ML043420360

Independent Assessment Report of the Engineering Program Effectiveness at the Davis-Besse Nuclear Power Station

ML043420360
Person / Time
Site:	Davis Besse
Issue date:	12/06/2004
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Caldwell J NRC/RGN-III
References
Download: ML043420360 (62)

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FENOC FirstEnergy Nuclear Operating Company Mark B. Beziila 550 I North State Route 2 Oak Harbor. Ohio 43449 4 19-321-7676 Fax: 419-321-7582 Vice President - Nuclear Docket Number 50-346 License Number NPF-3 Serial Number 1-1394 December 6,2004 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I11 2443 Warrenville Road, Suite 2 10 Lisle, IL 60532-4352

Subject:

Submittal of Independent Assessment Report of the Engineering Program Effectiveness at the Davis-Besse Nuclear Power Station

Dear Mr. Caldwell:

The purpose of this letter is to submit the Independent Assessment Report of the Engineering Program effectiveness at the Davis-Besse Nuclear Power Station (DBNPS).

This submittal is in response to the Nuclear Regulatory Commission (NRC) letter dated March 8,2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order.

This Independent Assessment was conducted from October 11 to October 22,2004. The Assessment was performed in accordance with the Engineering Assessment Plan submitted via letter Serial Number 1-1377 dated July 12,2004. The enclosed report contains the results of the Independent Assessment as well as action plans to address the Areas For Improvement (AFI) identified by the assessment.

If you have any questions or require additional information, please contact Mr. Clark A. Price, Manager - Regulatory Compliance, at (419) 321-8585.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1394 Page 2 of 2 Attachment - Commitment List Enclosure - Confirmatory Order Independent Assessment Engineering Programs Davis-Besse Nuclear Power Station cc:

USNRC Document Control Desk J. A. Grobe, Chairman, NRC 0350 Panel DB-1 NRC/NRR Senior Project Manager DB-1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1394 Attachment, Page 1 of 3 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 Compliance (419) 321-8585 at the DBNPS with any questions regarding this document or associated regulatory commitments.

COMMITMENTS DUE DATE AFI DB 1.2 - Modification Tracking and Closure

1. Classify the approximately 550 identified unclassified proposed 1. End of Cycle 14 engineering change requests by the end of Cycle 14. Progress will be monitored utilizing the status of open engineering changes monthly through the monthly Performance Report and quarterly through the Design Basis Assessment Report (DBAR).

2. The long term solution to the current less than adequate tracking 2. December 31,2005 of engineering change status between issuance to the field and return to engineering for closure will be addressed through the inclusion of engineering changes into SAP. This will provide a common platform for managing the design as well as the implementation stages of engineering changes and provide improved monitoring of the engineering change progress.

3. The planning organization has placed additional focus on 3. June 30,2005 processing through for closure the engineering changes that are essentially field complete. The actual status of the approximately 57 identified engineering changes requiring closeout will be confirmed and dispositioned properly by the end of the second quarter 2005.

4. In the interim, Operations will re-review these open engineering 4. February 28,2005 changes to ensure no adverse impact to safe plant operations. The total number of engineering changes issued for implementation will be monitored monthly through performance indicators included in the Monthly Performance Report.

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1394 Attachment, Page 2 of 3 COMMITMENTS DUE DATE AFI DB 1.2 - Modification Tracking and Closure (continued)

5. A future revision of NOP-CC-2003, Engineering Changes, will 5. December , 2005 include a common engineering change close-out process. This revision is currently in progress through the fleet engineering programs manager.

AFI DB 2.2 - Calculation Improvement Program

1. The Calculation Improvement Plan is updated on a quarterly basis through the Design Basis Assessment Report (DBAR). Several enhancements to the DBAR will be made, these changes include:

a) Improve the DBAR report content to include an overall trend and summary to focus management attention to problem 1.a) Upon Issuance of areas. This report content change will be made in the 1 the lStQuarter quarter 2005 DBAR. 2005 DBAR b) The current status of the calculation improvement plan will be reviewed against the recent level of calculation quality. Due dates will be reconfirmed and rebaselined and adjustments 1.b) Upon Issuance of will be made as necessary and the plan will be updated in the the 1 Quarter 2005 lStquarter 2005 DBAR. DBAR AFI DB 6.2 - Utilization Of The Self Assessment Process 1 . FENOC Fleet ownership for Self-assessments has been 1. Complete established.

2. Engineering efforts will be focused to better utilize the Self- 2. December 31,2005 Assessment process in regards to planning and completion of self-assessments. The 2005 self-assessment focus areas and owners have been identified and submitted for approval. There are Fleet engineering self-assessments being scheduled for 2005. These assessments would include Davis-Besse.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1394 Attachment, Page 3 of 3 COMMITMENTS DUE DATE AFI DB 6.2 - Utilization Of The Self Assessment Process (continued)

3. March 31,2005

3. During the next revision of Business Practice NOBP-LP-200 1, FENOC Focused Self-Assessment Process, enhancement opportunities and integration of overall assessments will be evaluated for inclusion.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1394 Enclosure CONFIRMATORY ORDER INDEPENDENT ASSESSMENT ENGINEERING PROGRAMS DAVIS-BESSE NUCLEAR POWER STATION (56 pages follow)

Confirmatoy Order hdependent Assessment Engineering Programs Davis-Besse Nuclear Power Statim Report Number 2004-0102 Fad li ty Pa vis-Eesse Location 5501 North State Route 2 Oak Harbor, Ohio 43449-9760 Dates October 10-22,2004 Final Submittal (Section I )

Date Independent Assessment Lead Assessment Action Plans (Section 11) Approved:

Date-vic'c

Table of contents SECTION 1 ......................................................................................................................... 1 A Executive Summary .................................................................................................... 1 B Introduction ................................................................................................................. 4 C Scope of Assessment ................................................................................................... 5 D Methodology ............................................................................................................... 6 E Results ......................................................................................................................... 9 Area 1 Modifications Process ......................................................................................... 9 Area 2 Calculations ....................................................................................................... 12 Area 3 System Engineering ........................................................................................... 17 Area 4 Use of the Corrective Action Program by Engineering .................................... 21 Area 5 Management Topics .......................................................................................... 23 Area 6 Self Assessment ................................................................................................. 30 SECTION 2 ....................................................................................................................... 33 Action Plans for Identified Areas for Improvement .......................................................... 33 Appendix 1 FENOC submittal .......................................................................................... 36 Appendix 2 Personnel interviewed ................................................................................... 48 Appendix 3 Documents reviewed ..................................................................................... 49

SECTION 1 A Executive Summarv The Engineering Programs Assessment Team found the engineering program at Davis-Besse to be generally effective.

The team reviewed engineering work product in a number of areas in depth, and did not find any discrepancies that were considered to be either significant in terms of the validity of the work product, or indicative of a systematic deficiency in engineering work performance or quality management.

The Teams findings consisted of:

3 Strengths 3 Areas For Improvement (AFls) 3 Positive Noteworthy Items (NI+)

13 Negative Noteworthy Items (NI-)

A Strength characterizes performance that is exceptionally effective in achieving desired results.

An Area for Improvement characterizes areas where acceptance criteria including management expectations are not being met.

A Noteworthy Item characterizes areas where acceptance criteria including management expectations are being met changes could be made to enhance program or process general efficiency.

The Team also identified Positive Noteworthy Items, which address areas where performance does not rise to the level of a strength, but nevertheless merited favorable mention.

There were several strengths and several areas where performance, while not at the level of a Strength, was nevertheless positive enough to be noteworthy.

However, there were also a number of areas where Engineering performance could be improved, a couple of areas where recent performance had fallen behind plan, and three areas for improvement.

Strengths included:

Rapid Response Team effectiveness in supporting resolution of urgenuemergent issues, especially as needed by the Plant Internalization of Engineering Principles and Expectations Engineering Assessment Board influence on quality of engineering work products Page 1 of 54

AFls included:

Slow closure of some modifications Declining focus on and rate of progress of the Calculation Improvement Program Slippage of the Self-Assessment schedule and mixed quality of assessment findings and corrective actions Positive Noteworthy Items Implementation and use of the Calculation Utility Effective use of the Design Interface Evaluation (DIE) to support calculations System Engineering Support of the Plant Noteworthy Items Selection and prioritization of modif icat ions (a1ign ment issue)

Lack of confidence In System Descriptions Limited focus of Margin Management initiative System Health Rating not a leading indicator System Health Improvement plans elements not accomplished as planned Inhibited access to calculations by system engineers Low level of fleet counterpart interactions Work burden imposed in finding acceptors of corrective actions Expectations at interfaces with parallel processes Engineering management tools and techniques for planning, scheduling, assigning work Backlog reduction Human Resource development Engineering Rigor and Attention to Detail The Team noted that Davis-Besse has recently restarted power operations after a lengthy shutdown and is in the transition from recovery activities to normal operation, with the transition period characterized by a work load consisting of both post-restart backlog workoff and work typical of normal operations. The team also noted that Davis-Besse is undergoing adjustment to the corporate fleet environment and the recent reorganization and redeployment of staff resources.

The Team observed that it is important for the Davis-Besse Engineering organization to adopt management techniques that will allow better prioritization of work load, better focus on priority work items, better integration of work efforts, and improvement of process efficiency.

Two condition reports were filed during the assessment:

04-06372 COIA-Eng -2004-Dry Fuel Storage Pad Transient Combustible Control.

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During a review by the Independent Assessment Team review of implementation of design basis requirements within the plant, a process issue related to control of transient combustibles was identified for the Dry Fuel Storage Pad.

04-06485 COlA -Eng-2004 Accumulator Sizing Calculation for S W1424/1429/1434 This Condition Report documents concerns and responses regarding Mechanical Calculation C-ME-011.01-142 Rev 01 "Accumulator Sizing Calculation for SW3434/1429/1434" that were identified during the 2004 Engineering Order Assessment.

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B Introduction The Confirmatory Order Modifying License dated March 8, 2004 required FENOC to conduct independent assessments of the effectiveness of the engineering program annually for a period of five years. The assessment conducted by the Independent Assessment Team and reported in this document is the first annual independent assessment of the engineering program.

The plan for this Independent Assessment was formulated in accordance with the guidance of FENOCs procedure DBBP-VP-0009 Mgt Plan for Conf Order Assessments Rev 1, and also with benefit of the guidance of FENOCs procedure NOBP-LP-2001 Focused Self-Assessment, The Assessment Plan was submitted via serial letter 1-1377 dated July 12,2004 (see Appendix 1 )

The members of the Independent Assessment Team were drawn from the nuclear power industry. There were three team members from operating US nuclear plants and three from the Marathon Consulting Group. The CVs of the team members are included in the Assessment Plan. The Team members were:

John Garrity The Marathon Consulting Group, Team Leader Paul Borer The Marathon Consulting Group Harold Baumberger The Marathon Consulting Group Brad Adams Byron Station, Exelon Nuclear John Meyer Comanche Peak Station, TXY Tom Vine Duane Arnold Energy Center, NMC (CVs are provided in Appendix 1)

The Independent Assessment Team commenced work on the Davis-Besse independent assessment in June of 2004 with information gathering and activities and discussions with FENOC management. The team gathered information from FENOC relevant to the DB assessment and posted this information to an FTP site established for this purpose over a period of several months. The two weeks of September 27 and October 4 were devoted to intensive review of FENOC documents and formulation of interview strategies, questions, and interview lists. The Team spent the weeks of October 11 and October 18 at the Davis-Besse site conducting initial and follow-up interviews and reviewing additional FENOC supplied material.

