ML043650173
| ML043650173 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/06/2004 |
| From: | NRC/RGN-III |
| To: | |
| References | |
| Download: ML043650173 (125) | |
Text
1 1 PUBLIC MEEING 2 BETWEEN THE USNRC O350 PANEL 3 AND FIRST ENERGY NUCLEAR OPERATING COMPANY 4 OAK HARBOR, OHIO 5 - - -
6 Date and Time: Monday, December 6, 2004 6:00 p.m.
7 Place: Davis-Besse Administration Building 8 Energy Education Center Oak Harbor, Ohio 9
Reporter: Marie B. Fresch 10 Registered Merit Reporter Notary Public, State of Ohio 11 12 PANEL MEMBERS PRESENT:
13 U.S. NUCLEAR REGULATORY COMMISSION 14 Steve Reynolds Acting Director of the Division of Reactor 15 Projects in Region III John "Jack" Grobe 16 Senior Manager, Region III Chairman O350 Panel 17 Christine Lipa Projects Branch Chief 18 Christopher Scott Thomas Senior Resident Inspector 19 Gene Suh, Section Chief NRR 20 FIRST ENERGY NUCLEAR OPERATING COMPANY 21 Mark Bezilla, Vice President 22 Barry Allen, Director Site Operations Bob Schrauder 23 Director Performance Improvement Steve Loehlien 24 Manager Nuclear Quality Assessment Ray Hruby, Manager Nuclear Oversight 25 Marie B. Fresch & Associates 1-800-669-DEPO (3376)
2 1 MS. LIPA: Okay, good 2 evening. I would like to welcome FirstEnergy and 3 members of the public for accommodating this meeting 4 tonight. This is a public meeting between the NRC's 5 Davis-Besse Oversight Panel and FirstEnergy Nuclear 6 Operating Company.
7 My name is Christine Lipa and I'm the Branch 8 Chief in NRC's Region III and I'm responsible for the 9 NRC's Inspection Program at Davis-Besse.
10 We're talking about the purpose of this 11 meeting on the next slide, and mostly to keep the public 12 informed of the ongoing NRC activities, and discuss with 13 the Licensee their performance and some activities they 14 have planned; and then also NRC activities, recent and 15 upcoming; and then also be available to answer any 16 public questions or address any comments.
17 The next slide shows the agenda. And we'll be 18 covering, I'll be covering introduction and opening 19 remarks and the NRC's activities. Then, we'll turn it 20 over to the Utility for them to discuss recent 21 performance. And, then, what we'll do is adjourn the 22 business portion of the meeting, but we'll still be 23 holding a meeting to have comments and questions from 24 members of the public.
25 What I would like to do first of all is start Marie B. Fresch & Associates 1-800-669-DEPO (3376)
3 1 off with some introductions at the NRC table here.
2 We've got to my far left over here is Steve Reynolds.
3 Steve is the Acting Director of the Division of Reactor 4 Projects in Region III. He's also in transition to 5 become the Chairman of the Davis-Besse Oversight Panel 6 by the end of the year.
7 To my left is Jack Grobe. He is the Chairman 8 of the Davis-Besse Oversight Panel currently, and will 9 be transitioning to Steve.
10 Scott Thomas to my right is the Senior 11 Resident Inspector at the Davis-Besse facility.
12 And to Scott's right is Gene Suh. Gene is a 13 new member of the panel. He replaces Tony Mendiola.
14 Gene is the Section Chief in NRR, and he's responsible 15 for licensing actions at Davis-Besse and several other 16 Region III plants.
17 Also, NRC folks that are here today. We have 18 Jan Strasma, our Public Affairs in the back. Jan.
19 We have Nancy Keller. She's our Office 20 Assistant at the Davis-Besse office and she was helping 21 with the handouts.
22 We also have the two Resident Inspectors, Jack 23 Rutkowski and Monica Williams.
24 Then, Mr. Bezilla, if you want to introduce 25 your folks.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
4 1 MR. BEZILLA: Good evening.
2 Thanks, Christine.
3 To my far right is Steve Loehlein, Director of 4 Engineering here at Davis-Besse.
5 To my immediate right is Barry Allen, my 6 Director of Site Operations.
7 To my far left is Ray Hruby, Manager of 8 Nuclear Oversight.
9 And to my immediate left is Bob Schrauder, my 10 Director of Performance Improvement.
11 And, also, in the audience we have Jeannie 12 Rinckel, who is our Vice President of Oversight, 13 transitioning into position February 2005. Jeannie.
14 Okay. And we have Joe Hagan, Senior Vice 15 President of Engineering in Technical Support.
16 And Gary Leidich, President and Chief Nuclear 17 Officer for FENOC.
18 MS. LIPA: Okay, thank you.
19 I would like to talk a little bit more about 20 this meeting, and of course it's open to public 21 observation, but it is a business meeting between the 22 NRC and FirstEnergy, so we'll wait until the conclusion 23 of the business portion to take comments from members of 24 the public, but we'll be available for comments and 25 questions during that Q and A session and then after the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
5 1 meeting.
2 I would like to talk a little about the 3 handouts that we had today. There are several. The NRC 4 has handouts that are in the blue, and then FirstEnergy 5 has handouts as well on the back table.
6 We also have a NRC Public News Update that we 7 use to provide current information on recent and 8 upcoming NRC activities, that also has good contact 9 information on how you can reach us and get to the 10 website.
11 We also have a Public Meeting Feedback form 12 that you can use to provide comments to us on how this 13 meeting goes today.
14 We're having this meeting transcribed today, 15 and to maintain a record of this meeting and that 16 transcription will be available on our website within 17 about three to four weeks.
18 The next slide talks about some recent NRC 19 activities. The first one is the NRC Triennial Fire 20 Protection Baseline Inspection. That was held about a 21 month ago. That report has been issued. And the 22 results were fairly positive. And there was one 23 inspection finding from that report.
24 The second bullet is the Service Water 25 Inspection. That was held the first week of October.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
6 1 And that also, there were no findings coming out of that 2 inspection, and they found that the Generic Letter 8913 3 Program to be in good shape at Davis-Besse.
4 Third bulletin is a inspection that has been 5 completed, but the report is not issued yet. That is a 6 supplemental inspection for the NRC Performance 7 Indicators that we use to indicate performance of the 8 Alert and Notification System, which are also known as 9 the sirens.
10 And so the, the sirens have all been -- they 11 did have a failure of the sirens back in May. The 12 condition has been corrected. They were tested 13 successfully several times. The only issue remaining is 14 how to count some of those failures and successful tests 15 when computing the Performance Indicator, and that 16 report should be out in a few weeks.
17 November 16th, we had a public meeting out in 18 the Perry area, and it was actually to discuss with 19 FENOC corporate management and site management their 20 plans for improvement of performance of all three of the 21 FirstEnergy sites; Perry, Davis-Besse, and Beaver 22 Valley.
23 And then November 9th was the beginning of a 24 Team Inspection that we have to look at the Licensee's 25 Corrective Action Program, the implementation of that Marie B. Fresch & Associates 1-800-669-DEPO (3376)
7 1 program. And there will be a separate inspection report 2 issued in January.
3 The next slide talks about the some of the 4 Confirmatory Order Activities. We previously discussed 5 these. We have four areas that are covered by the 6 Confirmatory Order; and there have been, there are four 7 plans that have all been submitted and two of the 8 reports have now been submitted to us; and I understand 9 that the engineering report is due today, so we'll be 10 evaluating that as soon as we get it.
11 The Safety Culture one is still ongoing. And 12 that, we should expect that report to be issued in 13 January.
14 The next slide talks about some other upcoming 15 NRC activities. I mentioned earlier that Steve Reynolds 16 will be taking over for Jack Grobe as the Chairman of 17 the Panel, and they have been transitioning and 18 discussing issues so that Steve is current on all the 19 matters on Davis-Besse.
20 Also, I already mentioned the Problem 21 Identification and Resolution Inspection; that's another 22 word for looking at the Licensee's Corrective Action 23 Program.
24 Then, I'll turn it over to Scott Thomas to 25 talk a little bit more about the Mid-Cycle Outage Marie B. Fresch & Associates 1-800-669-DEPO (3376)
8 1 Inspections.
2 MR. THOMAS: During the 3 Mid-Cycle Outage, additional Region-based specialists 4 will evaluate the following areas. First, the Upper and 5 Lower Reactor Vessel Head Inspections, Pressurizer 6 Penetration Nozzle and Steam Space Piping Connections 7 Temporary -- TI or Temporary Instruction, and the 8 Evaluation of Licensee's Steam Generator Tube Inspection 9 Activities.
10 The Resident Inspectors will continue to 11 monitor day-to-day activities on-site. Significant 12 portion of our time will be spent in Containment, 13 walking down equipment systems not normally accessible 14 by the operator.
15 MS. LIPA: Okay, thank you.
16 That's all I have.
17 I'll turn it over to you, Mr. Bezilla, for 18 your part of the presentation.
19 MR. BEZILLA: Thank you, 20 Christine.
21 And, good evening.
22 Our Desired Outcomes for tonight are first to 23 demonstrate that Davis-Besse's operations continue to be 24 safe and conservative; and, second, to status you on the 25 Confirmatory Order Independent Assessments, that being Marie B. Fresch & Associates 1-800-669-DEPO (3376)
9 1 actions taken and planned for the Operations Assessment; 2 and, second, the areas for improvement and actions taken 3 and planned in regard to the Corrective Action Program, 4 Confirmatory Order Independent Assessment.
5 Not on this meeting's agenda, but probably for 6 the next meeting, we will be prepared to discuss the 7 Engineering Performance Assessment and the Safety 8 Culture/Safety Conscious Work Environment Confirmatory 9 Order Independent Assessment.
10 Steve is prepared to briefly overview the 11 results of the Engineering Assessment, if we have time 12 and if you would like.
13 Next slide, please.
14 Tonight, we will cover the following items:
15 Plant Performance or noteworthy items since the last 16 public meeting; actions taken and planned for the areas 17 for improvement from the Operations Performance 18 Assessment, areas for improvement and actions taken and 19 planned for the Corrective Action Program Assessment, 20 the results and actions taken and planned from our 21 recent internal Safety Conscious Work Environment Survey 22 and an overview of our recent Safety Culture Assessment, 23 a brief look at our backlog reduction efforts, a 24 discussion on our Mid-Cycle Outage, actions taken and 25 planned to ensure a successful Outage, and finally, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
10 1 discussion by Ray presenting his Oversight Sections 2 Perspective.
3 Before I turn it over to Barry, I would just 4 like to make a few introductory remarks. In regard to 5 our momentum and sense of urgency, I've reflected on 6 this, and I also worry about our momentum, our drive to 7 improve our performance and reduce our backlogs.
8 What I see is a team that's focused on 9 improving its performance and is committed to turn our 10 backlogs into workloads, that being steady state 11 workloads.
12 I'd liken it to we're running a marathon, and 13 we're pacing ourselves, okay, which is different than 14 the effort that was expended during extended shutdown, 15 where we were sprinting, or at least it seemed like we 16 were always sprinting.
17 I and this team, we'll ensure that we continue 18 to improve and work our backlogs into a steady state 19 workload condition and that's currently forecast to be a 20 reality come the spring of 2006.
21 In regard to Operation's performance, we 22 continue to have some lower level, minor, or no 23 consequence errors; and even though these things, even 24 though they're minor, it's troublesome. All right.
25 We have taken steps to reduce the probability Marie B. Fresch & Associates 1-800-669-DEPO (3376)
11 1 of errors and mistakes, and you'll hear more on that 2 from Barry little later in the presentation.
