQA field NQA field NQA field show that most observations show observations show observations show individuals are not that most that a large majority that individuals in raising problems individuals are of individuals are general are raising encountered in the raising problems raising problems problems field. encountered in the encountered in the encountered in the field. field. field.

NUCLEAR OPERATING BUSINESS PRACTICE NumberB

___ _______ ___ ___ ___ ___ ___D B B P-V P-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 45 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 27 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO RIGOROUS WORK CONTROL AND PRUDENT APPROACH Performing activities in a quality manner is the standard ATTRIBUTE RED YELLOW WHITE GREEN Event Free Clock The event free The event free The event free clock The event free clock is clock is less clock is between is 30 to 39 days on greater than 40 days on than 20 days on 20 and 30 days average. average.

average. on average.

Industrial safety There are more There are There are 7 OSHA There are no more than performance than 10 OSHA between 10 and 7 recordables per 3 OSHA recordables per recordables per OSHA year. year.

year. recordables per year.

Individual error The individual The individual The individual error The individual error rate rate error rate is error rate is rate is <0.29 is <0.26 individual errors

>0.30 individual <0.31 individual individual errors per per 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> errors per errors per 10,000 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked.

10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> hours worked. worked.

worked.

Program and >0.48 program <0.48 program <.30 program and <0.27 program and process error rate and process and process process errors per process errors per errors per errors per 10,000 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked.

10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> hours worked. worked.

worked.

Significant human There are more There are fewer There are fewer than There were no performance than 3 significant than 3 significant 2 significant human significant human errors resulting in human human performance errors performance errors per plant transients( performance performance per year resulting in year resulting in plant 3 see page 43 for errors per year errors per year plant transients. transients.

definition of resulting in plant resulting in plant transient) transients. transients.

Backlog of There are more There are 200 There are 150 open There are 100 open procedure change than 200 open open PCRs. PCRs. PCRs.

requests (PCRs) PCRs.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

___ _______ ___ ___ ___ ___ ___D B B P-V P-0002 Tite: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 46 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 28 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO RIGOROUS WORK CONTROL AND PRUDENT APPROACH (continued)

Performing activities in a quality manner is the standard Deficiency rate for Deficiency rate The deficiency The deficiency rate The deficiency rate for QC holds for QC holds rate for QC holds for QC holds points QC holds points is less points is more points is less than is less than 15 %. than 7 %.

than 25% 25%.

Rework rate Rework rate is The rework rate The rework rate is The rework rate is more than 3%. is 2.5-3.0% 2.1-2.5% <2.0%

Ratio of completed Less than 50% More than 50% of More than 75% of More than 90% of to scheduled of scheduled scheduled work scheduled work scheduled work orders works orders per work orders are orders are orders are are completed.

week completed. completed. completed.

Number of late Less than 50% More than 50% of More than 75% of More than 90% of preventive of scheduled scheduled PMs scheduled PM are scheduled PMs are maintenance (PM) work orders are are completed. completed. completed.

activities completed.

Backlog of There are more There are There are between There are less than 134 corrective than 230 CM between 229 and 149 and 134 CM CM activities maintenance (CM) activities 150 CM activities activities outstanding.

activities outstanding. outstanding. outstanding.

Number of There are more There are two or There is one Red There are zero Red Maintenance Rule than four Red three Red (a)(1) are one or two (a)(1) (a)(1) systems.

(a)(1) systems (a)(1) systems. systems. systems.

Performance More than one One significant Major plant Major plant evolutions during major plant significant event event has evolutions have have been performed as evolutions.(see has occurred occurred during a been performed with planned. There are no page 43 for during a plant plant evolution. some less than significant events during definitions) evolution. There There are three significant major plant evolutions are more than significant events challenges or prior to restart.

three significant during major transients. There is events during plant evolutions one significant event major plant prior to restart. during major plant evolutions prior evolutions prior to to restart. restart.