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C Scope of Assessment The assessment concentrated on engineering performance in six areas of interest:

Modifications Calculations System Engineering Use of the Corrective Action Program by Engineering Management topics Self-Assessment Within each of these areas, sub-areas were identified for review. These sub-areas are shown in the assessment plan (Appendix 1).

The engineering assessment avoided duplication of the work performed under other independent assessments, particularly the independent assessment of the Corrective Action Program that was completed during the weeks of September 13 and September 27 before the engineering assessment took place.

The scope of the Engineering program assessment included primarily activities and performance since restart.

Within the areas assessed, information was drawn from a variety of sources, including:

Documents supplied by FENOC, including procedures, performance data and reports, program descriptions, engineering work products such as modification packages, calculations, etc., CAP work items and records, and assessments (partial list of documents provided in Appendix 3)

Assessments performed by others such as NRC, INPO, and independent assessors and reviewers FENOC task, project, program, and business plans and status reports Interviews with FENOC personnel (interview list provided in Appendix 2)

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D Methodology The assessment was performed in according to the sequence of steps, summarized below.

1 . Develop the assessment scope, including areas to be assessed and assessment topics under each area. This step included consideration of FENOC managements views, FENOCs procedural and business planning guidance for assessments in general, and the need to meet the particular assessment requirements for Davis-Besse.

2. Develop the assessment plan, including the overall objectives and approach, the framework for conducting the assessment, and including review and comments by FENOC engineering and corporate management and staff.

3 . Determine the team size and composition requirements.

4. Recruit the team. This effort was aided significantly by support initiatives to recruit industry peers.

5. Develop a document library and means to provide access to team members.

This included collecting documents from FENOCs corporate offices and the Davis-Besse site such as procedures, performance reports, engineering work products, and organizing them for access by team members through a website established for this purpose.

6 . Develop a list of plant personnel to be interviewed and typical interview questions or areas of inquiry. A list of plant personnel to be interviewed was developed by defining the organizational positions to be interviewed for each assessment area and topic, and selecting one or more team members to represent that interview area of interest. The team reviewed the interview list and proposed consolidation of interviews where appropriate to reduce duplication of effort by the plant staff and the team members. The assessment areas and topics were reviewed and a list of interview intentions and potential questions was prepared by the team.

7 . Develop the detailed interview schedule. Plant administrative support personnel scheduled interviews and published schedules notifying interviewees and team members of the time, date, location, subject, and participants of each interview. Typically an interview was scheduled for an hour, and interviewees were scheduled to meet with from one to up to four team members. Follow-up interviews were scheduled during the assessment as needed. Approximately seventy formal interviews were conducted, with seventy-nine individuals interviewed, And additional follow-up discussions were held as necessary. The first week on site was dedicated to interviews Page 6 of 54

and assessment of the areas of modifications, calculations, and system engineering, while the second week focused on the areas of use of the CAP by engineering, management topics, and self assessment.

8. Assemble the team and provide orientation. The team assembled for an orientation session the Sunday evening before the assessment. The interview schedules were briefed, any new documents received were noted, and the overall assessment schedule was discussed. The assessment plan and scope, the background for and development of the assessment scope, and the guidance provided for focused self-assessments by the FENOC fleet procedure, were discussed.

9. Obtain badges for unescorted access to the plant. All Independent Assessment Team members were granted unescorted access.

10.Conduct interviews and document reviews. During the assessment period, results of interviews and document reviews were summarized on daily records of facts and observations. Items of interest were those thought to require further follow-up or having the potential for becoming findings.

Approximately four hundred items of interest were logged during the assessment. The daily records were collected, consolidated, and distributed to team members on a daily basis.

11 .Organize items of interest. Toward the end of each of the assessment weeks, items of interest from daily records were binned to identify evolving issues in the form of potential Strengths, AFls, and Noteworthy Items in each of the assessment areas. Potential findings were documented on a summary form developed for this purpose.

12. Provide regular counterpart briefings. The Team briefed site counterparts on a regular basis to keep the site staff informed of items of interest and potential findings, and also to support generation of Condition Reports when appropriate (two were generated during the assessment).

13. Consolidate items of interest into strengths, areas for improvement (AFls),

and noteworthy items (Nls). Near the end of each the assessment week, issue summary forms were developed to reflect available information and to support generation of management briefing and exit talking points.

14. Brief plant engineering management at exit. Site management was briefed at a formal exit on Friday of the second week of the assessment. The briefings were conversational in style, with a team member for each assessment area discussing the significant findings in his area. For each potential finding, the issue and appropriate examples or other supporting information was presented and questions were answered. The daily counterpart briefings and Page 7 of 54

management pre-exit briefings assured that the site personnel being briefed already knew of all findings and that appropriate CRs had been generated.

15.Provide assessment finding preliminary findings. Site management briefing talking points and the issue summary forms were provided to the sites in electronic file form after the assessment was complete. (At this stage, the findings were still considered draft, but useful information for the sites).

16. Provide report for Davis-Besse. This report is the report for information and action by Davis-Besse and FENOC.

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E Results The Assessment teams findings are summarized in this section. These findings are based on extensive working field notes and Team discussions conducted each day during the assessment period and after.

Recommendations are provided following some findings. The Team offers these recommendations as additional information, but expects that FENOC will formulate their own action plans which may legitimately differ from the Teams recommendations.

Area I Modifications Pro cess The teams review included the following activities:

a. Selection and prioritization of potential modifications

b. Efficiency of the modification process (graded approach, at risk changes)

c. Owner acceptance sub-process (review of contracted work)

d. Quality of modification packages

e. Closeout of modification packages and supporting document updates

f. Effectiveness of modifications in fixing known problems

g. Known process problems and progress in solving

h. Fleet interaction and progress toward consistency

i. Interaction and support from parallel processes

j. Workload management Strength DB 1.1 Rapid Response Team The Rapid Response Team (RRT) provides timely and efficient resolution of emergent- engineering issues and reduces the unscheduled workload of design and plant engineering.

AFI DB 1.2 - Modification Tracking and Closeout Initiation and closeout of documentation associated with plant modifications are untimely and inefficient.

There are about 550 Engineering Change Requests (ECR) that have not been dispositioned (apparent indecision about the need or type of modification to be used).

Planning and document control personnel indicate that there are about 57 modifications, some believed to be installed in the plant as early as 1998, Page 9 of 54

that remain open because the exact status of the modifications in question is unknown; thus the documentation closeout has not been performed.

The closeout process is unique at each FENOC site. At Perry, closeout is performed by Document Control; at Beaver Valley, the process is handled by Engineering; at D-B, Work Planners are responsible.

Recommendation 1 . Review the modification closeout processes across the fleet and adopt a common process. Consider process efficiency improvements as well as consistency improvements.

NI (-) DB 1.3 Selection And Prioritization Of Modifications The process for selection, prioritization, and communication of station decisions for potential modifications needs improvement.

Some system engineers expressed significant frustration with recent decisions by the PHC/TOS to cancel modifications suggested by the staff.

This could create an alignment gap between station management and the engineering workforce.

The team reviewed proposed modifications screened via the FVR process. Per the procedure, a modification must receive a score of 2 300 points to get funded. The following table shows the distribution among a number of improvement areas for the proposals that received FVR>300 and also for the proposals that received FVR<300.

> 300 points <300 points Nuclear Safety / Equipment Reliability 75% 83%

Radiological Safety 0O/O 4 '/o Industrial Safety 0O/O 4 yo Production/Cost Improvement 10% 0 O/O EP / Security Initiatives 15% 4 '/o Other 0 O/O 5yo The above data suggests that the site rightly places a high priority on Nuclear Safety and Equipment Reliability issues. However, it would also appear that Industrial and Radiological Safety are underweighted in the FVR process.

One voided modification that received significant negative comment was the proposed modification to seal-weld the access covers to the nuclear instrumentation ports in containment. These access covers have been a Page 10 of 54

source of boric acid intrusion to the side of the reactor vessel in the past.

The team recognizes that there may be other alternatives or options to address this issue. However, the system engineer expressed frustration with the decision that was made by TOS without his input.

System Managers were not involved upfront with the TOS modification prioritization (reduction) effort. Some expressed concern about the decisions that were made. The more aggressive system managers will likely ask for reconsideration of canceled modifications by the TOS.

However, less aggressive system managers may just accept the decisions of the TOS without challenge. It is possible that a significant project or modification could get canceled inappropriately.

Recommendations

1. Reevaluate/revise the FVR procedure to include a more balanced evaluation of industrial and radiological safety items.

2. Consider application of the FVR process to a broader scope of items, including projects and other issues that are presented to the PHC.

This would help improve the overall PHC prioritization process.

3. Include system managers upfront in any backlog reduction/issue prioritization efforts in the future.

4. Consider addition of a special coding in the work control system to flag backlog issues identified by the PHC needed to improve system health. Cancellation or rescheduling of these items would require PHC or Senior Management approval, thereby ensuring that the high priority backlog items needed for improved system health are completed.

(Note: the do not cancel designation in work week schedules, and adoption of the BV RIO process, both planned for implementation in the short term at DB, will help and may suffice)

5. Develop a station wide communication strategy for the issue prioritization and backlog reduction efforts. The focus of this strategy should be to gain and maintain alignment between station management and the workforce on this issue.

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Area 2 Ca/cula ti0 ns The teams review included the following activities:

a. Acceptance criteria

b. Questioning attitude

c. Technical rigor

d. Margin management and allocation, propagation of engineering requirements for operation and maintenance

e. Linkages and consistency with other calculations

f. Preservation of design bases g . Docu mentat io n/traceabiIity/att ribut ion

h. Calculation health and improvement process

i. Known process problems and progress in solving

j. Interaction and support from parallel processes

k. Workload management Strength DB 2.1 Internalization Of Engineering Principles And Expectations (EP&E)

The internalization of the EP&E has had a positive influence in reinforcing the role of Engineering as owner of the design basis, as protector of design margin, and in promoting rigor in Engineering processes.

Note: This strength was observed first by the assessors for the Calculation area, and was subsequently noted or confirmed by assessors in the other areas as well. Therefore this strength can be considered a cross-cutting strength.

AFI DB 2.2 Calculation Improvement Program The Calculation Improvement Program is not receiving sufficient management focus to ensure timely completion.

Although the Calculation Improvement Program status report in the DBAR is provided to engineering management, there is no discussion or assessment of progress provided, only item-by-item status. Low management visibility and lack of a summary level discussion could result in overlooking information showing lack of progress .

Relatively few items have been addressed since restart. Most items due in the March - June 2004 time frame have been extended through the end of the year. Many of these items are reporting 0% complete.

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Several due dates indicate Under Review or TBD without indication (in notes or otherwise) of the reasons for not having a required due date.

The goal established for the Calculation Quality Indicator is an average score of 1.0 or less. Actual performance has been better than this goal since February 2004. A more challenging goal has not been established.

Recommendations 1 . Since implementation of this program represents a regulatory commitment, either complete scheduled actions in a timely manner or justify and request a change to the commitment.

2. Evaluate whether the remaining actions under Section 2 Re-Affirmation and Alignment of DB DES Supervision and Staff are warranted/add value and work with the regulators to adjust the plan, if appropriate.

3. Establish a more challenging goal for the Calculation Quality PI.

4. Consider factoring progress on Calculation Improvement Program items when assigning a Calculation Quality window color. (e.g. 90%

or above achievement of scheduled items - Green).