3 Operator Performance is an area where we 4 observe and monitor fairly frequently. We'll continue 5 to watch this area closely, and we'll work to strengthen 6 our barriers; that being individual performance, 7 procedure quality, supervision, and oversight; to 8 further reduce the chance of errors; and, if errors do 9 occur, to mitigate the consequences of those errors.
10 In regard to our Corrective Action Program, 11 you will hear Bob talk about our Confirmatory Order 12 Independent Assessment on the Corrective Action Program 13 in detail. That team said our Corrective Action Process 14 was marginally effective.
15 The Corrective Action Process is the tour 16 engine we use to identify, prioritize, and solve 17 problems. It consumes much of our resource and time and 18 it's critical to our future.
19 We have and will continue to improve our 20 program and our people's ability to use the tools.
21 We're confident in our people's commitment to use the 22 Corrective Action Program to capture and solve problems.
23 We will continue to focus and improve our performance in 24 this area.
25 In regard to our recent internal Safety Marie B. Fresch & Associates 1-800-669-DEPO (3376)
12 1 Conscious Work Environment Survey results, we saw a 2 reduction in the number of positive responses to some 3 questions and in some sections. Follow-up on these 4 survey results is very important for us and for me.
5 Our desire is to have a robust Safety 6 Conscious Work Environment atmosphere where our team 7 feels free and unencumbered in regard to raising issues 8 and concerns. The results indicate that our people are 9 willing, our willingness to identify and raise issues 10 and concerns remains strong. And that's a good thing.
11 However, there are areas in which we need to focus 12 management attention.
13 I'll speak more on this a little bit later in 14 the presentation.
15 In summary, we've got a lot of work yet to do.
16 And looking in total, I believe both the plant and my 17 staff have performed pretty well since restart.
18 With that, I would like to turn it over to 19 Barry.
20 MR. ALLEN: Thank you, Mark.
21 My objective tonight is to demonstrate that 22 the operation of Davis-Besse continues to be safe and 23 conservative.
24 Per plant status, Davis-Besse station is at 25 100 percent power generating approximately 925 megawatts Marie B. Fresch & Associates 1-800-669-DEPO (3376)
13 1 electric. We are at 121 continuous days of safe and 2 conservative operations. And we're currently at 60 3 consecutive Human Performance success days.
4 Next slide.
5 Now, I would like to briefly mention some of 6 the more noteworthy items that occurred at the station 7 since our last public meeting.
8 The second of our four Confirmatory Order 9 Independent Assessment on the Corrective Action Program 10 implementation completed during this time frame, and as 11 Mark said, Bob Schrauder will cover this later in detail 12 in the presentation.
13 Also, as Christine mentioned, the NRC 14 inspection of our Service Water System. This was a very 15 good and thorough inspection with no findings that 16 demonstrated strong system engineering ownership of that 17 program.
18 We also conducted our Annual Safety Conscious 19 Work Environment Survey the week of October 4th, which 20 Mark will discuss in more detail later in the 21 presentation.
22 Next slide.
23 The Confirmatory Order Independent Assessment 24 of Engineering Program Effectiveness was performed in 25 October and we are submitting the final report to you Marie B. Fresch & Associates 1-800-669-DEPO (3376)
14 1 today.
2 On October 11th through the 13th, nuclear 3 oversight personnel conducted Safety Culture, Safety 4 Conscious Work Environment interviews with station 5 personnel, and Ray will discuss those interviews later 6 in his presentation.
7 Also on October 15th, we conducted a 8 successful Emergency Plan Drill to qualify several newly 9 assigned emergency response organization team members.
10 And, in that exercise 23 of 23 objectives were met.
11 Then, on October 18th, the Nuclear Oversight 12 issued their Third Quarter Continuous Assessment Report, 13 which Ray will also discuss later in his presentation.
14 Next slide.
15 On October 25th, we had an NRC inspection of 16 ALARA, Access Control, and NRC Performance Indicators; 17 and in the Exit on October 29th, no potential violations 18 or findings were identified.
19 And during the same week, the NRC performed a 20 special inspection of our Alert and Notification System 21 Performance Indicators, and your inspection team asked 22 us some very good questions, which caused us to reflect 23 and resubmit our data to you. And in retrospect, we 24 believe we should have initially submitted the indicator 25 as white, with subsequent discussions regarding the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
15 1 data.
2 On October 25th and 26th, we conducted our 3 Annual Safety Culture Assessment and Mark will discuss 4 the results of the annual assessment later in his 5 presentation.
6 And then on October 29th, we achieved full 7 compliance with the NRC Security Order.
8 In the first week of November, we met an 9 important milestone in completing the NRC Baseline 10 Inspection; and then our Independent Assessment of 11 Safety Culture, Safety Conscious Work Environment began 12 with interviews, surveys, and observations in November 13 and that team is off assessing that data right now with 14 the initial report projected to be issued to us on 15 December 21st.
16 Then, on November 12th, we held a Fleet Review 17 of our Mid-Cycle Outage Readiness and I'll discuss our 18 Mid-Cycle Outage Readiness later in the presentation.
19 Also, the week of November 15th was our NRC 20 Licensed Operator Requalification Inspection. And while 21 there were no potential violations or findings 22 identified at the Exit, the team did leave us with 23 several opportunities for improvement.
24 And, also, currently, the NRC Problem 25 Identification and Resolution Inspection of our Marie B. Fresch & Associates 1-800-669-DEPO (3376)
16 1 Corrective Action Program is in progress, with the first 2 of the three weeks completed last Friday.
3 Next slide.
4 Some of our key upcoming 2005 events include 5 our January Mid-Cycle Outage, which you will be here to 6 observe, our Graded Emergency Preparedness Exercise in 7 May, and others as listed on the slide.
8 Okay. So, in conclusion, operation of 9 Davis-Besse continues to be safe and conservative.
10 MS. LIPA: I had a question 11 for you. Back on slide 7, you talked about the October 12 18 Nuclear Oversight Third Quarter Assessment Exit. Do 13 you plan to get into any more detail later in your 14 presentation?
15 MR. ALLEN: Yes.
16 MR. BEZILLA: Yes.
17 MR. ALLEN: Okay, next 18 slide.
19 Now, we will provide an updated status of our 20 Independent Assessments.
21 Next slide.
22 Three of the four Independent Assessments have 23 been completed with the Engineering Program 24 Effectiveness Assessment Report being submitted today.
25 The Independent Assessment Team for Organizational Marie B. Fresch & Associates 1-800-669-DEPO (3376)
17 1 Safety Culture is still underway, as I mentioned 2 previously. I will update you regarding some of the 3 actions we've taken in the Operation's performance area 4 since our previous meeting; and then Bob Schrauder will 5 discuss the Corrective Action Program Implementation 6 Assessment in detail tonight.
7 We will discuss the Engineering Program 8 Effectiveness and the Organizational Safety Culture 9 Independent Assessment at the next public meeting.
10 MS. LIPA: With respect to 11 the Safety Culture Assessment, what's the actual 12 schedule for completion of that assessment?
13 MR. ALLEN: December 21st is 14 when we are supposed to get the initial report.
15 MS. LIPA: Okay.
16 MR. SCHRAUDER: Right, they have 17 completed gathering their data for that assessment.
18 They're currently in the process of evaluating that data 19 and they intend to Exit with us on December 21st, on the 20 findings from that assessment.
21 MS. LIPA: Okay. Then, the 22 report will be submitted 45 days from the Exit?
23 MR. SCHRAUDER: That's correct.
24 MS. LIPA: Okay, thank you, 25 Bob.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
18 1 MR. ALLEN: Okay. At our 2 last public meeting, I discussed the scope and results 3 of the Operations Independent Assessment in great 4 detail. Tonight, I would like to discuss a few of the 5 key areas for improvement and some of the actions we 6 have completed since our previous public meeting.
7 In the area of Work Management Interface, we 8 have communicated details of the work scheduling process 9 to Operations personnel to help them more fully 10 understand how the scheduling process should function.
11 We've also reviewed routine Operations 12 activities for inclusion in the work implementation 13 schedule to do a better job of scheduling our Operations 14 resources.
15 We're also ensuring we have licensed operator 16 representation at routine work scheduling meetings.
17 In the area of procedure back logs --
18 MR. GROBE: Barry, excuse 19 me. Before you go on, could you specifically describe 20 what the finding was in the area for improvement in work 21 management interface?
22 MR. ALLEN: Yes, Jack, I can 23 get that. Okay, Jack, this is area for improvement.
24 It's resolve operators misunderstanding about work 25 scheduling and improve the quality of work scheduling.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
19 1 So, some misunderstanding, not clear 2 understanding of how the work scheduling process works 3 and the inputs that go into it. And improve the quality 4 of the work scheduling; we worked it out, such as 5 ensuring we schedule, I'll call it, lower level 6 monthly-type activities, and then ensuring that we have 7 operators involved in the scheduling meetings.
8 MR. GROBE: Was the specific 9 concern there that Operations activities or Operations 10 workload wasn't being properly managed with what might 11 be the nonroutine Operations workload, meaning routine 12 activities and nonroutine activities were not being 13 properly managed; is that the issue?
14 MR. ALLEN: Jack, I believe 15 it was probably like a combination of things. First, 16 maybe being that throughout the organization, there was 17 not a common understanding of what the function of the 18 schedule was. Operations leads the station; however, 19 one of the tools that we utilized to ensure that we're 20 safe from a core damaged frequency perspective is to 21 provide that input into the schedule and then perform a 22 risk assessment of that schedule.
23 And, so, not all personnel within the 24 department understood how that schedule was developed; 25 or understood that Operations input was solicited into Marie B. Fresch & Associates 1-800-669-DEPO (3376)
20 1 that scheduled development. And, so, there was some 2 knowledge weaknesses there, if you will, that we felt we 3 had to address with the operators.
4 In other activities, we felt that although 5 minor, I do impact resources available, and therefore we 6 felt like we should schedule a finer level of detail, up 7 to and including say end of shift briefs, those kind of 8 routine shift activities or monthly activities.
9 MR. GROBE: Have you seen a 10 difference in day-to-day operations interfaced with 11 scheduling activities as far as the outcome? What 12 change in behavior have you seen?
13 MR. ALLEN: The greatest 14 benefit that we've seen, Jack, is having the SRO's 15 involved in the scheduling process, because they do 16 bring insights into station operations that other 17 individuals may not be as fresh on. And, so, it's the 18 ability, I believe, for the Operations organization to 19 lead the organization is the greatest benefit that we 20 see from that.
21 MR. GROBE: Okay. Thank 22 you.
23 MR. ALLEN: In the area of 24 procedure backlogs, we have reviewed the procedure 25 backlog for priority and safety significance. After Marie B. Fresch & Associates 1-800-669-DEPO (3376)
21 1 doing that, we also developed a backlog reduction plan 2 which will address the operations procedure backlog by 3 the end of Cycle 14. Then, we have allocated additional 4 resources to be assigned to the procedure backlog 5 reduction initiative.
6 MR. GROBE: Barry, why was 7 it necessary for the independent team to identify this 8 issue?
9 MR. ALLEN: Jack, we have 10 tracked our backlog throughout the year. One of the 11 things that we did early in the year was, we looked at 12 the largest areas of the our backlog; and two of the 13 areas we identify as seeing most burdensome to the 14 station were the engineering backlog and engineering 15 maintenance backlog; and we saw those as, I guess I 16 would say, formidable challenges for the organization to 17 work through. So, we set up teams to go address those 18 specific backlogs.
19 As we track and trended our backlog through 20 the year, what we observed was we were not making as 21 much progress in the area of procedures as we had 22 desired. And, so, we had just essentially looked at 23 laying out a plan to address the procedure backlog as we 24 have the other areas.