NUCLEAR OPERATING BUSINESS PRACTICE Number DBBP-VP-0002 TiUe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 47 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 29 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO RIGOROUS WORK CONTROL AND PRUDENT APPROACH (continued)

Performing activities in a quality manner is the standard Use of procedures Management Management Management Management and work orders observations and observations and observations and observations and NQA NQA field NQA field NQA field field observations observations observations show observations show show that individuals show that most that most that a large majority in general are using individuals are individuals are of individuals are procedures or work not using using procedures using procedures or orders.

procedures or or work orders. work orders.

work orders.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002

Title:

Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 48 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 30 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO OPEN COMMUNICATIONS Associates are comfortable in voicing opinions, issues and concerns ATTRIBUTE RED YELLOW WHITE GREEN Number of CRs Less than 13% of Between 13-15% Between 15-17% of More than 17% of perperson per individuals wrote of individuals individuals wrote CRs individuals wrote group CRs during the wrote CRs during during the past 30 CRs during the past past 30 days. the past 30 days. days. 30 days.

Ratio of concerns There are more There are more There are 4 times There are 8 times submitted to NRC allegations ECP concerns more ECP concerns more ECP Employee than ECP than NRC than NRC allegations. concerns than NRC Concerns Program concerns. allegations. allegations.

(ECP) vs. NRC allegations Employee surveys Employee surveys Employee surveys Employee surveys Employee surveys indicate that most indicate that 65- indicate that more than indicate that more individuals are not 75% of individuals 75-90% of individuals than 90% of willing to raise are willing to raise are willing to raise individuals are concerns. concerns. concerns. willing to raise concerns.

Feedback from Feedback from the Feedback from the Feedback from the Feedback from the 4Cs meetings 4Cs meetings 4Cs meetings 4Cs meetings 4Cs meetings indicates that most indicates that most indicates that a large indicates that individuals are not individuals are majority of individuals almost all willing to raise willing to raise are willing to raise individuals are concerns. concerns. concerns. willing to raise concerns.

SCORE program Each months total Each months Each months total Each months total Safe behavior is total Safe behavior Safe behavior is 70% Safe behavior is 59% or less is 60% to 69% to 79% 80% or higher Pre-job briefings Management Management Management Management observations and observations and observations and QA observations and QA field QA field field observations QA field observations show observations show show that, with some observations show that most pre-job that most pre-job exceptions, pre-job that pre-job briefs in briefs are not briefs are briefs are acceptable. general are acceptable. acceptable. acceptable.

NUCLEAR OPERATING BUSINESS PRACTICE Number DBBP-VP-0002 Tdte: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 49 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 31 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO OPEN COMMUNICATIONS (continued)

Associates are comfortable in voicing opinions, issues and concerns Intra-department No formal Haphazard and Formal Formal communication information communication infrequent communication structures exist and are sharing structures exist information structures exist and consistently used to for sharing sharing exists are occasionally used share information within 3 information within to share information departments within departments within departments departments Quality of 4Cs surveys 4Cs surveys 4Cs surveys indicate 4Cs surveys indicate communication indicate less indicate 30-60% 60-90% believe more than 90% believe than 30% believe communication is communication is good believe communication is good communication good is good

NUCLEAR OPERATING BUSINESS PRACTICE Number:

____ ___ ___ ________ ___ ____ ___ ____ ___D B B P-V P-0002

Title:

Revision Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 50 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 32 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO OPEN COMMUNICATIONS SAFETY CONSCIOUS WORK ENVIRONMENT (SCWE)

CRITERIA RELATED TO RAISING CONCERNS WITHOUT FEAR OF RETALIATION ATTRIBUTE RED YELLOW WHITE GREEN Employee Surveys/interviews Surveys/interviews Surveyslinterviews Surveys/interviews awareness of indicate that most indicate that 50- indicate that 75-90% indicate that more than policy employees are not 75% of employees of employees are 90% of employees are aware of policy. are aware of policy aware of policy and aware of policy and and consider it a consider it an FE consider it an FE value FE value value and the normal way to do business Training on Less than 50% of Between 50-74% Between 75-89% of More than 90% of SCWE managers, of managers, managers, managers, supervisors, supervisors, and supervisors, and supervisors, and and operators have operators have operators have operators have received training on 3 received training received training received training on SCWE.

on SCWE. on SCWE. SCWE.