Additional note: The team found information relating to the overall quality of calculations in two different sections of the DBAR: calculations under the Design Basis Health tab, and calculation quality under the Engineering Programs tab. Different individuals are named as owners.

Overall calculation health might be better indicated by taking into account both the quality of current production calculations and also the condition of legacy calculations, with one owner responsible overall.

Recommendation

1. The team recommends taking a more integrated view of calculation health and reporting the result in one section of the DBAR.

NI(+) DB 2.3 Calculation Utility The Calculation Utility has been implemented and is an excellent tool for determining design inputs and outputs for calculations.

Data has been entered and verified for all existing Davis-Besse and vendor-supplied calculations (approximately 22,000).

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Training has been conducted for all DES engineers and some plant and Rapid Response Team engineers. The remaining engineers are to be trained by the end of the year.

A fleet-wide business practice for the Calculation Utility is in final review and should be issued shortly. Other engineering procedures are in the process of being updated to include reference to and use of the calculation utility.

Engineers interviewed use the calculation utility, and find it useful and accurate.

NI (+) DB 2.4 Effective Use of DIE For Calculations The Design Interface Evaluation (DIE) is effective in the process of defining design inputs, acceptance criteria, and outputs/impacts of proposed changes. This process is also required and used for calculations that are not associated with physical changes to the plant (modifications).

Similar processes are used in the industry for modifications, expanding the use of the DIE process to calculation changes provides a mechanism to help improve the quality of calculations and communicate potential impacts of a calculation change to those impacted.

Feedback from DIE process has been beneficial in identifying additional inputs, requirements and impacts.

NI (-) DB 2.5 Lack Of Confidence In System Descriptions There is a lack of confidence that system descriptions provide a consistently focused and reliable source of design basis information.

Some interviewees do not trust the system descriptions for design basis information, stating some design requirements cannot be traced.

Engineers interviewed noted that system descriptions tended to have many pending changes. A number of system descriptions have recently been updated, but the perception remains. Review of a recently updated service water (SW)system description indicates that changes had accumulated for almost nine years and the change incorporated almost 40 outstanding SDCNs. The recently completed SW system description (SD-018) was reviewed by the team for evidence of types of issues noted by engineers during interviews. In general, it appeared well organized and provided a good single source roadmap for design basis information.

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Because of lack of confidence in system descriptions, engineers must search multiple data sources to get accurate design and licensing basis information. A single source roadmap that has the confidence of engineers is needed. (ATLAS may fulfill this function when fully implemented.)

The Team noted that the plans for updating the remainder of the system descriptions (an additional 49) and/or their potential replacement by ATLAS system representations have not been developed Recommendations

1. Determine strategic choice for the Davis-Besse Design Basis Document format and establish a plan for implementation.

2. If System Descriptions have a role in this effort, consider ways address valid user issues to improve the usefulness of the documents and to improve the perceptions of potential users about the reliability of system descriptions. (The current effort to eliminate the backlog of SDCNs is a good start.)

Note: Additional comments developed from this item are presented in NI 5.5 NI (-) DB 2.6 FLEET COUNTERPART INTERACTIONS While some common procedures are in place, interactions with fleet engineering counterparts are limited.

Most engineers (both design and plant) do not know who their counterparts at the sister plants are and interfaces appear to be limited.

Interplant contacts are not routinely considered as a resource. Several system engineers indicated information sharing is casual and a matter of individual initiative for the most part.

Periodic cross-site visits are not required of plant or design engineers.

Note: This NI was observed first by the assessors for the Calculation area, and was subsequently noted as applicable by assessors in the System Engineering areas as well. Therefore this NI can be considered cross-cutting.

Recommendations

1. Establish points of contact with counterparts at sister plants.

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2. Establish expectations for sharing information on system health issues, health managemenVimprovement techniques, and best practices in design and system engineering.

3. Provide opportunities for peer visits and peer review of system health notebooks and system walk-downs, and peer visits in the design engineering disciplines to address commonalities such as calculation techniques, and use of the calc utility.

NI (-) DB 2.7 Margin Management While progress is evident in identification and recovery of low margins in risk-significant systems, planning and more formal guidance for overall margin management is not provided.

There is no procedural requirement to explicitly document remaining margin in calculations. The only global guidance on margin management is found in the last bullet of Section 11. of the Engineering Principles and Expectations booklet: Recover or expand margins that are low.

There is no guidance for achieving an appropriate balance between design and operating margins, or for maintaining or improving operating margins.

There is currently no plan to go beyond identifying low margins in Tier 1 calculation for risk-significant systems. Balance of plant design and operating margins have proven to be issues at other plants.

The Team notes that common objectives for overall margin management and improvement include:

Reduce probability and risk of events Reduce challenges to plant operators during normal operation (allocate margin to operating protocols and setpoints)

Reduce challenges to organization from emergent plant conditions Reduce challenges to organization from equipment aging Support uprate Recommendation 1 . Develop additional guidance for a margin model and direction for implementing a margin management program.

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Area 3 System Engineering The teams review included the following activities:

a. System Health evaluation and reporting

b. Process for prioritizing, communicating, and resolving health deficiencies C. Process for addressing system health deficiencies -- what corrective activities actually get done -- work week survival

d. Equipment Reliability Improvement Program

e. Maintenance Rule system monitoring and trending

f. Restart issues and lessons learned

g. Experience and expertise, including use of operating experience

h. Margin awareness and margin allocation I. Known process problems and progress in solving

j. Interaction and support from parallel processes

k. Workload managem ent NI (+I DB 3.1 System Engineers are Highly Supportive of the Plant Several managers reported exemplary service quality and responsiveness provided by system engineers. (This feedback pertained to support of problem solving and emergent equipment issues.)

System engineers participate or lead problem solving /decision making teams in response to plant problems (There have been -60 problem solving / decision making teams since restart). System engineering representatives participate in shift turnovers and duty team phone calls.

The Plant Engineering statement of duties and responsibilities in NOPL-CC-0002 roles - responsibilities includes Providing technical support to Operations and Maintenance, including technical reviews, assistance in problem solving, planning assistance, work prioritization in addition to responsibilities which focus on longer term system health. System engineers have shouldered a heavy burden in this area.

The organization has come to depend upon system engineers to supply information, typically troubleshooting guidance, that could be supplied by maintenance supervision or troubleshooting procedures. System engineers attention to system health duties may be diverted by these information requests.

Recommendation Page 17 of 54

1. Check and adjust the expectations and practices of System Engineering to share the short term support work load with the RRT, Operations, and Maintenance personnel so System Engineers can provide heightened attention to system health monitoring and improvement.

The Team noted management initiatives in this area which appear to be having the desired effect under the direction of the Duty Teams and as the redefined RRT responsibilities are implemented.

NI (-) DB 3.2 System Health Rating The system health rating process may not provide early indication that system health is degrading.

Generally, the criteria selected to indicate system health are coincident with the consequences that are intended to be avoided. This does not provide a warning of degrading performance prior to reaching the undesirable consequence.

The system color is determined by three major criteria, maintenance rule status, material condition, and operator workarounds. The maintenance rule status is determined by a system going into a maintenance rule a(1) status in the previous monitoring period. This does not provide an early warning that system performance is degrading. More aggressive criteria could be used to indicate degraded performance prior to reaching the a(1) threshold. The three criteria utilized to determine material condition are the number of work orders, temporary modifications and derates caused by the system. The total work order indicator does not take into account the relative importance of the deficiency identified in the work order. This may or may not be accounted for by the system engineers judgment. The derate criteria provides a lagging indication that the systems performance has already impacted production.

Operator burdens and temporary modifications seem to be appropriate leading indicators.

The system health ranking criteria for Freeze Protection/Heat Trace has recently been revised, and is now less stringent (easier to score better system health). This was accomplished by counting only maintenance rule equipment work order backlog and excluding non-maintenance rule circuits from consideration.

Recommendation Page 18 of 54

1. Reconsider the downgrading of the system health scoring for freeze protection/heat trace. The evolution of system health indicators should be in the direction of being more challenging and more anticipatory.

NI (-) DB 3.3 System Health Plan Implementation System health plans and their implementation are not always carried out as planned and scheduled.

Several system health improvement activities for several systems were not accomplished as planned and scheduled. Numerous work order and engineering change scheduled dates slipped. Recently, a 192 hour0.00222 days <br />0.0533 hours <br />3.174603e-4 weeks <br />7.3056e-5 months <br /> auxiliary boiler outage left several planned health improvement activities not done.

Work planners are not regularly apprised by system engineers of the tasks which need to be given priority and retained in work week schedules to improve system health. (The Team noted that several initiatives are planned for near term implementation that will help in this area - labeling system health improvement plan related work orders as do not reschedule in work week schedules, and adoption of the Beaver Valley RIO process.)

System health plans for systems in a yellow or lower condition consists of lists of work orders and ECRs outstanding. The plans generally do not segregate these items into groups necessary to achieve system health progression from yellow to white, white to green, or the dates by which progress to the higher health steps will be achieved. System health plans do not contain additional actions required to effectively achieve the task dates listed, such as obsolete parts issue resolution for affected work orders, and do not illustrate linkages between related tasks to support overall coordination.

NI (-) DB 3.4 Access To Knowledge Of Engineering Information In Calculations Calculation information that is important to engineers knowledge of system design is not readily accessible. Awareness of the engineering requirements for operation and maintenance of systems and of available margin is inconsistent.

Calculations typically contain a significant amount of design information which is important to understanding system operating and maintenance requirements, and to understanding available margin. System engineers Page 19 of 54

should be familiar with the significant calculations supporting their systems. The calculation utility has been implemented at DB but the system engineers have not been trained in its use or provided with the application for their use in identifying and reviewing calculations supporting their systems.

System Descriptions contain system design values but do not routinely identify the calculation supporting that value, relying on other (secondary) sources of that information such as drawings, specs, vendor supplied data, and operating procedures.

Recommendation 1 . Consider expanding availability of the calculation utility to all groups that need access to design information, and especially to expediting access for the System Engineers.

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Area 4 Use of the Corrective Action Program by Engineering The team's review included the following activities:

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

b. Quality of evaluationshesolutions (including use of critical thinking concepts and operating experience)

C. Effectiveness of recurrence control

d. Work management and backlog management

e. Support of corrective actions assigned to others

f. Site to site and multiple plant Condition Reports

g. Root Cause Analyses techniques and management component of cause description

h. Use of Condition Report process for action items tracking

i. Known process problems and progress in solving

j. Interaction and support from parallel processes

k. Workload management The Team was given a draft of the Independent Assessment of Davis-Besse Corrective Action Program Implementation Report (Assessment Number 2004-0100, dated October 21, 2004) for review the second week of the onsite assessment period. The Team confirmed most of the issues in that report as being applicable to the engineering program area.

The Engineering Program Team found that the Engineering personnel were generally prompt in initiating condition reports for identified conditions adverse to quality. Several root and apparent causes produced by Engineering were reviewed and found to be of good quality.

The Team found that corrective action implementation timeliness is an issue in Engineering in that that due date extensions are numerous and relatively easy to obtain. Trending of corrective action program information is generally weak.

Department trending activities are primarily semi-annual Collective Significance Reviews. The Team recognized/agreed with the CAP assessment that an integrated plan is needed for the corrective action backlog as well as for other backlogs such as Engineering and corrective/elective/preventive maintenance.

Where the findings of the Engineering Program Assessment Team duplicated or significantly overlapped the CAP Assessment findings, the findings were not duplicated in this report.

The Team identified an additional Noteworthy Item discussed below (NI (-) DB 4.1).