25 But we have been tracking our backlog on a Marie B. Fresch & Associates 1-800-669-DEPO (3376)
22 1 weekly basis and fully aware of what our backlog is, 2 what's trending down, which areas we were not making as 3 much progress in.
4 MR. GROBE: Okay. So, you 5 had a plan at that time to reduce this backlog prior to 6 the independent assessment?
7 MR. ALLEN: We had a 8 proposal, that Operations had developed and presented to 9 me. We worked on that. And then it was presented to 10 Mark, I think it was under the Vice President and my 11 review at that time. We had been working on that plan 12 for several weeks, within the Operations Department.
13 MR. GROBE: Are there any 14 other areas of backlog where there is not a management 15 plan in place yet to deal with it?
16 MR. ALLEN: Yeah. We also 17 have -- well, we also have a concerted effort being 18 initiated in the condition report backlog area; and then 19 of course we're working to integrate that with 20 procedures.
21 MR. BEZILLA: Jack, I think 22 we've got all the areas covered. I think Bob will cover 23 that a little bit later when he talks about the 24 Corrective Action Program Assessment; and one of the 25 things that he asked us to do was integrate the various Marie B. Fresch & Associates 1-800-669-DEPO (3376)
23 1 backlog efforts that we have; and Bob will talk briefly 2 about that.
3 MR. GROBE: There is no 4 other surprises though; simulator modifications, 5 training backlogs, what else is out there that we're not 6 aware of?
7 MR. BEZILLA: I think we've 8 got them covered.
9 MR. GROBE: Okay.
10 MR. THOMAS: Make sure I 11 understand. The goal is to integrate this, all the 12 backlogs under one process or program that you're going 13 to head up, Bob?
14 MR. SCHRAUDER: That's right.
15 We'll take all of the efforts that are currently 16 underway for backlog reduction and show how they all fit 17 together and integrate those processes together or those 18 reduction backlogs.
19 MR. REYNOLDS: I have a 20 question, to start off with. I think where you answered 21 Jack's questions on the reduction plan, your slide 22 implies that it was done as a result of your independent 23 assessment and you said you already had plans in place.
24 You had -- it wasn't because an assessment.
25 So, my question goes to the next symbol down; Marie B. Fresch & Associates 1-800-669-DEPO (3376)
24 1 additional resources assigned. Is that because of the 2 independent assessment or is that because of some other 3 factor?
4 MR. ALLEN: Steve, we were 5 laying out our plans to address the Operations procedure 6 backlog; and we want a specific plan with here's where 7 we are, here's our goals, here's our targets, here's the 8 resources it will require.
9 When the independent assessment came through, 10 it all, the fact that we weren't making headway got 11 captured in the Independent Assessment; so, it just 12 happened to be coincidental, if you will.
13 MR. BEZILLA: See, Steve, 14 initially, we were looking to see if there would be 15 better internal resources to work on that project versus 16 external. And after we did that assessment, which was 17 I'll say, in parallel or shortly after this effort, we 18 decided to go external. And some of the external folks 19 we brought in here were ex-Davis-Besse SRO-type 20 individuals who we think will do a good job for us in 21 this effort.
22 MR. REYNOLDS: I think I 23 understand your answer. Better way to ask my question; 24 if you didn't have the Independent Assessment, that 25 didn't happen, these three sub-bullets, would you have Marie B. Fresch & Associates 1-800-669-DEPO (3376)
25 1 went ahead and done it anyway? You always had those 2 actions to go forward?
3 MR. BEZILLA: Yes, this helped 4 solidify our belief that we needed to do that.
5 MR. REYNOLDS: All right, thank 6 you.
7 MR. ALLEN: In the area of 8 Corrective Action Program Backlog, we have reviewed all 9 open condition reports and reviewed all open 10 preventative and remedial corrective actions for 11 priority and safety significance within operations. And 12 as we discussed, resolution of these items will be 13 integrated with the resolution of Corrective Action 14 Program Backlog within the procedure backlog reduction 15 effort. And Bob spoke to that briefly just a moment 16 ago.
17 Then, we talked about routine tasks in several 18 of the public meetings. In the area of routine tasks 19 performance by Operations, a few things I just wanted to 20 mention tonight. We scheduled end of shift crew 21 critiques to identify and address all equipment and 22 Human Performance issues that occur within that shift, 23 opportunities for improvement.
24 We've also instituted an independent 25 cross-crew Senior Reactor Operator review of all Marie B. Fresch & Associates 1-800-669-DEPO (3376)
26 1 surveillance tests performed on shift before the 2 off-going Senior Reactor Operators leave at the end of 3 that shift.
4 And we've also, following up with that, we 5 have Operations management review of the completed 6 cross-crew reviews, as well as periodic management 7 observations scheduled to observe those cross-crew 8 reviews.
9 MR. REYNOLDS: Your actions on 10 routine tasks, are these permanent actions or just 11 interim actions until you get enough level of 12 performance out of your crews to say you no longer need 13 these?
14 MR. ALLEN: Steve, that's a 15 subject to some discussion at Davis-Besse. The 16 end-of-shift crew critiques, that is an expectation do 17 not see that probably ever changing. I think there is a 18 value and benefit in that.
19 As far as the, at the end of an operation 20 shift, when all the SROs get together to review 21 surveillance on their shift. We now require an SRO from 22 another shift to come in and perform that review with 23 them. That's my interim action to make sure we get our 24 surveillance tests done.
25 And the challenge is, to the shift managers, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
27 1 to alter the performance of their crews to determine if 2 there are alternative or better ways of performing that 3 task and ensure we don't have errors in surveillance.
4 We could do this forever or the shift managers 5 through their ownership may come up with ultimate means 6 of accomplishing the same task.
7 MR. REYNOLDS: You may not know 8 the answer to this question, but out of curiosity, I 9 always wanted to know. End-of-shift crew critiques you 10 said that was going to be permanent; do you know if your 11 other FENOC plans plants do that currently?
12 MR. ALLEN: I believe so, 13 Steve, but I have not observed those at those stations.
14 So, at best, I have secondhand information.
15 MR. REYNOLDS: Okay.
16 MR. GROBE: Barry, why is it 17 necessary to have the independent cross-crew 18 surveillance review?
19 MR. ALLEN: Jack, we just 20 believe that we would get some value to ensure that as 21 we completed a shift, we were looking for some 22 independent assurance that we had not had errors within 23 our surveillances.
24 And then one of the benefits, Jack, that we 25 saw pretty early on, was that bringing an independent Marie B. Fresch & Associates 1-800-669-DEPO (3376)
28 1 SRO from another crew over, again to point out, I'll 2 say, very minor inconsistencies at a low level between 3 the way individuals on different crews might initial or 4 place key or other minor types of activities.
5 And, so, what this does, it allows an 6 opportunity for the shifts to identify the best way to 7 perform a task for some of these, I'll say, minor low 8 level-type activities that we perform within operations.
9 And, so, we're getting some benefits out of 10 that in that it gathers more consistency in operation 11 and documentation between the crews; and, therefore, 12 looking for that to help improve our performance at the 13 very minor level, which we believe will head off 14 precursors and prevent events at greater levels.
15 MR. GROBE: There is 16 certainly no problems with having additional reviews. I 17 think the most recent surveillance performance problem 18 had to do with heat tracing where a surveillance wasn't 19 correctly performed and it wasn't realized until after 20 control room review of the surveillance results, and an 21 engineer was looking at the result of a surveillance 22 test.
23 Why are these things happening, and, you know, 24 what is the root cause, and why is this band-aid 25 necessary?
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
29 1 MR. ALLEN: Jack, the, 2 subsequent to that condition report which you discussed, 3 that's when we instituted the cross-crew reviews. And 4 that's to ensure that we have individuals go back and 5 specifically review the entire surveillance to ensure 6 that there is not an oversight or some missed data, or 7 inaccuracies in the surveillance test data.
8 MR. THOMAS: By the time it 9 gets to that point, there has been two reviews already, 10 two SRO reviews, so this is a third review on top of the 11 two?
12 MR. ALLEN: A third review 13 with the entire crew, okay, with the SROs on the 14 off-going crew. So, as a team, now, instead of 15 reviewing, one SRO reviews independently, another SRO 16 reviews independently; that all occurs, but this gets 17 that Operations crew together with some independent 18 oversight, if you will, from an additional SRO, and then 19 they go through and critique the performance of those 20 surveillances and look for any opportunities for 21 improvement. Then, that's documented on observation 22 cards.
23 MR. THOMAS: Has this 24 impacted overtime by the crews, this additional review?
25 MR. ALLEN: It has.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
30 1 Individuals have to come in on days off, on weekends, 2 and times like that to perform the review. So, it does 3 impact the SRO's; and they are the ones who are 4 developing the action plan, as I said, to determine if 5 they do something different; and they are the people who 6 schedule that additional SRO review based on their 7 schedules.
8 MR. THOMAS: Okay.
9 MR. GROBE: I'm still not 10 understanding what the cause of the performance 11 deficiencies have been in the past; both within the 12 field where activities aren't completed in accordance 13 with procedure, and then in the Operations organization 14 and those activities are reviewed and deficiencies in 15 the field performance aren't identified.
16 What is the cause of that and how is this 17 fixing the cause?
18 MR. BEZILLA: Jack, my belief 19 is it's attention to detail, and these things that we've 20 had, I'll say, errors occurring, are fairly routine, 21 tech spec related, so it's very important, but they are 22 routine items, and it's a matter of attention to detail.
23 And we found when we have the, I'll say, 24 higher profile items, since restart, we've appeared to 25 have done pretty well on those, but these are the things Marie B. Fresch & Associates 1-800-669-DEPO (3376)
31 1 that happen daily, weekly, monthly, is what we're having 2 our issues with. And, so, our view is that there is no 3 task that's routine, everything is important, and you 4 have to focus on your task at hand.
5 As Barry said, this is an interim solution.
6 We've asked the shift managers to work together to 7 identify what they're going to do to make sure on these 8 routine items they can successfully perform them day in 9 and day out without this additional, I'll say, oversight 10 checks, monitoring, et cetera. And, if we had the 11 answer, we would have eliminated this already.
12 MR. GROBE: Did I read in 13 our Ops assessment, I think I did, I read a lot of 14 documents, so I don't remember exactly where I read 15 those things. But I think I read somewhere in the Ops 16 assessment that there is a too frequent a default to 17 human performance being the specific cause of the 18 problem and not looking deeper as to what's causing the 19 people not to perform correctly. Was that your honest 20 assessment? I think it was, wasn't it?
21 MR. BEZILLA: Right, it was.
22 MR. GROBE: Is this a case 23 where, by saying it's attention to detail, it strictly 24 places the performance issue on the individual. Were 25 there any unusual time constraints or poor guidance or Marie B. Fresch & Associates 1-800-669-DEPO (3376)
32 1 was there anything else that was driving that 2 performance issue?
3 MR. ALLEN: Jack, on this 4 particular one, once we discovered the error that we had 5 in the field on this one, the Operations Manager, Kevin 6 Ostrowski, and the Operations Superintendent, Dave Imlay 7 went out and performed that surveillance to verify 8 adequacy and accuracy of the procedure. And then the 9 following morning, I came in and took an equipment 10 operator at random to get a copy of the surveillance, 11 and take me out and walk me through performance of the 12 surveillance.
13 And I believe from all of our perspectives the 14 procedure was clear. It was explicit. It was not a 15 challenge to perform that surveillance correctly. I 16 believe in that case was more of a challenge to review 17 it than it was to perform it because of the way the data 18 was captured and collected. But just straightforward, 19 Jack. I don't know how else to say it. Just a simple 20 routine task, which was performed incorrectly.