Ratio of There are more There are more There are 4 times There are 8 times concerns NRC allegations ECP concerns more ECP concerns more ECP concerns submitted to than ECP than NRC than NRC allegations. than NRC allegations.

ECP vs. NRC concerns. allegations.

allegations NQA interviews NQA interviews NQA interviews NQA interviews NQA interviews indicate indicate that less indicate that indicate that between that more than 90% of than 50% of between 50-74% 75- 90% of individuals individuals are willing to individuals are of individuals are are willing to raise raise concerns.

willing to raise willing to raise concerns.

concerns. concerns.

ECP concerns More than 50% of Between 40-50% Between 30-40% of Less than 30% of ECP that request ECP concerns per of ECP concerns ECP concerns per concerns per year confidentiality or year request per year request year request request confidentiality anonymity confidentiality or confidentiality or confidentiality or or anonymity anonymity anonymity anonymity

NUCLEAR OPERATING BUSINESS PRACTICE NumberDBBP-VP-0002 Tite. Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 51 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 33 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO OPEN COMMUNICATIONS SAFETY CONSCIOUS WORK ENVIRONMENT (SCWE)

CRITERIA RELATED TO EMPLOYEE CONCERNS PROGRAM (ECP)

ATTRIBUTE RED YELLOW WHITE GREEN Use of ECP by Employee Employee Employee surveys Employee surveys employees surveys indicate surveys indicate indicate that indicate that more than that less than 65 that between between 75% and 90% of individuals are

% of individuals 65% to 75% of 90% of individuals willing to raise concerns.

are willing to individuals are are willing to raise raise concerns. willing to raise concerns.

concerns.

Satisfaction of Less than 50% of Between 50% Between 75% and More than 90% of employees using employees that and 74 % of 89% of employees employees that use the the ECP use the ECP employees that that use the ECP ECP report being report being use the ECP report being satisfied satisfied with the satisfied with the report being with the process process process satisfied with the 3 process Complaints of There are more There are 2 There is I complaint There are zero breach of than 2 complaints complaints per per year complaints per year confidentiality of per year year ECP Management Employee Employee Employee surveys Employee surveys support for ECP surveys indicate surveys indicate indicate between indicate more than 90%

less than 65% of between 65% 75% and 90% of of individuals believe individuals and 75% of individuals believe management supports believe individuals management ECP management believe supports ECP supports ECP management supports ECP

NUCLEAR OPERATING BUSINESS PRACTICE Number B

___________________________________DBBP-VP-0002 Title Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 52 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 34 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO NUCLEAR PROFESSIONALISM Persistence and urgency in identification and resolution of problems is prevalent ATTRIBUTE RED YELLOW WHITE GREEN Ownership for Less than 50% of Between 50-74 % Between 75-90% of More than 90% of Excellence applicable of applicable applicable employees applicable employees employees have employees have have completed the have completed the completed the completed the Ownership for Ownership for Ownership for Ownership for Excellence Excellence Excellence Excellence development plans development plans development development plans. plans Training Training Training Training attendance Training attendance is 3 attendance attendance is less attendance is is between 75-89%. greater than 90%.

than 50%. between 50-74%.

Rework rate The rework rate is The rework rate The rework rate is The rework rate is more than 3%. is 2.5-3.0% 2.1-2.5% <2.0%

Results of EAB The quality of The quality of The quality of The quality of assessments engineering engineering engineering products engineering products as products as products as as measured by the measured by the EAB measured by the measured by the EAB is 2.0 or less. is 1.0 or less.

EAB is greater EAB is 3.0 or than 3.0. less.

Red and Yellow There are more There are 13-19 There are 6-13 yellow There are less than 6 windows in than 19 yellow or yellow or red or red windows in yellow or red windows training red windows in windows in training. (80-90%) in training. (90% or training. (Less training. (70- better) than 70%) 80%)

Radiation There are more There are 1-3 There is 1 radiation There are no radiation Protection than 3 radiation radiation protection event per protection events per events protection events protection events quarter. quarter.

per quarter. per quarter.

Chemistry The index is The index is The index is equal to The index is equal to or Performance greater than equal to or less or less than 1.004. less than 1.000 Index 1.036 than 1.036

NUCLEAR OPERATING BUSINESS PRACTICE Number.