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NI (-) DB 4.1 Corrective Action Work Burden Individuals who are required to formulate corrective actions sometimes have difficulty obtaining acceptance of the corrective actions by the prospective owner.

Assignment and acceptance of corrective actions was identified as being difficult - especially when assignments cross department boundaries.

Condition report evaluators are required to gain agreement by the individuals accepting the corrective actions prior to making assignments.

Reluctance to accept assignment of corrective actions may be indicative of silos within the organization and a lack of inter-departmental teamwork.

Although this requirement is typical in the industry, management support for this process is needed at DB to reinforce the cross-functional teamwork and collaborative behaviors necessary to achieve orderly assignment and implementation of corrective actions.

Recommendation

1. Provide management reinforcement for prompt acceptance of CAS, and an escalation path when acceptance is not readily forthcoming.

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Area 5 Management Topics The teams review included the following activities:

a. Engineering interfaces Providing design and licensing basis information to others 0 Requests for assistance Problem solving and troubleshooting - roles and division of responsibility Engineering perspective and influence on plant operations and maintenance Engineering support of other processes (work control, technical procedure development, procurement) 0 Engineering information formulation and presentation, receptivity of and interaction with operations, maintenance, and management

b. Programs effectiveness monitoring (including Training & Qualification element)

c. Change management - reorganization, new standards NI (-) DB 5.1 Interfaces With Parallel Processes The expectations for interfaces between Engineering and some site processes havent been clearly defined by management and /or accepted by the engineering workforce.

Differing expectations at process interfaces are demonstrated by the following examples:

The plant work management process owner expects engineering to be effective in meeting due dates for actions necessary to reduce engineering restraints for work items identified at work planning meetings such as T+24 and T+11. Engineering does not seem to have the same expectation and does not always manage to this expectation.

The plant individual responsible for running the work management T+l1 meeting expects the engineering representative attending that meeting to be fully prepared to report status and expected completion dates for all engineering restraints and inputs for all planned work orders. This expectation is essential to accomplishment of the objective of the meeting

- to complete the scope selection decision making and equip all participants with the knowledge of what items are in scope by the end of the meeting. The engineering representative expects he should be prepared to discuss most items but that it is acceptable for him to take action items out of the meeting and provide the required information later.

Page 23 of 54

This expectation also applies to the other work management planning meetings such as T+24, and T+8.

Maintenance planning has incorporated decision points and options into some work plan templates and expects engineering to provide the information needed to support decisions and select options. Engineering expects maintenance planners to provide the needed information based on knowledge the planners should have ready access to. If the options and decisions havent been selected and/or taken at the time of the work week reviews, the scope and work input requirements cannot be known.

The RRT expects Procurement Engineering to perform replacement parts evaluations using the PIE procedure even when some simple document changes are required (work sharing arrangement similar to Beaver Valley). Procurement Engineering expects to perform PIES only when no document changes are required.

Recommendations

1. Develop an interface expectations protocol for use at interfaces between engineering processes and other processes, for use in situations such as:

A new engineering individual is assigned to interface with another process There are known issues requiring clarification at an interface Previously implemented interface expectations can be revised to improve process performance.

2. Use this protocol at interfaces where differing expectations exist, for example at the interfaces with plant work week planning, and procurement engineering ,

NI (-) DB 5.2 Engineering Work Management Tools And Techniques Better engineering performance may be achieved with less effort by adopting work management technology and tools supporting the ability to plan and resource work, anticipate and accommodate challenges to work completion, and to recognize opportunities to improve expected performance.

There is no consolidated work items list and no integrated schedule for completion of engineering work. Assignment listings to the level of individual contributor do not exist for all work except as individuals create and maintain their own assignment lists from information drawn from a variety of sources. Individual engineers report they query sources such as Page 24 of 54

CREST, SAP, DBATS, EWMS, and Curator, as well as keeping notes from discussions with supervisors and meetings to assemble their own work lists. They report the resultant lists are incomplete and cannot be kept current without great difficulty.

Individual engineers work off assignments based on their own lists, but are hampered by the lack of management information such as tasks assigned, priorities, current due dates, appropriately planned task start dates, durations, and work intensity expectations, predecessor and successor logic ties, and ability to anticipate and accommodate problems in carrying out assignments The Engineering Workload Management System (EWMS) is limited to providing a work list and is rarely used. Manloading /levelization/work linkage features are not used. Engineers report their work is reactive to many influences involving late recognition of work assignments and/or untimely communication of assignments and changed due dates. The imposed reactive posture is not conducive to orderly and efficient completion of work.

Some engineering managers relate that they are not ready to make the transition from a bulk work approach to a managed work approach (because the transition is hard to accomplish, the available tools have not been made fully useful, and because they do not see the value of adopting project and work management planning, scheduling, and monitoring tools). The point at which they believe the transition should take place is believed to be a year or so away, and only following deployment of work management tools via SAP.

Recommendations:

1. Establish a strategy for engineering work management to include performance and functional objectives, articulation of roles and responsibilities of department and project managers, supervisors, and individual contributors, and the nature and level of support to be provided by the work management system for these newly defined roles and responsibilities.

2. Select and adopt work management tools for use across engineering that support the following:

o Readily accessible single source work lists for individuals o Prompt communication to individuals of new work assignments and changes to established assignments and schedules o Schedule dates for task starts and finishes Page 25 of 54

o Task linkages for work by a single individual, across individuals within engineering, and for important items, with the plant work schedule.

o Resource loading and ability to identify and mitigate overloads before they impact work execution.

NI (-) DB 5.3 Engineering Backlog Reduction The outcome of the engineering backlog reduction project (future rate of backlog item completion, end date, resource requirements) is uncertain because the work items to be completed are not represented in work plans and schedules.

The Engineering Backlog Reduction Project is not strongly supported by some plant departments. Operations and Maintenance departments participation in system reviews and subsequent backlog item completion is notably absent.

Criteria for maintenance work order elimination does not appear to be well defined. Engineerings support of the Maintenance backlog reduction effort is via the normal work management process, not through a distinct and coordinated set of activities.

Engineering is not using planning and scheduling tools appropriate for a project of the size, complexity, and importance of the engineering backlog reduction project. The corrective action program application (CREST) is used as the default engineering scheduling tool and due dates are not based on manpower availability, which results in numerous due date extensions.

Recom men dat ion(s) 1 . As in interim step, implement simple backlog project scheduling using Microsoft Project or an equivalent simple scheduling tool that supports task resource loading and subtask linkages. Establish milestones or ties to plant work week activities where appropriate.

2. Develop means to integrate engineering backlog reduction and plant backlog reduction.

Page 26 of 54

NI (-) DB 5.4 Human Resource Development Some aspects of human resource development need attention to increase productivity to deal with department workload and to eventually replenish an aging workforce.

The Engineering Backlog Reduction plan assumes the Engineering Department is fully staffed; but currently the design engineering organization has 8-1 0 open positions. Budgeted slots are not back-filled.

Bench strength in specialty areas such as stress and seismic analysis, fire protection, coatings and electric motors is weak. There may be plans to address these areas but they have not been communicated to the workforce.

There has been inadequate training on use of SAP software to fully leverage this technology. Design engineering received minimal SAP training and planners are just now discovering some of the benefits of the software in planning repetitive tasks after receiving additional training.

The recent reorganization assumed certain enablers, one of which is transfer of certain testing and component monitoring activities from System Engineering to Maintenance. Per System Engineering personnel, these enablers have not been fully implemented and there are potentially some key testing and monitoring responsibilities that are currently in question.

Recom mendat io n (s)

1. Consider performing a technical expertise assessment of all personnel in the Engineering organization based on critical skills and likelihood of vacancy over the next 5 years. For positions or critical skills that are at significant risk for D-B, a contingency/development plan should be developed.

2. Perform a training needs analysis in the area of SAP software utilization to identify areas where training could enhance engineering performance.

3. Identify the key enablers associated with the reorganization, specifically for the transfer of certain testing and component monitoring functions from Engineering to Maintenance. Implement actions to address any identified gaps.

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Note: The following Noteworthy Item was added after the Assessment Team left the site, upon evaluation of additional information and discussions with site personnel. A supplemental briefing of DB Engineering management was conducted by phone on Thursday November 4.

NI (-) DB 5.5 Engineering Rigor and Attention to Detail A lack of rigor and demonstration of high standards was noted i n the conduct of some engineering department activities. The teams review of System Description SD-018 Service Water System (Rev. 3), and subsequent review of CR 02-05773 completed in August of 2004, gave rise to items a-e below.

a. Calculation rigor was degraded by some work practices (see discussion in NI 2.5).

Information developed in the discussion section of a CR was incorporated by reference into two revised calculations by listing the CR and providing a summary on the calculations cover sheets. The cover sheet information stated that the information in the original calculation (s) is in error, but that the condition adverse to quality was acceptable with the basis for acceptability being the information presented in the CR.

The information presented in the CR does not appear to have been developed with the rigor that would have been required if the information were developed within the calculation.

Further, the Team is concerned that where the flow rates and screen velocities were previously justified by active calculations (albeit with errors), they no longer are justified by active calculations.

b. The use of engineering judgment is casual and the bases (substantiation and conservatism) for engineering judgment are not documented.

The CR discussion information that was adopted as a reference to the two calculations specifically included reliance on engineering judgment with no indication that engineering judgment was properly used.

C. Some corrective actions fail to adequately address the condition adverse to quality.

The service water system LIR team identified a statement that a condition beyond design is acceptable with no apparent justification. A CR was initiated, Corrective Actions taken, and the CR was eventually closed, with the exact same problem remaining in the system description.

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The condition report written in response to this issue identified two calculations that needed revision. Design engineering accepted action to revise the calculations, and to revise affected documents (presumably including the system description) but decided in August 2004 not to correct the known errors in the calculations or to revise affected documents. Thus the condition reported was not addressed.

d. The disposition of safety related system issues and functions is not rigorous.

In the immediate actions taken/ supervisor comments section of the CR, it was stated that resolution of this issue was a Mode 4 restart restraint and that it involved documentation for a safety-related system. In the response section, it was stated that the function is not safety related, further stating that the condition of the traveling screens has no impact on systems (sp) accident function. There was no mention of the Mode 4 restraint removal. The team believes that the ability of the screens to pass sufficient flow under all conditions would be necessary for the SW system to perform its safety related function.

e. An opportunity to more clearly define and recover margin was missed when the service water calculation mentioned above was downgraded instead of revised and upgraded.

The service water calculations for flow rate and screen flow velocity were noted to not contain acceptance criteria. The service water system is one of the systems identified as risk significant, is known to be low in margin, and designated for efforts to quantify and improve margin. Revision of the flow calculations would have provided an opportunity to calculate the correct flow rates and screen velocities and at the same time establish some form of acceptance criteria and quantify the margin to those criteria.

The Team expects that such quantification would demonstrate significant margin to flow velocity limiting values.

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Area 6 Self Assessment The teams review included the following activities:

a. Aggressiveness in developing and correcting self-assessment findings.

Adequacy, timeliness, and prioritization of corrective actions.

b. Aggressiveness in developing and correcting assessment (internal oversight, Engineering Assessment Board (EAB), and Corporate Nuclear Review Board (CNRB)) findings. Adequacy, timeliness, and prioritization of corrective actions.

c. Receptivity and responsiveness of management and staff to issues raised in self-assessments and assessments Strength DB 6.1 EAB Process The EAB process has provided excellent reinforcement of standards and expectations for newly createdhevised calculations, modifications and other Engineering products.