21 MR. GROBE: Okay.
22 MR. REYNOLDS: Couple questions 23 just to clarify in my mind. Three activities you added; 24 end of shift crews, independent cross-crew SRO review 25 and Ops management review. Were they implemented all at Marie B. Fresch & Associates 1-800-669-DEPO (3376)
33 1 the same time or did you do one and then add another and 2 then add another?
3 MR. ALLEN: Steve, the end 4 of shift crew critiques, that's earlier, a while back.
5 And one of the things, again, I've talked about 6 scheduling a lower level of operations activities.
7 Sometime back when the shift manager said, 8 boy, we struggle to do a good job at these. We said 9 we'd put them in the schedule. When we want something 10 in the schedule, we want it to occur, we put it in the 11 schedule. So, we put it in the schedule.
12 So, we did that. And I believe that's helped.
13 Psychologically, if nothing else, it has the station 14 looking at the schedule and recognizing that we do have 15 that critique. And I believing the station is honoring 16 that time that Operations has spent in performing that.
17 The cross-crew review, if you will, that was 18 immediately after the latest error, a day after that.
19 The Operations management review, that's still ongoing.
20 That's Kevin and his folks checking that occasionally.
21 Every shift, when those reviews are performed, 22 I get a sheet from the off-going crew that lists the 23 individuals who performed that review and had a 24 reference to their observation. Now I get copies of 25 many of the observations. I have cards that the extra Marie B. Fresch & Associates 1-800-669-DEPO (3376)
34 1 SRO, if you will, performs a documented observation of 2 that review.
3 So, I review all of those. And then this will 4 also allow us to look collectively, if you will, at 5 those observations and see if there is common areas that 6 we feel like the shift managers want to help address as 7 they work towards the long term solution.
8 MR. REYNOLDS: Then, I guess, 9 another question, maybe a comment is how it comes out, I 10 guess. I think where Jack was trying to go. In 11 Inattention to detail, usually you see that on a rare 12 occasion. Individual just didn't pay attention to 13 detail.
14 But if you see it many times with the same 15 group of people, the same type of activities, there is 16 usually a common cause, it's not just an individual 17 making an error.
18 Talked about procedure. You didn't think it 19 was that. But, you know, it could be training, it could 20 be procedures that you talked about. Said it wasn't 21 that. Could be standards and expectations. Did you 22 look at training and standards and expectations as far 23 as a cause for repeated inattention to detail problems 24 in Ops?
25 MR. ALLEN: In this one, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
35 1 Steve, we did. I did not personally see any of that.
2 In this particular case, we had been quite 3 awhile, been clean for a good while before this latest 4 incident. And, the individual involved had multiple 5 attention to detail events, if you will, in the last 6 year or so. And that individual was just not able to 7 meet our high standards of performance, and that 8 individual is no longer in the Operations Department.
9 MR. REYNOLDS: Okay, that 10 helps, thanks.
11 MR. SUH: Barry, I just 12 had a question, maybe you covered this at the previous 13 meeting. But the Independent Assessment talked about 14 the fact that self-assessments done by the corporate 15 board and by the QA Department in the Operations area 16 was effective and factual and in depth, but then it 17 talked about the self-assessments done by the Operations 18 Department, and they didn't meet that standard.
19 And, I was wondering, was an action, did an 20 action come out of that, or what the status or what your 21 response to that finding was?
22 MR. ALLEN: Just a second, 23 Gene.
24 MR. SCHRAUDER: Gene, while 25 Barry is looking that up, I can tell you that that Marie B. Fresch & Associates 1-800-669-DEPO (3376)
36 1 comment was specifically aimed at our Collective 2 Significance Reviews that sections managers do right now 3 on a semi-annual basis, and it's a fairly new process 4 for us.
5 And several of the sections, I would say, we 6 have a finding of that in the Corrective Action 7 Assessment too, where we had a, I'm going to say, a 8 variety of levels of quality in those assessments. And 9 our folks are just coming up to speed with really how to 10 do those effectively.
11 The second round of those is just now coming 12 due, will be coming to the senior management team to 13 look at how critical, how well we followed the 14 guidelines, and improving the quality of those. So, we 15 are working on that particular aspect within the 16 Corrective Action Program.
17 MR. SUH: Do you have data 18 to suggest that other departments self-assessments are 19 similarly lacking or is it just the Operations 20 Department self-assessments?
21 MR. SCHRAUDER: There were 22 several sections that were found not to have the highest 23 quality in those documents, so we're addressing across 24 the site.
25 MR. SUH: Across, okay.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
37 1 And another question; on the commitment list that came 2 along with the Independent Assessment in the Ops area, 3 there were a number of due dates there that, I guess now 4 that we're here in December, I was just wondering, you 5 may not have, you know, the information right off the 6 top, but are you folks meeting those due dates that you 7 had previously made?
8 MR. ALLEN: Yes, we are 9 meeting those due dates, Gene.
10 MR. SUH: So, that's 11 positive, correct?
12 MR. ALLEN: Right.
13 MR. SUH: Okay, thank you.
14 MR. ALLEN: Next slide.
15 Now, I would like to turn it over to Bob 16 Schrauder to discuss the Independent Assessment of our 17 Corrective Action Program implementation.
18 MR. SCHRAUDER: Okay, thank you, 19 Barry.
20 As Mark indicated earlier, Barry indicated 21 earlier -- next slide, please -- this assessment was 22 performed through the middle of September and into 23 October. It was performed by a combined team of 24 consultants and three peers, three industry peers that 25 are responsible for the Corrective Action Program at Marie B. Fresch & Associates 1-800-669-DEPO (3376)
38 1 their respective sites.
2 We believe that the assessment was a good, 3 tough look at where we are with implementing the 4 Corrective Action Program at Davis-Besse. And as Mark 5 has said, the team identified the overall implementation 6 of Corrective Action Program at Davis-Besse as currently 7 marginally effective.
8 What does marginally effective mean to us? It 9 means that we minimally meet the requirements for the 10 program. And that is certainly not where we want to be 11 with this program at Davis-Besse. And this team is 12 working diligently to make sure that Corrective Action 13 Program is one that consistently finds, assesses, fixes 14 and prevents the recurrence of problems at Davis-Besse.
15 Listed on the slide are the areas that the 16 team reviewed. And each of those individual areas was 17 identified as marginally effective with the exception of 18 the trending program, which I'll get into a little bit 19 later that was identified as unsatisfactory.
20 MR. REYNOLDS: Before you go on 21 to the next slide. You talked about marginally and 22 unsatisfactory, those were, I guess, grades or 23 evaluation. What other possible grades, so to speak, so 24 I could put it in better perspective. You said 25 marginal. You said minimal. Was that the top end or Marie B. Fresch & Associates 1-800-669-DEPO (3376)
39 1 were there upper ends that you could have done better?
2 MR. SCHRAUDER: We could have 3 clearly done better. The team didn't actually give us, 4 here's the three or four categories we're going to use.
5 They simply assigned us their rating of the program.
6 But my sense is we were going to get one of three 7 ratings; effective, marginally effective, or 8 unsatisfactory.
9 MR. REYNOLDS: Okay, thank you.
10 MR. SCHRAUDER: Or fully 11 effective, if you will, for the best rating you could 12 get.
13 Okay, so what I want to do is go through, and 14 a lot of this information we have docketed, but I'll go 15 through the areas for improvement. There were seven 16 areas for improvement identified in this. And then the 17 actions that we're taking to improve our performance of 18 these areas.
19 The first area for improvement was some 20 organizations were not initiating condition reports as 21 required. Now, the team did recognize that Davis-Besse 22 has a high rate of generation of condition reports by 23 industry standards, but they did identify a few 24 instances where it was felt that a condition report 25 should have been initiated or where our process for Marie B. Fresch & Associates 1-800-669-DEPO (3376)
40 1 procedures would have required one to be generated and 2 was not.
3 Some examples of that included in the 4 Collective Significance Reviews that we talked about 5 earlier in the sections, that the procedure, the process 6 would require that for areas for improvement and for 7 noteworthy items that a condition report document that 8 finding and put it into the Corrective Action Program, 9 so that we can resolve the issue.
10 That was not consistently done by some of the 11 organizations. And, most notably, was in the area for 12 noteworthy items in those. Most of the areas for 13 improvements were identified in condition reports, 14 although a few were not, but several sections did not 15 initiate condition reports for noteworthy items, which 16 are improvements or enhancements.
17 Also, the team identify in two instances where 18 we're evaluating a specific condition report, that 19 another issue, if you will, was identified in the review 20 of that condition report and a separate condition report 21 was not written.
22 For instance, one, it was identified during 23 the review of condition report, that a unit log had a 24 discrepancy or error in it and no condition report was 25 initiated to identify that as a condition adverse to Marie B. Fresch & Associates 1-800-669-DEPO (3376)
41 1 quality.
2 Then, another one was during the review of one 3 of the missed tech spec surveillances, it was found that 4 this activity had improperly documented several times in 5 the past, and, in fact, during his review of the rounds, 6 one of the unit supervisors had identified that it 7 hadn't been documented correctly, and corrected it on 8 the spot, which they do, but did not initiate a 9 condition report. The team felt that initiation of a 10 condition report at that level may have helped prevent 11 missing the thing in the future.
12 So, those are the types of examples that they 13 found where some organizations were not initiating 14 condition reports.
15 Actions to review, to improve that is to --
16 we'll look at the procedure again, make sure the 17 procedural guidance is appropriate and complete for 18 reviewing, for threshold for initiation. Then, but we 19 don't want to wait until that review is done, and if we 20 see things that need to be, you know, improved and we 21 get that out, because procedure revision and the like 22 can take longer than sometimes than you would like it 23 to.
24 So, we will issue an expectations directive to 25 communicate and reaffirm CR initiation criteria. And Marie B. Fresch & Associates 1-800-669-DEPO (3376)
42 1 then in June of next year, we'll perform another 2 assessment in the area of how well we're doing on 3 initiating these.
4 One of the things I did do with all these 5 findings to try to get things onto the table quickly is 6 made a presentation to the managers, the manager team of 7 all the findings of this assessment, the QA reviews of 8 the Corrective Action Program and our internal 9 self-assessments. So, while we're going through and 10 making the formal corrections, we have it on the table 11 to remind people of what people are continuing to see.
12 So, that's the first area for improvement.
13 The next area for improvement as stated --
14 MR. REYNOLDS: I'm sorry, I 15 thought you were --
16 MR. SCHRAUDER: Yes. Go ahead.
17 MR. REYNOLDS: You said you 18 were going to issue the expectations directive because 19 it takes longer to get the procedure out, if it needs to 20 be revised.
21 MR. SCHRAUDER: Right.
22 MR. REYNOLDS: And I was just 23 looking at your due dates from --
24 MR. SCHRAUDER: You're wondering 25 why it's going to take so long to get the directive out.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
43 1 MR. REYNOLDS: Well, it says 2 the implement procedure changes if necessary by 12-30-04 3 and directive is completed by 1-15-05.
4 MR. SCHRAUDER: Let me clarify.
5 We'll have the review done for the threshold and the 6 initiation by the 30th, by the end of this year. The 7 procedure changes, any required procedure changes may 8 not be completed yet at that time.
9 MR. REYNOLDS: Oh, okay. The 10 statement just needs to be clarified. If I read it, 11 implement procedure NOP LP 2001 changes, if necessary, 12 by 12-30-04. This is in your letter to us dated 13 November 15th.
14 MR. SCHRAUDER: I'm reading it 15 off the slide. If that's what the, the middle said, 16 then that's what the expectation is to complete the 17 procedure change by then.
18 I think I understand your point. The interim 19 action will be done after the final action.
20 MR. REYNOLDS: If those dates 21 are correct. I didn't know if those dates are correct.
22 MR. SCHRAUDER: We expect to get 23 this expectations directive out next week or probably 24 yet this week.
25 MR. REYNOLDS: Maybe it should Marie B. Fresch & Associates 1-800-669-DEPO (3376)
44 1 be 12-15-04.