___________________________________DBBP-VP-0002

Title:

Revision. Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 53 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 35 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO NUCLEAR PROFESSIONALISM (continued)

Persistence and urgency in identification and resolution of problems is prevalent Procedure Management Management Management Management compliance observations and observations and observations and observations and NQA NQA field NQA field NQA field field observations show observations show observations observations show that individuals in that most show that most that a large majority general are complying individuals are not individuals are of individuals are with procedures.

complying with complying with complying with procedures. procedures. procedures.

Personal Few employees Employees work Employees do what it Employees at all levels 3 initiative routinely express hard to do what's takes to get the job take personal initiative why work can't be expected. done to invent methods to done or improved. achieve higher quality and greater efficiency Ownership Employees don't Employees are Employees follow Most employees follow through on inconsistent in through and do what regularly volunteer to assigned following through is asked of them and own/lead project, commitments and to meet quality do what is defined develop plans, seldom volunteer and timing of within their job coordinate efforts and for ownership assigned description see work through to commitments completion

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 Tfile: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 54 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 36 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO NUCLEAR PROFESSIONALISM (continued)

Persistence in identification and resolution of problems is prevalent CRITERIA RELATED TO THE CORRECTIVE ACTION PROGRAM ATTRIBUTE RED YELLOW WHITE GREEN Implementation Implementation Implementation of Implementation of The CAP improvements of CAP of the CAP the CAP the CAP designated for restart improvements improvements improvements improvements for are completed and designated for designated for restart are associated training is restart has not restart are started completed but the completed.

started but none are associated training completed. is not completed.

Root cause The root cause The root cause The root cause The root cause evaluation quality evaluation evaluation evaluation approval evaluation approval rate approval rate as approval rate as rate as determined as determined by the 3 determined by determined by the by the CARB is CARB is 90% or greater.

the CARB is less CARB is between between 75-90%.

than 50%. 50-74%.

CR category The CR category The CR category The CR category The CR category accuracy accuracy rate is accuracy rate is accuracy rate is accuracy rate is 90% or less than 70% or between 70-80% between 80-90%. greater.

greater.

CR self- Less than 80%of 80% or more of 90% or more of the 95% or more of the CRs identification rate the CRs the CRs originated CRs originated are originated are self-originated are are self-identified. self-identified. identified.

self-identified.

Employee survey Employee Employee surveys Employee surveys Employee surveys surveys indicate indicate that indicate that indicate that less than that only 15 % of between 15-10% between 10-5% of 5% of individuals are not individuals are of individuals are individuals are not willing to use the CAP.

not willing to use not willing to use willing to use the the CAP. the CAP. CAP.

NUCLEAR OPERATING BUSINESS PRACTICE Number:

DBBP-VP-0002 TMe: Revision: Page RESTART READINESS REVIEW EXTENDED PLANT OUTAGE 03 Page 55 of 55 APPENDIX A: ASSESSMENT OF SAFETY CULTURE CRITERIA Page 37 of 37 INDIVIDUALS' COMMITMENT AREA CRITERIA RELATED TO NUCLEAR PROFESSIONALISM (continued)

Persistence in identification and resolution of problems is prevalent CRITERIA RELATED TO THE CORRECTIVE ACTION PROGRAM NQA interviews NQA interviews NQA interviews NQA interviews NQA interviews indicate that 15% indicate that indicate that between indicate that less than of individuals are between 15-10% 10-5% of individuals 5 % of individuals are not willing to use of individuals are are not willing to use not willing to use the the CAP. not willing to use the CAP. CAP.

the CAP.

Timeliness of Less than 50% of Between 50-74% Between 75-89%of More than 90% of corrective actions corrective actions of corrective corrective actions are corrective actions are 3 are completed on actions are completed on completed on schedule without completed on schedule without schedule without extensions. schedule without extensions. extensions.

extensions.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1310 Attachment Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments.

Please notify the Manager - Regulatory Affairs (419-321-8450) at the DBNPS of any questions regarding this document or associated regulatory commitments.

COMMITMENTS DUE DATE None