The EA6 reviews 100% of engineering work products and grades them for content and conformance to standards and expectations. EAB grades are tied to the DBAR measurement of calculation and modification quality.

The review process has provided a level of consistency among engineering disciplines and vendors and provides positive motivation and reinforcement of high standards to those involved in preparing engineering products.

Feedback from EA6 reviews is used by supervisors and provided to all members of their group (not just the preparedreviewer) for use in improving their performance.

Recommendation Consider whether and if so how to reduce the EA6 role and have the line organizations reassume sole responsibility for product quality.

AFI DB 6.2 Utilization Of The Self Assessment Process The Self Assessment Process is not being fully utilized to improve Engineering Perfor mance.

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To date, of the 34 engineering self assessments scheduled for 2004, seven have been completed, ten are pending completion, and 17 have been canceled.

Twelve fleet-wide focused self assessments were originally scheduled for 2004. Ten of these scheduled assessments have been canceled.

The team reviewed 16 self assessments, including focused assessments, ongoing departmental assessments, and collective significance reviews.

The quality was variable. 50% (8) of the assessments were judged to be critical and had appropriate CAS to address the issues. The remaining 50% were judged average (3) or below average (5),particularly in the area of CAS.

In general, the focus of most self assessments has been backwards looking for compliance instead of forward looking toward improvements and higher standards. Therefore, there were few assessments where opportunities for process efficiencies/improvements or higher standards were identified.

The change management associated with the implementation of corporate procedures NOBP-LP-2001 and NOBP-LP- 2004 was inadequate.

Currently, no owner for the self-assessment process exists onsite.

Discussions with site personnel indicate that the owner is now a corporate individual. This individual was interviewed and he recognized the change management issues and indicated that he is actively working to address them in the future.

Recommendati o n(s)

1. Establish site and corporate ownership for the self assessment program.

2. Plan self assessments well in advance to identify which SAs will be performed, who will perform them (identify direct and support requirements), and to coordinate them.

3. Develop a strategy for SAs taking into account factors and considerations such as the following:

Demonstrating compliance with corporate, site, and external requirements and commitments Identifying needs and opportunities for process change to improve quality and business results Identifying areas where enhanced standards would benefit FENOC Integration of self assessment activities Page 31 of 54

4. Consider CARB review of self assessment plans and results to provide a management perspective (as an interim measure)

Page 32 of 54

SECTION 2 Action Plans for Identified Areas for Improvement The Areas For Improvement (AFI) Action Plans contained in this section were developed by the Davis-Besse Nuclear Power Station (DBNPS) in response to the AFls identified in Section 1 by the Independent Assessment team.

The Confirmatory Order assessment provided an independent and comprehensive review of Engineering Programs at the Davis-Besse Nuclear Power Station. The assessment team identified three Areas for Improvement (AFI). These AFls have been entered in the Corrective Action Program. The AFls and the associated Action Plans are presented in this Section. In addition to the AFls, there were several Noteworthy Items documented by the assessment team. These Noteworthy Items have been captured in the Corrective Action Program .

AFI COIA-DB 1.2 - Modification Trackinq and Closure Initiation and closeout of documentation associated with plant modifications are untimely and inefficient.

Action plan:

1. Classify the approximately 550 identified unclassified proposed engineering change requests by the end of Cycle 14. Progress will be monitored utilizing the status of open engineering changes monthly through the monthly Performance Report and quarterly through the Design Basis Assessment Report (DBAR).

2. The long term solution to the current less than adequate tracking of engineering change status between issuance to the field and return to engineering for closure will be addressed through the inclusion of engineering changes into SAP. This will provide a common platform for managing the design as well as the implementation stages of engineering changes and provide improved monitoring of the engineering change progress. This change will be completed by the end of the fourth quarter 2005.

3. The planning organization has placed additional focus on processing through for closure the engineering changes that are essentially field complete. The actual status of the approximately 57 identified engineering changes requiring closeout will be confirmed and dispositioned properly by the end of the second quarter 2005. In the interim, Operations will re-review these open engineering changes to ensure no adverse impact to safe plant operations by Page 33 of 54

February 28, 2005. The total number of engineering changes issued for implementation will be monitored monthly through performance indicators included in the Monthly Performance Report.

4. A future revision of NOP-CC-2003, Engineering Changes, will include a common engineering change close-out process. This revision is currently in progress through the fleet engineering programs manager and is expected to be issued by the end of the fourth quarter 2005.

AFI COIA-DB 2.2 Calculation Improvement Proaram Calculation Improvement Program is not receiving sufficient management focus to ensure timely completion Action Plan:

1. The Calculation Improvement Plan is updated on a quarterly basis through the Design Basis Assessment Report (DBAR). Several enhancements to the DBAR will be made, these changes include:

a) Improve the DBAR report content to include an overall trend and summary to focus management attention to problem areas. This report content change will be made in the 1" quarter 2005 DBAR.

b) The current status of the calculation improvement plan will be reviewed against the recent level of calculation quality. Due dates will be reconfirmed and rebaselined and adjustments will be made as necessary and the plan will be updated in the ISt quarter 2005 DBAR.

AFI COIA-DB 6.2 Utilization Of The Self Assessment Process The Self-Assessment Process is not being fully utilized to improve Engineering Performance.

Action Plan:

1. FENOC Fleet ownership for Self-assessments has been established

2. Engineering efforts will be focused to better utilize the Self-Assessment process in regards to planning and completion of self-assessments. The 2005 Self-assessment focus areas and owners have been identified and Page 34 of 54

submitted for approval. There are Fleet engineering self-assessments being scheduled for 2005. These assessments would include Davis-Besse.

3. During the next revision of Business Practice NOBP-LP-2001, FENOC Focused Self-Assessment Process, enhancement opportunities and integration of overall assessments will be evaluated for inclusion. This revision is expected to be completed by March 31, 2005.

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Appendix 1 FENOC submittal FENOC Davis-Besse Engineering Assessment Plan ASSESSMEN?' AKEAS:

Engineering program effectiveness of modifications, calculations, system cnginccring, corirctivc action program utilizdtion, ;tiid selected additional areus, 1'L; HPOSE:

The purpose is t o provide an independent and comprehensive asscssincnt of the Enginccring prograin effectiveness 31 the Davis-Besse Nuclear Power Station. ?'hc assessment will be perl'orined i n accordance with the requirements o f the blarch 8, 2004, Confiiinatoi-y Order Modifying License No.NPF-3, and Davis-Bessc Business Practice Di3~3P-VP-00(19,hlanngement Plan for Confirmatory Order lndcpcndcnt r\sscssmcnts.

'I'he ;issessitieiit will be used to identify areas for improvement, requiring corrective xtions w i t h action plans. The assessmcnt will also be used to assess the rigor, criticdity, and over;ill quality of' available Davis-Bcssc intci-nal self-asscssrnent activities i n [he Enginccring program arcas listed above.

SCOPE:

The Inclependent Assessmcnt Team will assess the following Engineering program ;area:

I . Plant Modification process

2. Ca I c u I ;it i o n process

3. Systcrn Enginccring 4, Coirectiw Action Program (CAP)

5. Additioniil ~ ~ l c c t careastl

6. Effectivcncss of self-assessments Thc Asscssmcnt Team will ;ISSCSS conduct of the following xtivities:

1. t'lnnt hlodification Process l'hc temi will pcdorm a review of cictiviiies to assess t h e effectivcncss of the plant inodification proccss:

il . Selection and prioi-itization of potential modifications

13. Efficiency of' the modification proccss (graded approach, at risk changes)

c. Owner acceptance sub-process (review of contracted work)

d. Quality of modific:ttion packages C. Closcout of modification packages and supporting documcnt updates

f. Effectivcncss of modifications i n fixing known problems

?. Known process problems and progress in solving tl . Inrclaction and support from parallel proccsses I. Workload managcmcnr Page I of 5 Page 36 of 54

FENOC Davis-Besse Engineering Assessment Plan

2. Calculation process The Learn will asscss the following attributes of the plant calculation prciccss:

a. Acceptance criteria

b. Questioning attitude c . Technical rigor

d. hlargin management and allocation, propagation o f enginccring requircments for operation and maintenance

c. Linkages and consistency with other c;iIctil;itions f'. Preservation of design bases

s. Document at i on/traceabi I i I y/a[tri buti o n

h. Calculation health and irnprovcmcnt proccss

i. K n o w process problems and progress in solving J- Interaction and support from p;iraIlcl proccsscs k . Workload manageincnt

3. System Kngineering h-ograrns and Pr;ictices

'T'tic tenin will in\.cstigntc the following ilerns:

a . Systcm 1 lealth cv;ilu;itiori and reponing

h. 1)roccss for prioritizing, communicating, and resolving health deficiencies c . Process for addressing system health deficiencies -- what corrective activities actually get done -- work baeek surviyal d . Equipmen[ Rcliability Improvement Program

c. Maintenance Rule systcrn monitoring iind trending

!. Iiestar-t issucs and lessons Ieamcd

g. Expwience ;[rid expertise, including use o f olxxiting experirnw h . hfnrgin awareness and margin allocation i . Known process problems and progress in solving

j. Intcraction and support from parallel processes l i . Woi.kload managcment

4. Iniplenientatioii of the Corrective Action process by Engiiirering I'hc tcarn will ~ S S C S Sthe following:

I. Ev:iluntc the impact of thc backlog and backlog trend on organizstional and operntional effectiveness

11. Quality of' e\,aluations/resolutions (including use of critical thinking concepts a n d opcrating cxpcricncc)

c. Eflcctiveness uf recur-rcncc control

d. Work rniaringement and backlog managcinent

e. Suppon of coi-rective actions assigned to others 1'. Site to site and multiple plant Condition Kepoits Pagc 2 of' 5 Page 37 of 54

FENOC Davis-Besse Engineering Assessment Plan

g. Koot Cause Analyses techniques and management component of causc descrip tiori

h. Use of Curidition Report process fur action iterris tracking

i. Known process problems and progress in solving

j. Intcraction and support from parallel proccsses

k. Workload nianagcmcnt 5 . Other Arras

a. Eriginccring interfaces Providing design and licensing basis information to others Rcquests for assistance Problem solving and troubleshooting - roles and division of responsibility Engineering pcrspcctive and influence on plant oper;ttions and mai ntcnancc Engineering support of other processes (work control, technical proccdurc development, procurement)

Engiriccring information fonnulation and presentuiion, reccpti\*ityo f and interaction with operations, maintcnancc, arid rnan;igcmerit

b. Pr.ogrnms effectiveness monituring (including Training & Qualification elerricnt)

c. Change management - reorganization, new standards

6. Effectiveness of Davis-I3esse Assessment Acti.iritics The Assessment Team will evaluute the cffecliveness o f [he Davis-Bcssc Nuclear Power Plants ;isscssmcnt iictivities associated with the implementation of Enginccring, prO~al1S:

a. Aggressiveness in dcvcloping and correcting self-assessment findings. .i\clcquacq, timeliness, and prioritization of corrcctivc actions.

b. Aggrcssivcncss in developing arid conecting assess men^ (intcrnal o\usipli1, Enginccring Asscssment Board (EAB), and Corporate I\uclcar Rcvicw Board (CNRB)) findings. Adcquacy, timeliness, and prioritization of coircctive actions.

c. Kcccprivity and responsiveness of management and staff LO issues raised i n sclf-asscssmcnts arid assessnients John Gamty, Marathon Consulting Group, Team Leader Paul Borer, h.l;irathon Consulting group i[arold Baurnbcrgcr, Maralhon Consulting Group Bradley Adnms, Sire Engineering Director, Byron Nuclcar Station, Exelon Nuclear John Ivlcyer, Design Engineering Analysis Munager, Comanchc Peak, TXU Energy Toni Vine, Manager, Engjncering Prograins, Duane Arnold Energy Center Pagc 3 of 5 Page 38 of 54

FENOC Davis-Besse Engineering Assessment Plan Junc 9 through J u l y 7, 3,004, devclop, review and submit asscssment plan io NRC.