2 MR. SCHRAUDER: I had that 3 discussion with performance improvement to get this out.
4 So, point noted.
5 Go ahead, Jack.
6 MR. GROBE: Yeah, Bob, is 7 this expectations directive, is this standard across the 8 FENOC sights or unique to Davis-Besse?
9 MR. SCHRAUDER: This will be 10 unique to Davis-Besse, again as an interim action to 11 make sure we don't wait for the process to drive all the 12 changes. We want to make sure that we identify the 13 specific areas that were identified here, where our 14 folks are not initiating a condition report when they 15 should be. Okay.
16 Next area for improvement states that the 17 process for prioritizing scheduling and extending work 18 does not consistently support the timely implementation 19 of actions to fix longstanding problems.
20 This area for improvement discussed with the 21 team is specifically aimed at the backlog of corrective 22 actions that exist today. Certainly, our team 23 recognizes the need to aggressively pursue and eliminate 24 the backlog of Corrective Action Program open items.
25 And, you know, as we went through this Marie B. Fresch & Associates 1-800-669-DEPO (3376)
45 1 process, we did identify those things that we had 2 committed and stated we would get done prior to restart, 3 whether it was the evaluation of the condition or actual 4 fixing of the, you know, implementing the corrective 5 actions. And we had the process of another set of them, 6 we said we would complete after restart. And that's 7 where we're at right now.
8 So, we did go through a process that put them 9 in one bin or another. And, now, it's our job to get 10 after those and get them completed.
11 I believe we have shown some good progress in 12 that regard when you look at the conditions adverse to 13 quality. When we restarted the unit, we had a little 14 over a thousand evaluations that were open, that were to 15 be done post-restart. We currently have 311. Or as my 16 data point late last week, we had 311 evaluations.
17 But in the process, we had also initiated an 18 additional almost 1900 evaluations that were initiated 19 and completed in that time frame. So, we've been pretty 20 busy in getting this backlog work down.
21 Then, for the corrective actions that are 22 associated with significant conditions adverse to 23 quality and conditions adverse to quality; when we 24 restarted, we had about 5,300 open corrective actions.
25 And we've reduced that now to about 3,500, 3,600 range, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
46 1 and also have generated an additional 2,700 in that time 2 period. So, we have made some pretty good progress in 3 working on the condition adverse to quality backlogs.
4 And we expect, as I think Barry said earlier 5 or Mark, that by the end of the 14th refueling outage we 6 will effectively converted what was the backlog into a 7 normal workload or through put for the Corrective Action 8 Program.
9 MR. REYNOLDS: As far as that 10 backlog, if I remember correctly, you talked before, 11 that your workload you were getting to, you benchmarked 12 that to determine what that should be; am I correct on 13 that?
14 MR. SCHRAUDER: That's correct.
15 What we benchmarked, Steve, was the, the overall 16 workload, everything that we're working on at the site.
17 MR. REYNOLDS: I just wondered, 18 benchmarking is a good thing. And I was wondering if 19 you benchmarked how long it took other plants coming out 20 of extended shutdown to get to their workload number, to 21 see if two years is consistent with that, ahead of 22 schedule, or behind schedule; if you know it from a 23 performance standpoint, how does that track?
24 MR. SCHRAUDER: I can't answer 25 that absolutely. I can tell you that I believe we are Marie B. Fresch & Associates 1-800-669-DEPO (3376)
47 1 on a track to get our backlog done sooner than some 2 others have. So, we have made pretty substantial 3 progress, I think consistent progress in the months 4 that, since the unit has restarted.
5 MR. REYNOLDS: Two years seems 6 long to me, but it may be you lose track of times in the 7 other plants.
8 MR. SCHRAUDER: Seems short to 9 us when we're in here working on it. Respect your 10 perspective.
11 MR. REYNOLDS: Yes, it does.
12 MR. SCHRAUDER: We've looked at 13 it. And part of what I was doing, the senior management 14 team got together, based on some of the comments here, 15 because one of the activities that we had put in the 16 post restart, or after restart, we had a recurrence of 17 that issue, which is what your, why you don't want a 18 backlog, because it can happen again if you haven't 19 gotten the corrective action in place yet.
20 So, the senior team sat down. We went through 21 all of the open items from significant conditions 22 adverse to quality, our apparent cause evaluations for 23 conditions adverse to quality, and what we used to call 24 basic cause evaluation, which in our old vernacular of 25 the system was between a root cause and apparent cause.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
48 1 We went through every one of those corrective 2 actions to see whether the current schedule we felt was 3 appropriate and adequate; whether we needed to pull any 4 of those up; whether, where they were currently 5 scheduled, whether we felt like we needed to put any 6 interim actions in place, to help try to prevent them 7 recurring again.
8 So, we've looked at that backlog again in a 9 fair amount of detail to assure ourselves that we think 10 it's appropriately scheduled and can be worked off.
11 MR. REYNOLDS: Okay.
12 MR. SCHRAUDER: This action plan 13 is the, we talked about this to create a comprehensive 14 integrated backlog reduction plan that looks at the 15 Corrective Action Program, the Maintenance workload, if 16 you will, the Engineering workload, procedure change 17 request; pull all that stuff together to make sure we're 18 on a path to efficiently reduce that backlog within the 19 time frames that we've just spoken.
20 MR. SUH: Bob, just a 21 question, I'm sorry. In the commitment letter, the 22 creation of the integrated backlog plan is December 23 31st.
24 MR. SCHRAUDER: That's correct.
25 MR. SUH: And then the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
49 1 word, the verbiage says "implement the integrated 2 backlog reduction plan, March of 2006."
3 MR. SCHRAUDER: That's right.
4 MR. SUH: And I was 5 wondering what the word implement in that case meant.
6 MR. SCHRAUDER: That's another 7 way of stating what I think we've already said, and that 8 is we will be through the backlog by the end of March of 9 '06 or approximately the end of the 14th Refueling 10 Outage. And we believe that we will be done with 11 backlog, and back to workload at that time.
12 MR. SUH: Just a 13 suggestion, I think the word is, could be interpreted a 14 couple ways; and just to tie into Steve's, Steve 15 Reynolds' comment before on the previous commitment, on 16 the previous AFI, implementing the procedure change. I 17 agree with Steve, that's a little bit, the wording there 18 might be, you folks might want to take a look at that.
19 Not only on this one.
20 I guess I'm just, just seems like different 21 readers would interpret the word implement differently 22 here, unless it's more fully explained somewhere else.
23 MR. SCHRAUDER: No, it's not 24 fully explained, and I appreciate your input. And I 25 just want to let you know, I mean, we can look at Marie B. Fresch & Associates 1-800-669-DEPO (3376)
50 1 revising the words, if we need to, but specifically our 2 intent was that that means we'll create the plan by the 3 end of this year; we'll work through the plan by March 4 of '06, and have the backlog completed at that time.
5 MR. SUH: Right, right.
6 And, what I meant by Steve's previous comment was about 7 implementing the procedure.
8 MR. SCHRAUDER: Right.
9 MR. SUH: I think your 10 first interpretation was, made sense to me, Bob, you 11 were going the to evaluate it by December 30th, but if you 12 do a procedure revision, that obviously takes longer; 13 and, so, you know, the comment was that maybe just a 14 verbiage needs to be changed.
15 MR. SCHRAUDER: I think I was 16 wrong in my response to Steve. I think he was right; 17 we're supposed to have the procedure done if it needs to 18 be revised by then. I have to look at that, but I 19 believe that's what we meant by that.
20 MR. SUH: So, you'll check 21 that?
22 MR. SCHRAUDER: Yes.
23 MR. SUH: Okay, fine.
24 MR. SCHRAUDER: Next area of 25 improvement is a review of open corrective action Marie B. Fresch & Associates 1-800-669-DEPO (3376)
51 1 implementation extensions classified as nonrestart, 2 should be conducted to ensure appropriate compensatory 3 actions are in place. I discussed this on the previous 4 slide; where this is, this is the issue where we had one 5 or two, as I recall, there was only one instance that 6 they pointed to that we had a repeat occurrence of one 7 of our conditions, corrective actions that we put into 8 the backlog.
9 So, our actions to improve this, as I stated, 10 were to review the backlog of significant conditions 11 adverse to quality and conditions adverse to quality, 12 root and apparent causes.
13 We looked specifically at preventative and 14 remedial actions to consider whether we needed to pull 15 any of them up or put in interim compensatory measures.
16 Now, eventually, what we're going to do with 17 our, with the CREST system, which is the software that 18 drives the Corrective Action Program, is we'll require 19 in the future when people request an extension to one of 20 these types of preventative or remedial actions, they 21 will specifically have to address and ask and answer the 22 question and document their response as to whether an 23 interim action is required due to this extension; and if 24 not, why not.
25 So, and again, rather than wait to get that Marie B. Fresch & Associates 1-800-669-DEPO (3376)
52 1 completed in CREST, because software changes can 2 sometimes take awhile too, Mark has put out an 3 expectations directive on this too, that says, in the 4 interim while we're waiting for the CREST change to do 5 it, to force you to do it, we want you to do it as a 6 matter of business, in addition to the procedural 7 requirements right now. And we have begun to do that.
8 Now, the only people that can extend 9 significant conditions adverse to quality and conditions 10 adverse to quality at root or apparent cause level are 11 the Directors and Mark. And, therefore, it's a rather 12 small audience that really has to maintain awareness of 13 that. We usually do not like to do things by directive; 14 we want it in procedures, but in this case, it's a very 15 small population of individuals that has the 16 responsibility to make sure that's done. So, we think 17 we'll be successful in that area.
18 Questions on this one?
19 MR. SUH: I just fully 20 wanted to understand, Bob, did I understand you to say 21 when you get an extension, it can only be at the 22 directive level or you were talking on a very specific 23 population?
24 MR. SCHRAUDER: I'm sorry, Gene, 25 could you repeat the question?
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
53 1 MR. SUH: I'm sorry. On 2 the commitment in your letter you say, "condition report 3 process procedure currently states that corrective 4 action extensions are to consider the need for interim 5 actions."
6 Let's see. Well, let's see. I guess I'm not 7 quite sure where I made my comment here. I was 8 wondering, when you get an extension, is that, do you 9 require a higher level of approval than the original 10 sets of approvals or is it the same level?
11 MR. SCHRAUDER: An extension for 12 these levels requires director or vice president for 13 significant condition adverse to quality. The initial 14 setting of that corrective action due date is driven by 15 procedure. So, there is specific default values that 16 you can not exceed. You can always put one in earlier, 17 but you can't exceed certain levels. So, as long as 18 you're within that time frame, Mark does not have to 19 approve those.
20 They do however go to the Corrective Action 21 Review Board. And if the Corrective Action Review Board 22 doesn't believe they're timely enough, we can, we can 23 accelerate the due dates too. But once that due date is 24 established, then it requires vice presidential approval 25 for continuation.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
54 1 MR. SUH: For significant 2 conditions?
3 MR. SCHRAUDER: Right, and for 4 conditions adverse to quality at the root and apparent 5 cause levels, it requires a director's approval to 6 extend those.
7 MR. SUH: Thank you.
8 MR. SCHRAUDER: The next one 9 addresses the trending program, and the area for 10 improvement states that we have not aggressively worked 11 to correct Corrective Action Trending Program 12 deficiencies identified in previous self-assessments or 13 oversight findings.
14 Team went back as far as the NRC Corrective 15 Action Team Inspection, where we identified that we had 16 at that time suspended the trending program. We did 17 that as a conscious management decision through the 18 course of the recovery, because there was so many 19 condition reports being generated with the same types of 20 things like the boric acid inspection walkdowns and the 21 like. And we didn't think that we were going to get a 22 lot of value from trending during the period of that 23 time.