J u l y 12. 2004, scnd selected documcntation to team members to begin off-site prepara [ions.

Octobcr 10, 2004, assessment team will assemble at the plant lor final assessirient preparations.

October 1 1 - 22, 2004, conducl onsite assessment and providc Diivis Bcsse with prcliiiiinai-y results prior to leaving sitc.

Final team assessment report will be provided to Davis-Besse within 14 days after thc complction of the on-sire assessment.

Firinl Davis-Ucsse assessment report and action plans (if rcquircd by findings) will he subniitted to the N R C within 1 5 days of the completion of the on-site ,i~xssincnt. ..

,mxsswwi'i w r i 10~)s:

The Independent Assessment Team will use DBDP-VP-0009 "Management Plan for Confii~inatoryOrder Independent Assessment" 3s the basis for conducting the '1;:5sessment.

Thc iisscssnient tncthodology m;iy include, but is not limitcd to, any coinbination of the fo 1 lo \v i np:

Observing activities In e r v ie wi ng pcrson ne1 R c v i cw i ng doc utnc n t ;I t i on Evaluaring or performing [rend analysis Reviewing procedures, instriictions, and programs Comparing actual IierI'onnance levels with pre-established performance indicators

'I"he following geneid standards will apply to the asscssinerit of Davis-BesseEngincci-ing prosiwn impleincntntion:

Modification and culcularions rcllecl in-dcpth reviews of problems and rcsolurions that support a high level of nuclear safety.

Engineers denionstratc knowlcdge and understanding of the dcsign basis.

including maintcnancc o f design basis docurnenkition.

System cnginccrs demonstrate intolerance for failures of critical cquipmcnt.

Etigincci's maintain clear ownership of corrective actions from iniliation through I-esoluti on.

\I rigorous appro;ich to problem solving and application of engineering procedures and methods is used.

The assessnient team will review the rcfcrcnccd procedure/docurncnts during the preparation period prior to si tc m i v a l .

Page 4 of 5 Page 39 of 54

FENOC Davis-Besse Engineering Assessment Plan Confirmitory Ordcr dated March 3, 2004 DBRP-L'P-0009 "M;inagerncttt Plan for Confirmatory Ordcr Independent Assessrncnt" NOP-CC-2003, Engineering Changes NOP-CC-3002, C;iiculntions NOP-LP-2001, Condition Report Process Past NKC inspection reports (CATI, RRATI) thal are applicable to the ;!rea assessed Past applicable Self-Assessmcnts QA quarrcrly assessments for past three quartcrs CKRR niccting minutes from last three CNRB inrervals.

Applicable Section or ;ire;i Pcr-t'ormance Indicators l{alpti Haisen, Executive Sponsor Page 5 of 5 Page 40 of 54

Ind epe rid ent En gin e erin g A s s e ss me n t P 1a 11 Assessors and Qualifications (6 p:tges to follow)

Page41 o f 5 4

John Ii. Garrity President and Chief Executive Officer (CEO)

Marathon Consulting Group 1994-prcscnt: M a r - d i o n Consulring Group; Prcsidcnt and CEO - Rcsponsiblc for Marathon client servicc operations, and selected personal consulting engagements. Engaged i ~ expcrti consulling i n the area of proccss performance monitoring and improvement, managcmcnt mentoring. process ccntercd team formation and compensation, configuration managcincnt, busiitcss plan and corporate strategy development, process improvement training, and projcct management training. Also conducted root cause arid collective significance analyses of client situations, and participated or lend high impact teams to resolve problems.

1993-1994: Ncw York Pmver Adzor-iq; Resident Manager - Placed in charge after unit was shut down under NKC confirmatory action letter and on problcrn plan1 lis[. Responsible for developing and executing plan to resolve problems in conkst of intense political pressure and company senior management turnover. Numerous escalated cnforccmcnt actions from actions of earlier periods mitigated by cffcctivc, aggrcssivc managcnient invcstigations and coriecrive actions.

1992: TVA Bcllcfonie;Sitc Vicc Prcsidcnt - Responsible l'or all ongoing acli vities necessary to rc:ictivale the projcct from dcfcrred s1atu.s.

1990-1902: TVA, IVurts Bar; Site Vice President - Responsible for all activities necessary to progress complction of thc Watt's Bar units, including enginecring, construction, startup, operational readiness, and commissioning. f?ormulatcd nianagernent objectives for restart of construction following stand down and significant regulatory involvcmcnt. Rccngincering of design cngineering and construction processes. restart of construction, outsourcing construction labor, engineering, and management. Instituted management performance accountability through sitc widc sclf-monitoring program, based on principles of TQM.

Significant improvcmcnt of sitc nuclcar pcrforinancc, Icft sitc positioncd for succcssful completion. Credibi I it. w i t h NRC rcstorcd. S igni ficant proccss performancc i niprovcmcn t rcsults in cnginccring design, cnginccring analysis, construction cnginccring, construction, and corrective action.

r Assistant to Presidenl - Spccial projects assignment, 1990: Muirie Yurtkee Arovlic P o i r ~ Co; including work on low Icvcl waste disposal options a\railablcLO company and state.

1989-1090: ibfairie Yunker Arowic Power Co; Vice President Engineering and Licensing -

Respoitsible for nuclcar engineering, plant engineering, licensing, and operations support 1988- 1989: ,\fui/~eYuriket' h u m i c Po\i:rr Co; Assistant \!ice President Engineering and Qualily Programs - Rcsponsiblc for quality assurance, nuclear cnginccring, licensing and pI :in t cngi n eerin g .

1984-1985: M a i m Ymtket h m i c Power Co; Plant Managcr/Scnior Sitc Manager -

Rcsponsiblc for site operations.

1953; Maiirt. Yuitkee Aloinic Power Co; Assislant Refucling Manager - Spccial assignment, monitored several dozen engineering projects and coordinated activity w i l h overall refueling eff'ort.

19S0-19S4: Muirw Ynnkee Aioniic Power Co; Director, Nuclcar Enginecring and Licensing -

Rcsponsiblc for ovcrall coordination of reload dcsign, plant safcty analysis and nuclcar engineering analysis of plant systems, emergency planning, and radiological monitoring.

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PauI J. Borer Consultant Marathon Consulting Group 2002-prescnt: Mararliori Cunsrcltr'ngGroup - Performed Safety Culture and Engincering Effectiveness Assessments.

0 1986-2002: Otsrircm U ~ N U G ~Power ~ L V Operations (INPOI-Held the following positions:

- Senior Representative for Assistance - Management consulting roIc. Responsible for formulating performance improvement plans for sevcral nuclear stations. Provided direct feedback to scnior station management on perfoiniancc issues. Prioritized deploymen1 of INPO assistance resources.

- Division Director, Plant Operations Division - a technical INPO division responsible for evaluation of Operations, Chemistry, and Radiation Protcction areas. Involvcd in setting standards for evaluations, responsible for the evaluator training program, and assisting the industry in attaining standards of excellence,

- Detroit Edison Vice Prcsidcnt - Nuclear Generation (On - loan from INPO 1997-1998)

Responsible for all aspects of Operation, Maintenance, and Engineering of a large scale RWR. Igd a plant staff of approximately 500.

- Vice President, Nuclear Engineering - New York Power Authority (On - loan from INPO 1993-1994). Responsible for Dcsign Engineering at two nuclear generating stations. Dcvcloped and irnplemcnted a plan to deploy corporale design engineering rcsourccs to the stations i n order to be more responsive to station needs.

- Depnrtmcnt Manager - Managed four INPO departments (Emcrgency Preparcdness, Operating Experience Applications, Technical Support, and Operations) - Responsible for the evaluation of their respective areas of plant performance and various assistance programs. Also functioned as aTearn Manager and lead teams of 15-30 INPO and industry professionals during performance-based nuclear plant and corporate evaluations.

Held a Senior Reactor Opcrator's License Boiling Watcr Reactor and Licensed Professional Enginecr - Mechanical.

1985: O1'yineering. Planning and Mamgeinerir, fnc.;Project Manager - Responsible for the o\walI conduct of work, sales, budget, schedule, clicnt relationship, and quality of products for EPM clients i n thc Southeastern U.S.

1983-1984: Smith Burney, Harris L'pkurn, on0 Conzpuny; Account Executive - Responsible for retail sccurities srtlcs, cticnt dcvclopmenl, securities research, financial planning advice.

1976 1983: Cooper Aruoleul- Sration; Served in various management positions, all reporting to the site manager. (Operations Managcr, Engincering Manager, Chemistry and Radiation Protection Manager) 1970-1976: U. S. Navy; Coniplelcd the Naval Nuclear Power Training Program and served aboard a nuclear submarine.

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Harold E. Rusty Raumberger Iice President arid Direcfor, Performalice Assessnient Marathon Consulting Group 1996-present: Muruthon Comitltirtg Group; Responsibilities include the following:

- Vice President and Director, Performance Assessment - Responsible for business areas of independent assessment, INPO evaluation and NRC inspcction suppoi-t, Design Basis assessments, and Maintenance Rule implcmcntalion. Also scrvc as Marathons Quality Assurance Managcr.

- Executive Lead, Transition for the Vermont Yankee Nuclear Power Corporation -

Managcd thc impleinentation of the sale agreement and transition of the Verinont Yankee station to new ownership. Rcportcd directly to the President & CEO.

- Quality Assurance Managcr - Developed and implemented Quality Assurance Program, obtained NUPIC certification, trained and certified lead auditors. Providcd interface with client QA Managers.

- Configuration Management Supervisor at Cooper Nuclear Station - Worked in environment of high regulatory scrutiny to improve Engineering performance and develop recovery strategies. ResponsibIe for maintaining Design Basis and resolving Design Basis and Configuration Control issues. Managed Modification Process. Design Criteria Program, Equipment Classification Program, Equipment Data Pile, and Drawing Conlrol Program.

- Served as a Safety System Functional Evaluation tcam member in thc area of Operalions at Denver Valley - Reviewed the 4kV Electrical Distribution and Emergency Diesel Generator systems for Unit 2.

- Providcd cxpcrt consulring related to INPO-related issues ut River Bend - Participated in major assessment covering the new INPO Performance Objectives, existing INPO findings, and items from the Long Term Performance Improvement Program.

~ Participated in a component-level design basis review of non safety-relaid systems and outage work at Dresden - Documented review of over 7000 components against Design Basis, FSAR requirements, original system and component specifications, and vendor-supplied data.

- Performed assessment of Design Basis programs at Vermont Yankcc including Design Basis document program development.

- Pitrticipated on corporate Engineering Independent Safety Assessment Response Team at Maine Yankee.

1990-1996: Irrdepedeent Corurtltartr; Provided services to nuclear utilities and Department of Energy (DOE)contractors in management, safety review, quality assuriincc and performance areas. Performed audits and independent assessments of overall performance, outage management, maintenance and configuration management programs.

1988-1990: Liberty CorisrtlfirigGroup; Senior Consultant - Led evaluations of management capability at nuclear power plants in all areas of facility opcration. Conducted assessment of pIant performance against NPO standards.

1980-1988: lmtirufe of N i d c a r Power Operations (lAP0); Evnluator/Senior Evaluator -

Performed evaluations of more than 50 commercial nuclear power stations in areas of Miiintcnance. Engineering Support, and Organization and Administration. Participaied in accreditation reviews of utility training programs.

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Bradley J. Adams Site Engineering Director Exelon Nuclear Corporation 2003-present: E,relotz - Byron NucZear Station; Site Engineering Director - Provide overall proactive management of the site engineering function including Systems Engincering, Dcsign Engineering, Engineering Programs, and Information Technology. Accountable for site engincering department budget, short-term and long tcrm staffing, dcvclopment, compcnsation, and related human resource needs for 95 assigned employees. Participate as a key station manager in the business planning and performance review process including integration with the overall Exelon business planning process. Manage the execution of contracted M E services as they pertain to the site enginecring function.

2002-2003: Exelon - Byroiz Nucleur Sfnriort;Superintendent of Elcctrical / ZSrC ivlaintenancc

- Direct rnanagemcnt of thc Electrical Maintenance and Instrumentation RC Control Maintenance Departments at the Byron Nuclear Station. This included 22 management pcrsonriel and 73 reprcscnted personnct in the 2 departments.

7,000-2002: Exelori - Ryrori Nitclsur Stutiort; System Engirteering Manager - Responsible for I

direct management of the 40-person System Engineering organization. Succcssf~ilin devcfoping and implementing state of the art performance centered mainteniince templates for Byron Station and the Exelon Nuclcnr Fleet.

Exelm - flyrun Nuclear Sratiart; licgulatory Assurance Manager - Managed thc ntei+acc for Byron Station with the U.S. Nuclear Regulatory Commission, Illinois Department of Nuclcar Safety, OSHA, Illinois and Federal EPA, and other regulatory agencies. During this period, assigned to key position with the Merger Intcgration Team 10 f'xilitate year-long effort to merge the former CornEd and PECo utilities into thc Exelon Corporation. This effort included evaluation of assets, managcmcrit o f governance and oversight structurc, and other key attributes of merger activities.

1995-1998: &elon - Bymii Nucleur Station; Staff Engineer - Dcsign Enginccr in the Mech:mical Support Group of the Byron Site Engineering organimtion. In previous years was responsiblc for imylemcntation of various process improvements to increase efficiency and improve quality of the engineering products delivered by the depanment. Involved in proactively increasing the knowledge base of personnel throughout the ComEd nuclear division by assisting the Nuclear Training Departmcnt in the dcvclopmcnt and prcscnlation of various continuing education classes.

1991-1994: CornEd Corporate Regtilatory Assurance; Licensing Engineer - Scrved as Generic Licensing Specialist in the Nuclear Engineering & Technolbgy Services Depattment. Was responsible for hclping ensure regulatory consistency between ComEd's six nuclear generdting stations. Also responsible for generating major technical licensing submittals from CornEd to the USNRC.

1983-199 1: CoinEd Corporate Nuclear Fuel Services; Design Engineer - Qualified Nuclear Design Engineer. Promoted twice within ComEd's Nuclear Fuel Serviccs Department to Design Group Leader with responsibility for direct supervision of eight engineers performing engincering design analyses for ComEd's entire fleet of 6 prcssurizcd watcr reactors.

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,JohnW. Meyer Design Engineering Analysis Manager TXU Power Comanche Peak 2OO3-prcsent: Conzaidie Peak Steam Eiectric Srariun (CPSES);Design Enginecring Analysis Manager - Founding Manager of a unit i n the Technical Support Department at Comanche Peak Steam Electric Station (CPSES). Responsible for rnaintcnance of the CPSES Design and Licensing Basis, design revicws, adverse condition report engineering resolution, industry operating event research and resolution, emergent opcrational problem resolution, consultation, engineering human performance, and the CPSES design control program. Provides analytical support for CPSES in such areas as radiation analysis, control room habitability, systems interaction, environmental barriers, thernial/hydraulic analysis, loss of ventilation analysis, tornado venting, electrical calculations, and civil/structural analysis.

1998-2003: CPSE3; Engineering Analysis Managcr - Managed a multi-disciplinccl staff of Consulting and Senior Engineers in the Reactor Engineering Department responsi ble for analytical support of CPSES in such arcas as radiation analysis, control room habitability, systems interaction, environmental barriers, thcrmal/hydraulic analysis, containment analysis, loss of ventilation analysis, and tornado venting. In addition, managed the efforts of the Risk and Reliability Supervisor. The Risk and Reliability group was responsible for maintaining the CPSES JPE and IPEEE and for 311 plant PRA and Risk assessnient activilics.

1996-1998: CPSES; Design Basis Engineering Supervisor - Responsible for maintenance of the CPSES Dcsign and Licensing Basis, Mastcr Equipment List maintenance, design reviews. adverse condition report engineering resolution, industry operating event research and resolution, emergent operational problem resolution, and implementalion of rcengincered electronic processes for design control and corrective action programs.

1992- 19%: CPSES; NSSS and HVAC Systems S u p e n h r - Responsible for Design Engineering support on CPSES Nuclear Steam Supply System, HVAC, and Fire Protection Systems. Supervised a senior staff of engineers to provide design modification engineering, temporary modification engineering review, adverse condition report engineering resolution, industry operating event research and resolution, and einergcnt operational problem rcsolution.

1987-1992: CPSES; Principal Engineer - Staff Assistant to the Manager, Plant Engineering at CPSES. Founding membcr of Operations Support Engineering, formed to provide immediate design engineering support to CPSES Operations during transition from construction to Unit 1 operation. NSSS expen assigned to the Primary Plant Systems group of the on-site CPSES corpornle engineering department.

1974-1987: Westingltouse Electric Corporation; Senior Project Engineer - Served as Nuclear Systems Engineer in the CPSES site office. Senior Field Service Engineer - Performed field services at operating and construction PWR projects. EngineedSenior Engineer B -

Responsible for schedule control of II major subcontractor on the Clinch River Breeder Rcactor Plant.

1969-1973: 17, S. Nczvy; Completed Naval officer nuclcar power training qualifying for supervision, operation. and maintenance of Naval Pressurized Water Rcactors. Assigned to a Sturgeon Class Nuclear Attack Submarine.

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Thomas V. Vine Engineering Programs Manager Nuclear Management Company 1991-present: Nitcleur Maitcrgenient Conipmzy, D i m e Arnold Energy Center; Positions held include the following:

- Manager, Engineering Programs - Responsible for implementation of lhe following plant programs: Prcdictive Maintenance, Preventative Maintenance, A S M E Code Compliance, Welding, Non Destructive Testing, In Servicc Inspection, In Service Testing, Motor Operated Valves, Air Operated Valves, Maintenance Rule, Thermal Performance, PRA EQ and Fire Protection. Direct reports include two Supervisors and 20 Program Engineers and Analysts, Additional responsibilities include Program Owner for the Engineering Programs, Technical Training Program.

- Project Engineer, Spent Fuel Storage - Responsible for the design and construction of an Independent Spent Fuel Storage Installatjon (ISFSI)licensed under IOCFR72. Directly responsible for oversight of Architecflngineers for TSFSI and plant security modifications as well as on-site contractors performing design, licensing and construction activities for the project. Also provided technical input into procurement and fabrication of components required for dry spent fuel storagc.

- Supervisor, Radwaste - Responsible for oversight and supervision of the Radwaste Department which is responsible for liquid processing, solids processing, wet waste disposal, cask handling, packaging and shipping of radioactive materials. Direct reports include twclve Radwaste Operators and two Health Physicists. Additional responsibilities include serving as a member of the plant Operations Committee, Program Owner of the Radwaste Training Program as well as being a member of the ASMFJEPKI Radwastc Subcommittee. Significant accomplishments: Spent Fucl Shipment in support of GE Nobel Chein fuel analysis. Innovative watcr processing tcchnology such as UV/Ozone organics rcmoval system. Aggressive program to evaluate reduced resin dosage on condensate filter demineralizers. Implementatiori of new design pleaied filters in condensate filler demineralizers to improve Feedwater iron control.

- Pnncipitl Engineer, Systems Engineering - Responsible for oversight of the following systems: Cranes, Radwaste (processing and shipping), Structures, MVAC, Aux Boiler, Reactor Recirculation, Additional responsibilities: Heavy Loads Coordinator, Project Leader for various major maintenance activitjcs. Significanl accomplishments:

Engineering support for Fuel Pool Re-rack Project. System improvements to Aux Boiler, LLRPSF HVAC modifications that solved long-standing temperature control problems. Project Leader for Recirc Pump Seal replacement to AECL CAN-2A scals.

19S8-1991: CPU Nctcfear, O y r e r Creek; Sr. Engineer, Plant Engineering - System Enginccr for Lifting 6t Handling, Socondary Containment, standby Gas Treatment, and Balance of Plant HVAC. Supervised project to replace 72" 16,000 LBS. bunerfly valves in circulating watcr system utilizing innovative rigging techniques. The project involved design and filbricaiion of devices that allowed movement of valvcs over numerous obstacles. Provided engincering interface for first US installation of ABB Wet-Lift system in a BWR.

Supcrvised major maintenance procedure upgrade projcct.

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Appendix 2 Personnel interviewed Allen, Barry Laurer, Tim Andrews, Doug LeBlanc, Guy Bair, Dick Loehlein, Steve Barron, Nate Marley, Jim Barteck, Gabe Matranga, Gene Bennett, Eric McCloskey, Pat Blakely, Dennis Meckfessel, Diane Boles, Brian Michael, Greg Bor, John Migas, Andy Browning, Kevin Moore, Connie Chimahusky, Ed Mugge, Bill Dallas, Dave Murtha, Matt Davis-Zapata, Ricardo Nassar, Dirul Dejong, Bill Nelson, Mike DeMaison, Brad Osting, Steve Dominy, John Ostrowski, Kevin Dunn, Karen Parker, Mike Duquette, Dale Patrick, Randy Dutkiewicz, Mike Pavlick, Mark Gherian, Ted Pierson, Jim Giese, Fred Plymale, Scott Grabnar, John Reineck, Brad Haley, Dan Ridlon, Tim Hansen, Ralph Rinkwoski, Elaine Harder, Lynn Rupp, Chuck Hartigan, John Saunders, Scott Hawley, Chuck Schrauder, Bob Hengge, Craig St.Clair, Tracy Hennessy, Brian Stevens, Mike Hiss, Tom Straube, Peter Hook, John Strumsky, Craig Horvath, Eric Sturdavant, Joe Hovland, Bob Swim, The0 Hruby, Ray Wahlers, Dave Jacobson, Peter Whalen, Doug Johnson, Eric Widner, Mike Kendall, Joe Zatco, Annalisa Koziel, Mark Zellers, Kevin Kremer, Dale Zurvalec, Frank Laird, Greg Page 48 of 54

Appendix 3 Documents reviewed The following list indicates the documents collected for review by the Independent Assessment Team. Some document titles were changed to support organization of the documents within the ftp site library, or to make the titles more indicative of the contents. The sequence of documents is not continuous, because the ftp site library contained documents not applicable to the Davis-Besse independent engineering assessment. Only the Davis-Besse engineering assessment related documents are listed.

A number of INPO documents were reviewed at the site. These documents remained in the control of FENOC personnel and were obtained under non-disclosure agreements. These documents are not individually listed.