24 And, really, I think the Corrective Action 25 Team Inspection's thrust was, hey, you're waiting too Marie B. Fresch & Associates 1-800-669-DEPO (3376)
55 1 long to get this thing reinitiated. And we did 2 reactivate it. We did reinitiate the trending program.
3 And we went back and did trend back to the point that we 4 had suspended that.
5 Since that time, we've looked at other sites.
6 We hadn't tried to incorporate or improve the quality of 7 the assessments so that they become a better tool for 8 management and to make sure that management is in fact 9 using the trend report, so we have incrementally 10 improved that thing, and have responded to 11 self-assessments and the like, but the trend report was 12 not where either we wanted it or where the peers thought 13 it should be at. And, so, we continued to improve that.
14 I will tell you that we just recently finished 15 the third quarter for this year's trend report, and it 16 has gotten a fairly good marks from our CNRB, our own 17 management team. We did go out to the management team 18 also and solicit their input on what would make a 19 meaningful trend report to them. So, this latest one 20 that came out was felt to be pretty good.
21 The thing with trend reports is they need to 22 be relatively simple in that the reader needs to be able 23 to pick them up and not have to really figure out, you 24 know, through a lot of detail what trend are you trying 25 to point out to me. But they have to be accurate, and Marie B. Fresch & Associates 1-800-669-DEPO (3376)
56 1 they have to take specific actions when trends are 2 identified.
3 So, I think we're going there. Now, the team 4 also, this assessment team, identified a concern in the 5 report that said, hey, you know, you've been a little 6 bit slow getting this thing up and good quality and 7 stuff; now you're transferring it to the fleet, as a 8 fleet initiative, and we're concerned that that's going 9 to delay it even further.
10 First of all, it's true that the trend process 11 will be a fleet wide process. It will be a common 12 process, with responsibility in the fleet for that trend 13 report, but we're not waiting, again, at Davis-Besse 14 until that product is finalized. We're continuing to 15 mature the trend report that we're currently using here, 16 again, to make it useful for us and to make sure our 17 management team is using it.
18 When the fleet finalizes the product, we'll 19 then go through a changed management process and adapt 20 the new fleet, but we're not waiting for that one to 21 improve the one that we have.
22 MS. LIPA: Bob, you 23 mentioned that the third quarter trend reports that you 24 just completed, you had pretty good product. Did the 25 Independent Assessment Team come before those were Marie B. Fresch & Associates 1-800-669-DEPO (3376)
57 1 issued?
2 MR. SCHRAUDER: Yes, it did.
3 MS. LIPA: So, they didn't 4 have the benefit of looking at those.
5 MR. SCHRAUDER: That's correct.
6 MS. LIPA: The other thing 7 I was wondering about, in the Cycle 14 Improvement Plan, 8 you had an action to reestablish the Corrective Action 9 Program Trending Process, which you declared complete on 10 February 2004.
11 So, since you already declared it complete, 12 did you have anything in the works to revisit the 13 effectiveness of it or was it kind of off the radar 14 screen until this independent team came in?
15 MR. SCHRAUDER: No, it wasn't 16 off the radar screen, we were continuing even before 17 they came in to look at it, to benchmark other 18 facilities, and to improve that, that document. It 19 wasn't off our radar screen.
20 MR. BEZILLA: Our 21 self-assessment I believe identified the need to 22 continue to improve that, and we had done benchmarking 23 and Bob's performance improvement guys were around prior 24 to this independent team coming in and looking, asking 25 for, hey, which form do you like, what format do you Marie B. Fresch & Associates 1-800-669-DEPO (3376)
58 1 like, that kind of stuff.
2 So, the third quarter model is already being 3 worked on when they were here, but we didn't have a 4 product out at the time that team was here.
5 MS. LIPA: Okay.
6 MR. SCHRAUDER: So, listed here 7 are the actions that we have taken or will take to 8 improve the trending report; benchmark other sites, 9 we'll continue benchmarking and this will be done 10 through the fleet at this time; enhance the quarterly 11 trend report, which we believe we've done with the third 12 quarter trend report and we'll continue to enhance that.
13 Improve the guidance concerning timeliness for 14 performing and completing collective significance 15 review. Another part of the trending process is not 16 just site wide process, but individual sections do 17 trending also. And, so we'll improve the guidance for 18 the development and the implementation of those reviews 19 or trend reports, if you will.
20 MR. GROBE: Bob, does that 21 involve the expectations directive or is that a 22 procedure change?
23 MR. SCHRAUDER: That will be a 24 business practice, Jack. There is a business practice 25 for doing it now, but we're reviewing that business Marie B. Fresch & Associates 1-800-669-DEPO (3376)
59 1 practice again to make sure it has appropriate guidance 2 and clear guidance to consistently do these and raise 3 the quality of them.
4 We still have initiative to develop and 5 implement a site-wide equipment trending program. And 6 a FENOC common trending program, which should be 7 completed by the end of January of '05.
8 MR. REYNOLDS: Now, I don't 9 know if this is the way you structured your slides, but 10 I also see in your letter to us, you make a distinction 11 between the site-wide equipment trending program to 12 develop and implement for the FENOC common trending just 13 to develop. I assume you mean, also implement the FENOC 14 common trending program.
15 MR. SCHRAUDER: That's correct, 16 Steve. Once it's developed, we'll implement it.
17 MR. REYNOLDS: Thanks, but I 18 just ask you then to formally update your letter.
19 MR. SCHRAUDER: We can do that.
20 I had to be a little careful with that one, because when 21 we're developing the FENOC common processes, okay, there 22 is a subsequent implementation schedule for putting them 23 in, and it may be, it varies depending on what is going 24 on at that time at the site. For instance, if we're in 25 the middle of an outage, we wouldn't at Davis-Besse Marie B. Fresch & Associates 1-800-669-DEPO (3376)
60 1 necessarily implement it as soon as it's developed and 2 released from the fleet.
3 MR. REYNOLDS: I'm not, I 4 guess, what date you put, I'm asking that you do plan on 5 implementing it, that you make that commitment to 6 implement the new effective date, that that makes sense 7 for you.
8 MR. SCHRAUDER: Yes, sir, got 9 it.
10 MR. GROBE: Just a quick 11 question, Bob. This site-wide equipment and trending 12 program, how does that relate to your maintenance rule?
13 Did you understand the question, Steve?
14 MR. LOEHLEIN: Yeah, I think, 15 let me see if I can paraphrase it back to you. You're 16 asking to link the maintenance rule program to the 17 site-wide equipment trending program.
18 MR. GROBE: Is this going to 19 be part of your system health reviews, or what is this 20 site-wide equipment trending program?
21 MR. LOEHLEIN: The site-wide 22 equipment trending program is intended to directly 23 support system health. That's correct. But it's still 24 only in development for the site. And I think the plans 25 are to make that FENOC-wide later, but we don't have Marie B. Fresch & Associates 1-800-669-DEPO (3376)
61 1 that currently at issue.
2 The existing corrective action covers that, 3 Jack, I believe has a due date at the end of the year 4 for that, and there are folks working on that right now, 5 but there is a tie in a supportive system health as the 6 primary objective that, that whole effort.
7 MR. THOMAS: Help me 8 understand what the difference between what this program 9 will provide and what's being done on a system basis now 10 by the system engineers?
11 MR. LOEHLEIN: I would suggest since I didn't 12 prepare a lot of background topic for this meeting, 13 maybe I just bring it with me next time when I talk 14 about the engineering assessment, and bring that along 15 as a topic, and by then we should have a lot more to 16 talk about.
17 MR. THOMAS: Okay.
18 MR. SCHRAUDER: Anything else on 19 trending?
20 Okay, the next area for improvement is, is 21 that improvement is warranted in the documentation of 22 organizational collective significance self-assessments 23 with respect to minimal procedure guidance, 24 expectations, documentation, documentation of condition 25 reports, and overall performance rating.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
62 1 We've talked about this a couple of times 2 already. These are the Collective Significance Reviews.
3 This team, as well as our self-assessment, identified a 4 variety of quality, I'm going to say, on these. And 5 this again goes to our condition reports being written 6 for noteworthy items, getting condition reports out for 7 areas for improvement.
8 And are the areas, are that the sectional 9 managers reaching an overall statement of their 10 performance, they're given an overall rating. Some 11 were, some were not in this regard. So, we're looking 12 at, making sure the procedural guidance is clear enough 13 in that regard, and then establishing expectations for 14 the format and documentation, and making sure that there 15 is a requirement for an overall rating.
16 MR. GROBE: Where would 17 those expectations be captured?
18 MR. SCHRAUDER: In a business 19 practice.
20 Next area for improvement is, self-assessment 21 process does not provide a mechanism for identifying and 22 correcting programmatic concerns or trends identified 23 during the course of the assessment. This came from one 24 of our peer, a couple of the peer reviewers, and may not 25 be real evident what that means, but I spent quite a Marie B. Fresch & Associates 1-800-669-DEPO (3376)
63 1 deal of time talking to them.
2 What they were getting at is, if we do an 3 assessment, a programmatic assessment, let's say for 4 example, the AOV programs that we're assessing. We do a 5 self-assessment or collective significance assessment 6 and we find let's say four or five different things or 7 areas for improved -- to improve in that 8 self-assessment. The process currently doesn't drive 9 you to say, okay, I found these things, I'm going to go 10 fix them, but what is the status of the equipment out in 11 the field that I've used this program to use? And there 12 is no finding that we don't, you know, that there is an 13 impact out in the field. This is a process issue that 14 says you're not driven to go do and make that assessment 15 and document that assessment of what's the impact on, in 16 this case equipment out in the field.
17 The peers that we talked to have this in their 18 process and they're going to send us their, how their 19 process drives that assessment when you get there. So 20 that's another business practice that we'll be looking 21 at to make sure we have proper guidance there, and the 22 programmatic concerns are captured.
23 MR. REYNOLDS: If I was to add 24 on to your bullet then, you said it was to consider 25 potential aggregate impact of programmatic concerns or Marie B. Fresch & Associates 1-800-669-DEPO (3376)
64 1 trends on plant equipment.
2 MR. SCHRAUDER: Well, plant 3 equipment, Steve, was just an example I was using. It 4 could be other, could be in the Corrective Action 5 Program, and you find findings here; what's the impact.
6 MR. REYNOLDS: But at least on 7 plant equipment, it's not just a programmatic procedure 8 process review?
9 MR. SCHRAUDER: It is the 10 collective result of what does that mean in the 11 aggregate to the program you just assessed, and what 12 that program is supposed to protect you against.
13 MR. REYNOLDS: It's not just 14 looking at the program, let's go improve the program.
15 The effect on those problems had on whatever the program 16 touched.
17 MR. SCHRAUDER: Right, that's 18 correct.
19 MR. REYNOLDS: May be 20 equipment, may be Corrective Action Program, may be 21 operator training, maintenance training, whatever 22 happens to be.
23 MR. SCHRAUDER: That's correct.
24 MR. REYNOLDS: Thank you.
25 MR. SCHRAUDER: And the last Marie B. Fresch & Associates 1-800-669-DEPO (3376)
65 1 area for improvement is that additional access is 2 warranted on timely correction of items identified by 3 self-assessments and the nuclear quality assurance 4 finding.
5 This is a two-prong thing. First of all, it's 6 if additional access warranted, and that goes to the 7 backlog and if there is more things there than we like.
8 Some of them, as long as we have a backlog, are going to 9 be from self-assessments and nuclear quality assurance 10 findings.
11 There was a sense, at least among part of that 12 team, that the fact that these issues were identified in 13 self-assessments or by quality assurance, they should by 14 that virtue alone have a higher priority placed on them, 15 a higher timeliness. We have taken exception to that 16 area, and our position, and we believe the industry norm 17 is, that findings are prioritized in accordance with 18 their safety significance, not by who found them, or 19 what process found them.
20 So, we will go out and benchmark and make sure 21 that our understanding of the industry norm is as we 22 find it, but what we believe very strongly in that, 23 priority should be based on the safety significance of 24 the issue and not on who or what process found it.
25 MR. HRUBY: Nuclear Marie B. Fresch & Associates 1-800-669-DEPO (3376)
66 1 Oversight agrees with the line on this, that the safety 2 significance of the issue should dictate the timeliness 3 of resolution, not who generated it.
4 MR. REYNOLDS: If that's the 5 case, why are you going to go sample to see if the, it's 6 being done at comparable rates, if the rates don't have 7 much meaning, if it's not safety significant?
8 MR. SCHRAUDER: We want to make 9 sure that we're not an outlayer, that's why we'll go out 10 and benchmark that.
11 MR. REYNOLDS: Okay, even if 12 the sites identifying were safety significant issues, 13 NQA, who is going to benchmark. Like I said, I'm 14 struggling.
15 MR. SCHRAUDER: I'm sorry. What 16 we're benchmarking is to make sure that our priority 17 culture mindset, if you will, that it doesn't matter who 18 found it, it's the safety significance of the issue that 19 sets its priority. That that is the industry norm.
20 MR. REYNOLDS: That I 21 understand, but I guess -- okay. Then explain to me 22 what you're going to compare then?
23 MR. GROBE: You talking 24 about the last bullet, Steve?
25 MR. REYNOLDS: Yes.
Marie B. Fresch & Associates 1-800-669-DEPO (3376)
67 1 MR. GROBE: I wasn't sure I 2 understood that either, Bob. If safety drives all the 3 prioritizations, why are you discriminating between a 4 certain categorized site identified CR and a NQA 5 identified CR that are both the same. Are you thinking 6 that the staff might be saying this one came from QA, so 7 let's set it aside?
8 MR. SCHRAUDER: I understand the 9 question now. The reason that's in there is to make 10 sure that we're not stiffing QA's findings, and that we 11 are in fact addressing them commensurate with -- one 12 comparison is how are we doing on those as to how we're 13 doing on other findings to make sure we're not on the 14 other side of that spectrum and not addressing QA's 15 issues in a timely manner.
16 I believe Ray has already looked at that.
17 MR. HRUBY: We have a Cycle 18 14 LIP indicator that measures timeliness and 19 responsiveness of the organization to quality generated 20 condition reports and corrective actions and the like.
21 And we see that they're pretty much in alignment. The 22 lines responding in about as timely a manner to line 23 initiated condition reports as they are to the quality 24 condition reports.
25 MR. SCHRAUDER: Then the last Marie B. Fresch & Associates 1-800-669-DEPO (3376)
68 1 slide does identify the fact that they did, in fact, 2 find some positive things in their write-up for us.
3 They were complimentary of the systematic 4 approach to training that we took. Specific examples 5 they identified were the CR analyst and the Corrective 6 Action Review Board members, but we actually applied the 7 systematic approach to training to all of the training 8 needs in the Corrective Action Program; and we believe 9 that that has helped us.
10 They made comment that the Corrective Action 11 Review Board is effective and that we provided good 12 consensus among the members on the Corrective Action 13 Review Board and do provide an effective final barrier 14 for condition reports.
15 They felt that management here at the site is 16 knowledgeable of the program and areas that we need to 17 improve the program in; that the management is involved 18 in the program and are moving to improve the 19 implementation of the Corrective Action Program.
20 They did comment that there is a backlog, but 21 the backlog they can see we have been working on it and 22 it is decreasing.
23 And, finally, I think an important finding is 24 that this Independent Assessment does reflect 25 Davis-Besse's self-assessments in its program. That is, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
69 1 we didn't find anything really new in this process.
2 There were some repeat findings, I guess I would say, 3 but fundamentally, nothing really new came out of this 4 assessment that we didn't know and have in our 5 self-assessment that we needed to continue working on.
6 Unless there is additional questions, that 7 concludes my remarks.
8 MR. SUH: I had a 9 question. In the executive summary of the Independent 10 Assessment Report, they talk about, they made a 11 recommendation at the end about an integrated plan. Let 12 me just read it to refresh your memory, refresh some 13 peoples memory.
14 They said that based upon the writing rating of 15 marginal and the number of repeat findings the team 16 recommends an integrated approach for improvement and 17 they recommended, paraphrasing, they recommended that 18 the Davis-Besse staff develop an integrated action plan.
19 And I was wondering, is that in the commitment list?
20 MR. SCHRAUDER: It is not in the 21 commitment list we sent to you. I can tell you that we 22 have accepted that recommendation and we are developing 23 an integrated plan for improvements to the Corrective 24 Action Program, as well as this integrated plan for the 25 reduction of the backlog. So, we have accepted that Marie B. Fresch & Associates 1-800-669-DEPO (3376)
70 1 recommendation from the team.
2 MR. SUH: Okay. So, but 3 it's not on commitment list?
4 MR. SCHRAUDER: No, the 5 Confirmatory Action Letter was specific about what they 6 wanted us to get back to and commit to the regulator on 7 these assessments, and it was on the areas for 8 improvement identified in the report. That was not an 9 area for improvement, it was a recommendation that we 10 nonetheless have accepted.
11 MR. SUH: Okay, thank you.
12 MR. GROBE: Just one 13 observation. This is the first time I've seen in your 14 vernacular this concept of an expectations directive. I 15 wasn't exactly clear on what that was. I just caution 16 you to be careful to not create a work-around. I'm not 17 sure if that's what it is, but it kind of sounds like it 18 might be a work-around to procedure.
19 My experience is you have procedures and you 20 train to procedures. That this is a training element 21 that you're going to go out and train people to; it's a 22 training document. I'm not sure what an expectations 23 directive is.
24 MR. SCHRAUDER: What it was is a 25 memo from Mark to start doing it now before the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
71 1 procedure is changed. And the procedure is the formal 2 correction of the process. So, it's not intended to be 3 a work-around, but I understand your point. We don't 4 typically run the plant by memo either, but it's another 5 one of those we didn't want to wait when we could take 6 some action right now and make it clear what our 7 expectations are to the staff.
8 MR. GROBE: Okay. Very 9 good. Thanks.
10 MS. LIPA: Unless there is 11 any other questions, this is a good time for a ten 12 minute break. So, we'll be back in ten minutes. Thank 13 you.
14 (Off the record.)
15 MS. LIPA: Okay. Go ahead, 16 Mark.
17 MR. BEZILLA: Thank you, 18 Christine.
19 Our next slide, Kevin.
20 In regard to Safety Culture/Safety Conscious 21 Work Environment, what has occurred since the last 22 public meeting. Mr. Wright of your staff was on site to 23 look at various Cycle 14 Operational Improvement Plan 24 items and packages.
25 We conducted our annual internal Safety Marie B. Fresch & Associates 1-800-669-DEPO (3376)
72 1 Conscious Work Environment Survey. Our Nuclear 2 Oversight Department conducted a number of interviews as 3 part of their annual Safety Culture/Safety Conscious 4 Work Environment Assessment preparations. We conducted 5 our site annual Safety Culture Assessment.
6 And, finally, our Confirmatory Order 7 Independent Assessment of Safety Culture/Safety 8 Conscious Work Environment was initiated with surveys, 9 interviews, and observations being gathered. That team 10 is currently analyzing the data and has forecasted to 11 deliver preliminary findings and conclusions the week of 12 December the 20th and we think it's going to be on the 13 21st.
14 Next slide, please.
15 Now, let me spend a few minutes on the recent 16 internal Safety Conscious Work Environment Survey 17 results. We noted some less positive results in a 18 number of questions and across a number of sections.
19 This is noteworthy because last November we also saw 20 some less positive results.
21 Just looking on the surface, one could 22 conclude that these results are not surprising. Why, 23 what had recently occurred or was going on at the time 24 of or just before the survey? A couple of examples.
25 We had just recently on August 23rd Marie B. Fresch & Associates 1-800-669-DEPO (3376)
73 1 implemented a new organization where we implemented a 2 common structure, which resulted in some reductions in 3 staffing. We had union contract negotiations in 4 progress with both of our union locals. And we had just 5 recently presented a case study on an industrial safety 6 near miss that occurred this past March. And in that 7 case study, we talked about the various barriers and how 8 those barriers had been breached. However, the last 9 barrier had kept us from having an event and kept it to 10 a near miss.
11 Could these things influence the result?
12 Maybe. However, I don't want us jumping to 13 conclusions. So, what have we done so far? We've 14 reviewed the results as a management team through the 15 superintendent level. We obtained some external 16 assistance to help us understand what these survey 17 results are telling us, and to take an independent look 18 at the results and see what they think the results are 19 telling us.
20 It should be noted that this team is 21 essentially the same team that came in last December, 22 and helped us after the last survey we did in November 23 of last year.
24 We discussed the results with the staff. We 25 had an All-Hands Session last Friday and we covered I'll Marie B. Fresch & Associates 1-800-669-DEPO (3376)
74 1 say the preliminarily results and the themes. And we've 2 met three times, superintendents and above with some 3 facilitation to examine the results and ask why, why, 4 why. Okay.
5 So, what's next? We're currently in the 6 process of determining the drivers and the underlying 7 whys for those less positive responses.
8 Some themes that we noted from our 9 interactions and discussions: The reorganization 10 appears to be an impact. Perception of schedule 11 pressure is an impact. Timeliness and effectiveness of 12 corrective action on my thing appears to be an impact.
13 Perception of Employee Concerns Program confidentiality, 14 and perception that management holds the work force more 15 accountable than we hold ourselves.
16 Those are some of the themes that we've seen 17 in the interactions and discussions we've had. And we 18 need to understand those, so that we can take additional 19 actions.
20 Once we're confident, we understand and have 21 the whys, we'll figure out, determine the actions that 22 we need to address those whys. We'll use our External 23 Assistance Team to validate our conclusions, and we'll 24 also use Doctor Haber's Confirmatory Order Independent 25 Assessment of Safety Culture/Safety Conscious Work Marie B. Fresch & Associates 1-800-669-DEPO (3376)
75 1 Environment Report to provide a second check on our 2 understanding of the drivers.
3 Two noteworthy positives, because there were 4 positives, right, in the survey. First, employees 5 recognized their responsibility to identify concerns and 6 indicated that they would raise these concerns either 7 through their supervisor, the Condition Report Process 8 or the Employee Concerns Process. And second, employees 9 have not experienced acts of retaliation or perceived 10 retaliation.
11 So, this area, maintaining a robust Safety 12 Conscious Work Environment atmosphere was and is a key 13 focus area for I and my team.
14 Next slide.
15 MR. GROBE: When do you 16 expect that, excuse me, that you'll understand the 17 drivers and have these corrective actions identified?
18 MR. BEZILLA: Jack, we have 19 the debrief at least on preliminary findings with Sonja 20 December 21. And between then and now, I plan on 21 meeting with my team a couple of more times. And I 22 think we'll have the whys fettered out and we'll start 23 forming what actions we need to take on what behaviors 24 we want to change to impact, I'll say, the Safety 25 Conscious Work Environment atmosphere. And then the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
76 1 independent teams should be able to have something for 2 us about that time, and we'll be able to look at Doctor 3 Haber's report.
4 I believe we've actually already started the 5 process of improving, I'll say, some of those 6 perceptions. Let me give you an example. We gave the 7 managers the results. We gave them the comments from 8 their sections. We asked them to go look at those, and 9 then meet with their folks and have some discussions, 10 right.