Related to Document category and name Topic INPO reference material Material returned under confidentiality and non-disclosure agreement INPO reports on FENOC Material returned under confidentiality and non-disclosure agreement Assessment reports and plans Davis-Besse Corrective Action Program (CAP) Program DB Review Summary Report CA Program readiness Baseline Assessment Package for DB Calculation Control Program CALC Davis-Besse Plant Modification Program Review DB Summary Report MOD DB Corrective Action Assessment Plan 4 wrk SA Focused Self-Assessment Report Davis Besse DB Engineering Organization Readiness For Restart SA DB Operations Performance Assessment Plan DB DB CNRB 04-15-04 Mtg Minutes CNRB DB DB CNRB 11-20-03 Final CNRB DB DB CNRB 07-17-03 Rev CNRB DB DB QA 1st Qtr 04 Assessment PI DB DB QA 3rd Qtr 03 Assessment PI DB DB QA 4th Qtr 03 Assessment PI DB DB Quality Trend Summary-03Q03 PI DB DB Quality Trend Summary-03Q04 PI DB DB Quality Trend Summary-04QO1 PI DB 13.031 DB Engineering Assessment Plan Page 49 of 54

Related to Document category and name Topic 13.031a DB Engineering Assessment Plan (MS Word DB version) 13.031b DB engineering assessment plan docketed final DB version DB 13.033 Calculation Cotlective Significance Review 13.034 Assessment of Davis-Besse Calculation Program DB SL-008171 Calc PY 13.035 PY 2nd Q 03 DES Self Evaluation 576DES2003 SA DB 13.046 DB DBAR 1Q 04 B&W3 DBAR 13.047 SA2004-0096 Reconciliation of Installed DB Condition far ARCS SA DB 13.048 SA2004-0088 Post Fire Circuit Failures SA DB 13.049 SA2004-0087 Technical Training Comp SA SA DB 13 050 SA2004-0061 ATLAS Phase 1 SA SA DB 13.051 SA2004-0047 Use of PEFs wrt CRs SA DB 13.052 SA2004-0020 AOV program SA DB 13.053 SA2004-0015 PM roles Resp training Benchmark SA DB 13.054 SA2004-0004 work week performance review SA DB 13.055 QA 2nd Qtr 04 DB 13.056 CNRB 7-15-04 RO CNRB DB 13.059 DB 2nd quarter 2004 DBAR files DBAR DB 3 060 DB PHC Minutes, 2004-05-13 PHC minutes DB 3.061 DB PHC Minutes 2004-07-08 PHC minutes DB 3.062 DB PHC Minutes 2004-07-22 PHC minutes DB 3.063 DB PHC Minutes 2004-08-12 PHC minutes DB 3,064 DB PHC Minutes 2004-08-26 PHC minutes DB 3.065 DB PHC Minutes 2004-09-09 PHC minutes DB 3.066 DB PHC Minutes, 2004-04-08 PHC minutes DB 3.067 DB PHC Minutes, 2004-04-22 PHC minutes DB 3.068 DB PHC Minutes, 2004-05-27 PHC minutes DB 3.069 DB PHC Minutes, 2004-06-24 PHC minutes DB 3.070 DB PHC Mtg Minutes 7-15-04 RO PHC minutes 3.071 DB EAB first quarter report 2004 - Final as signed EAB and DB 5-1 1-04 EAB PI 13.072 DB EAB Final second quarter report 2004 20- EAB and DB 04 EAB PI DB 13.073 DB Design Engineering CSSA SA DB 13.074 DB Plant Engineering CSSA SA DB 13.075 DB Procurement Engineering CSSA SA DB 13.076 DB Project Management Section CSSA SA DB 13.077 DB Quality Trend Summary-2004QO1 CAP Page 50 of 54

Related to Document category and name Topic DB 13.078 DB Quality Trend Summary-2004Q2 CAP 13.079 DB RCA report-collective sig - Plant Mods DB Program Concerns Mods DB DBAR 2nd quarter 2004 DBAR Engineering and Relevant Fleet Procedures NOBP-LP-2001 FENOC FOCUSED SELF-fleet ASSESSMENT SA fleet 14.0011 NOBP-LP-2001 Rev3 SA DB DBBP-NED-0002 DB Engineering Assessment Board EAB 14.0021 DBBP-NED-0002 DB Engineering Assessment DB Board EAB fleet 14.005 NOBP-LP-4003A 50.59 guide fleet 14.006 NOBP-LP-4003B 50.59 mentoring comm fleet 14.007 NOBP-LP-2002 benchmarking fleet 14.008 NOBP-SS-4001 Change mgt fleet 14.009 NOBP-LP-2006 collective significance rev fleet 14.010 NOBP-CC-2003B Conceptual design pkg MOD fleet 14.01 1 NOBP-CC-2003 Config mgt data control fleet 14.012 NOBP-LP-2008 Cor Action review brd CA fleet 14.013 NOBP-LP-2007 CR effectiveness review CA fleet 14.014 NOBP-LP-2009 CR process ref guide CA fleet 14.015 NOBP-LP-2010 CREST trending CA fleet 14.016 NOBP-SS-3401 document hierarchy fleet 14.017 NOBP-CC-7002 enhanced procurement fleet 14.018 NOBP-ER-1004 fleet value rating FVR fleet 14.019 NOBP-LP-2001 focused self-assmnt SA fleet 14.020 NOBP-SS-2101 peer groups fleet 14.021 NOBP-ER-3002 plant health comm Plant Health fleet 14.022 NOBP-CC-2003A Prelim cost est fleet 14.023 NOBP-CC-3002 Processing calcs Calc fleet 14.024 NOBP-CC-7001 Procurement pkgs 14.025 NOBP-ER-1002 proj approval resource fleet association fleet 14.026 NOBP-CC-2003C Proj team fleet 14.027 NOBP-LP-2011 root cause analysis guide CA fleet 14.028 NOBP-CC-2003D walkdowns MOD fleet 14.029 NOP-CC-3002 calculations Calc fleet 14.030 NOP-LP-2006 CNRB CNRB fleet 14.031 NOP-LP-2001 CR process CR fleet 14.031a NOP-LP-2001 Rev 7 CR fleet 14.032 NOP-ER-3001 decision making prob solving fleet 14.033 NOP-CC-2002 design input MOD fleet 14.034 NOP-CC-2004 design reviews MOD fleet 14.035 NOP-CC-2001 design verif MOD fleet 14.036 NOP-CC-2003 Engineering Changes rev4 MOD Page 51 of 54

Related to Document category and name Topic fleet 14.037 NOP-CC-2003 eng changes MOD fleet 14.038 NOPL-CC-0001 eng principles- expectations fleet 14.039 NOP-ER-1001 eq perf imprvmt ERlP fleet 14.040 NOPL-ER-0001 eq reliab policy statement ERlP fleet 14.041 NOP-LP-4003 eval of test changes experiments fleet 14.042 NOP-CC-7002 procure mnt eng fleet 14.043 NOPL-CC-0002 roles - responsibilities R&R fleet 14.044 NOPL-LP-2003 SCWE policy SCWE fleet 14.045 NOPL-LP-2005 self-assessment policy SA fleet 14.046 NOP-WM-2001 work mgt process EWMS DB 14.047 DES EAB Policy-DEP-0001 EAB DB 14.048 Risk Desk Guide-RO Guide fleet 14.049 NOP-CC-3002-02 Rev 2 Calc Addendum Calc fleet 14.050 NOP-CC-3002-03 Rev 0 Post It Note Calc fleet 14.051 Procedure Hierarchy Proc 14.052 Mgt Plan for Conf Order Assessments Rev 1 DB DBBP-VP-0009 SA Enqineering program documents Davis-Besse Nuclear Power Station Operational DB Improvement Plan Operating cycle 14 DB DB Calc Improvement Plan DB Engineering Work Plan fleet Design Programs Hierarchy 15.007 DB Plant Engineer responsibility list SORT BY DB DESCRIPTlON DB 15.008 Eng Program List and owners Enqineering work products DB 16.016 DB modlist mod list DB 16.017 DB CALCs greater than 2004-01-01 calc list NRC reports Approval to restart Davis-Besse, closure of CALI Restart DB confirmatory order Order DB lnsp Rpt CAT1 03-010 IR DB lnsp Rpt RRATI 04-004 IR IR, Sys DB lnsp Rpt Sys Health 02-013&02-014 Health DB lnsp RptEng&Main Backlog 03-024 IR Confirmatory DB EA-03-214 Docket 50-346 Confirmatory Order Order DB 17.007 DB NRC inspection summary-1 IR summary DB 17.008 DB NRC Routine lnsp ending 040522 DB 17.009 DB NRC Routine lnsp ending 070702 DB 17.010 DB NRC lnsp RPT on Mods and 50.59 General Procedures DB Management Plan for Confirmatory Order Assessments Page 52 of 54

Related to Document category and name Topic fleet Focused self assessment process NOBP-LP-2001 SA fleet focused self assessment cbt MlSC 1275 SA Organizational Charts and Contact Lists fleet FENOC org chart ORG DB Davis-Besse org chart (OOD) ORG fleet 20.003 FENOC Hagan org 040517 ORG fleet 20.004 FENOC SrMgtTeam 040517 ORG fleet 20.01 1 FENOC orgl JulO4 ORG fleet 20.012 FENOC org2 JulO4 ORG fleet 20.013 FENOC 0rg3 Jul 04 ORG fleet 20.014 peer groups ORG DB 20.01 8 DB Org Chart-1 0-04-Distribution Performance Indicators DB 21.001 DB DES CR Workload PI DB 21.002 DB DES CA Workload PI DB 21.003 DB DES DC Development PI DB 21.004 DB DES DE Backlog Workoff PI DB 21.005 DB DES Qual of Eng Wrk Products PI DB 21.006 DB NED CR Workload PI DB 21.007 DB NED CA Workload PI DB 21.008 DB NED DC Development PI DB 21.009 DB NED Qual of Eng Calcs PI DB 21.010 DB NED Qual of Eng Wrk Products PI DB 21.01 1 DB PES CR Workload PI DB 21.01 2 DB PES CA Workload PI DB 21.013 DB PES Main Rule SS Re1 PI DB 21.014 DB PES Qual of Eng Wrk Products PI DB 21.015 DB PRS CR Workload PI DB 21.01 6 DB PRS CA Workload PI DB 21.01 7 DB RRT CR Workload PI DB 21.01 8 DB RRT CA Workload PI DB 21.019 DB RRT DC Development PI DB 21.020 DB RRT Qual of Eng Wrk Products PI DB 21.027 apri12004 db mpr MPR Fleet 21.030 february2004 fleet mpr MPR Fleet 21.031 january2004 fleet mpr MPR DB 21.033 march2004 db mpr MPR DB 21.043 DB june 04 draft mpr MPR DB 21.052 DB july2004mpr MPR DB 21.053 DB august2004mpr MPR DB 21.054 DB event history report event history DB 21.054a DB Events - abridged event history 21.055 DB Open Eng CRs-CAS (as of 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> 10-1 DB 04) CAP DB 21.056 DB Plant Health Report (2nd Quarter 2004) Plant Health Page 53 of 54

Related to Document category and name Topic Action Plans fleet 22.001 Action Plan Heading Legend Action Plan fleet 22.002 FENOC Business Plan[l] Action Plan fleet 22.003 fleet efficiency action plans Action Plan fleet 22.004 material condition action plans Action Plan fleet 22.005 outage performance action plans Action Plan fleet 22 006 people develop action plans Action Plan fleet 22.007 safe plant ops action plans Action Plan DB 22.008 DB Calc Imp Plan Action Plan Page 54 of 54