11 One area, one of the managers went and got his 12 folks together. And, one of the issues was 13 reorganization. And it said, you know, "Hey, you guys 14 got rid of the people that raised issues." Okay. "Or 15 you got rid of my friend."
16 Okay. And he said, "Okay, have you raised 17 issues?"
18 "Well, yes."
19 "Well, you're here, right?"
20 "Yeah."
21 "Have you raised issues?"
22 "Well, yes."
23 "Well, you're here."
24 Okay. And what he told them was, "I know why 25 each of those five individuals are no longer here with Marie B. Fresch & Associates 1-800-669-DEPO (3376)
77 1 us, but let me give you a scenario. If you were one of 2 those five, and I was sitting in here with a room of 3 your peers, would you want me going over the five 4 reasons why you aren't here anymore?"
5 And they said, "No, we wouldn't want you doing 6 that."
7 And he said, "Okay. So, I know, right? And 8 we've communicated to you. You all know. Just reflect; 9 you know what the process was, right? There was 10 knowledge, skills, abilities, okay, attitude. We went 11 through that. Human Resources Department. We went 12 through the Safety Conscious Work Environment Review 13 Team. Make sure there was no harassment, intimidation, 14 retaliation or discrimination. Okay, and we did that 15 for every selection that we made."
16 So, my point was, just through that 17 discussion, the feedback was, that individual, that 18 manager could see some of the anxiety removed, maybe 19 some of the stress removed. As far as my friend goes, 20 that's a little harder to deal with, right, but from a 21 positive standpoint, here's how we did it.
22 So, just the communication. I mean, we do do 23 surveys to get input so we can go take action. And I 24 believe we've actually already started some of that.
25 But we don't want to try to jump to conclusions. We Marie B. Fresch & Associates 1-800-669-DEPO (3376)
78 1 want to understand the whys and formulate actions or 2 behavior changes that we need to make to improve, I'll 3 say, the results the next time we take a survey or check 4 on our Safety Conscious Work Environment.
5 MR. GROBE: Well, we just 6 got this report this afternoon, and I've had some time 7 to look through it, but certainly not have had the 8 opportunity to do a thorough review, but the fact that 9 there is a negative trend in a number of areas is 10 troublesome.
11 We had a negative trend last November and you 12 brought in some help and evaluated things and things 13 improved. Now there is a negative trend from that last 14 November survey.
15 I hope that you're considering what types of 16 interim actions can be taken between Novembers to make 17 sure that you understand for significant activities that 18 are ongoing the effectiveness of your communications, 19 such that you do not continue to generate negative 20 trends in your Safety Conscious Work Environment that 21 are not disclosed until once a year; and so that you can 22 take timely corrective actions.
23 I know that you have the Safety Conscious Work 24 Environment Review Team in place. And you are 25 attempting to use your changed management process to try Marie B. Fresch & Associates 1-800-669-DEPO (3376)
79 1 to minimize these impacts, but those activities have not 2 been fully effective. And finding out that they haven't 3 been fully effective once per year at the end of the 4 year is, I'm not sure the most prudent approach.
5 So, in your consideration of what happened 6 here and what behaviors you need to change, I hope you 7 ponder what you might be able to do in the interim when 8 you are implementing an activity that has the potential 9 to negatively affect Safety Conscious Work Environment; 10 and you do it in such a way that you hope it doesn't.
11 Hopefully, there will be some way that you can assess 12 that on a more timely basis, so that issues don't fester 13 and you don't find out about them once per year.
14 MR. BEZILLA: Understand and 15 agree. Okay.
16 Next slide.
17 This next slide depicts our recent Safety 18 Culture Assessment results as compared to those from 19 November of 2003. As you can see, the commitment areas 20 remain white.
21 In the policy or corporate level commitment 22 area, areas remain stable, with the exception being 23 Nuclear Oversight where it improved to green.
24 In the plant management commitment areas -- in 25 the plant management commitment area, areas maintain Marie B. Fresch & Associates 1-800-669-DEPO (3376)
80 1 stable, with the exceptions being the commitment to 2 safety and commitment to continuous improvements, which 3 improved to white.
4 And in the individual commitment area, areas 5 remain stable with the exception being rigorous work 6 control and prudent approach which improved to green.
7 The one area that remains stable at yellow, 8 drive for excellence is an area of focus for us. The 9 key inputs to this area that kept us yellow were some 10 hardware metrics, where we have not yet achieved our 11 goals. And second, a few metrics associated with the 12 Corrective Action Program, timeliness, as an example, 13 that aligned with the improvements we're working to 14 achieve that Bob talked about a little bit earlier when 15 he went over that Corrective Action Program actions.
16 A question one could have would be how did the 17 Safety Conscious Work Environment Survey results 18 correlate or not with the Safety Culture Assessment?
19 So, what we have to remember is that the Safety 20 Conscious Work Environment Survey is an input to the 21 Safety Culture Assessment. It's an important input, but 22 it's just one of the inputs. And remember, there were 23 noteworthy positives from that survey that were input 24 into this Safety Culture Assessment.
25 So, in summary, I and my team are focused on Marie B. Fresch & Associates 1-800-669-DEPO (3376)
81 1 recent Safety Conscious Work Environment Internal Survey 2 results to understand the drivers, and then determine 3 and take the actions needed to address those drivers.
4 And from a Safety Culture perspective, right, that being 5 that assembly of characteristics and attitudes in the 6 organizations and individuals which establishes an 7 overriding priority towards nuclear safety activities, 8 and ensures that issues receive the attention warranted 9 by their significance, is maintained visible and is kept 10 in the day-to-day dialogue amongst, I'll say, us and our 11 people. All right?
12 Through this I believe we'll be able to assure 13 safe and conservative operation at Davis-Besse.
14 Questions?
15 Okay, with that, let me turn it over to Barry.
16 MR. ALLEN: Thank you, Mark.
17 I would like to briefly discuss our continued 18 positive progress and reducing our backlogs.
19 Next slide.
20 This is a graph of our total site workload, 21 all documents, that we continue to steadily reduce our 22 overall site workload.
23 Jack, although you recall we started up with 24 over 18,000 individual work items earlier this year. We 25 are now below 13,000 work items and turning in the right Marie B. Fresch & Associates 1-800-669-DEPO (3376)
82 1 direction. We feel like this is a good pace for us, and 2 continue to have progress in the correct direction.
3 Next slide.
4 MR. GROBE: Barry, just so 5 we understand these graphs. These include not only 6 those activities that were open at the time of restart, 7 but anything that's been generated since then?
8 MR. ALLEN: That's correct, 9 Jack. So, if you see, all the incoming items, we're 10 always generating new work items and that influx, that 11 generation rate has been kept up with, and we're also 12 working off additional items. So, this is overall 13 total.
14 In the preventative maintenance area, we had 15 the discussions earlier in the year about the 16 preventative maintenance tasks which we had deferred 17 from the extended outage because the equipment was 18 unavailable to perform the p.m. PM tests on. At this 19 point, we have worked approximately 96 percent of our 20 deferred preventative maintenance backlog. And we only 21 have 13 items left open total. That's not just the 22 original ones, that's 13 total. And those are all 23 scheduled to work. So, feel very good about the 24 progress we've made in the preventative maintenance 25 backlog area.
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83 1 Next slide.
2 We also --
3 MR. THOMAS: Barry, just a 4 quick question. On the preventative maintenance items, 5 you're now reflecting the backlog number. Are a large 6 number that are PMI, deep in their grace period. Would 7 you say that's a high number of items, a low number of 8 items, or about where you feel they should be? If I 9 recall, 150 to 200 items, give or take.
10 MR. ALLEN: Scott, we would, 11 the last report I had, we had, equivalent to nine 12 percent would be in deep grace. Our current goal is to 13 be less than ten percent. So, I would say we're 14 satisfactory. We would like to, as we get these 15 resolved, not have probably quite so many there, but we 16 are within the goals that we set for this year, being 17 less than ten percent deep in grace.
18 MR. THOMAS: Okay.
19 MR. ALLEN: In the 20 corrective action arena, we continue to make very steady 21 progress. You can see downward trend on condition 22 reports, where we've gone from 3,900 to 1,100. And, 23 again, corrective actions, a similar decline.
24 And just kind of in perspective, since the 25 last public meeting, condition reports we've worked off Marie B. Fresch & Associates 1-800-669-DEPO (3376)
84 1 a total of 232 since we last met. And of corrective 2 actions, we have 555 fewer corrective actions than at 3 the last public meeting.
4 Next slide.
5 Procedure change requests. We had some 6 earlier discussions about procedure change requests.
7 This was not a focus item for us early in the year; 8 however, late summer, early fall, we looked and realized 9 that our procedure change request backlog was, I'll say, 10 fluctuating fairly stable around 1,800 to say 2,200 11 items.
12 So, therefore, as we discussed with the 13 Operations effort, we began laying out our effort to go 14 address our procedure change requests. Now we have that 15 working. Still fairly early. But we still have 16 resolved 17 percent of the backlog that we had 17 identified in August, and have that trending in the 18 proper direction.
19 Next slide.
20 In accordance with the Integrated Restart 21 Report, we've now completed 27 of our 38 Appendix A 22 commitments, and we've also completed 59 of 94 23 Operational Improvement Plan commitments as scheduled.
24 So, really looking at our backlog in summary, 25 we continue to work off approximately 750 more open Marie B. Fresch & Associates 1-800-669-DEPO (3376)
85 1 items each month than we receive. So, we feel very good 2 about the progress we're making on backlogs.
3 MR. GROBE: Barry, on the 4 Operation Improvement Plan and the Integrated Restart 5 Report commitments, many of those are commitments to put 6 some activity in place, but not necessarily complete it.
7 Develop a program to accomplish something.
8 How are you tracking the implementation of 9 those programs; where does that fall?
10 MR. ALLEN: I'm not sure.
11 Well, I'll let -- Mark understood the question.
12 MR. BEZILLA: Jack, we have 13 our Operational Improvement Plan performance indicators, 14 and on a number of those items, in addition to putting 15 the thing in place, we also have commitments to do like 16 self-assessments or effectiveness reviews. So, those 17 are a couple ways in which we can check how we're doing 18 as far as performance.
19 MR. GROBE: Okay.
20 MS. LIPA: Barry, with the 21 backlog reduction efforts, looks like you've been able 22 to lower a lot of those numbers, but I wonder if you've 23 done an assessment to see what kind of impact you might 24 have from end of the year, vacation plans, preparations 25 for the mid-cycle and the actual mid-cycle. Do you Marie B. Fresch & Associates 1-800-669-DEPO (3376)
86 1 expect that to kind of deter some of your progress here 2 in the backlogs?
3 MR. BEZILLA: Let me answer 4 that, Christine. So, you're right. And we expected 5 through the holidays we'd probably flat line on the 6 backlog reduction. And also when we get into our 7 mid-cycle, that may be another area, another period of 8 time where we would flat line. But I believe even with 9 those two periods flat lining, we'll be able to achieve 10 our 4 to 6 thousand steady state numbers by the spring 11 of 2006.
12 And, as an example, over Thanksgiving, which 13 was a pretty short week, it was like three days, 14 although it was probably two and a half days. And, we 15 still lowered our numbers by about 60 that week. So, 16 even with that short week, we saw a reduction in overall 17 numbers.
18 MR. THOMAS: Do you believe 19 this reduction reflects a pretty good mix of more 20 difficult items and easier items, or? I guess what I'm 21 getting at, you could be working off the easier items to 22 get this steady down slope on your work-off curve, and 23 at the end be stuck with the bigger, more difficult 24 issues to work off. I guess I'm asking what your 25 opinion is on the mix of items that are being worked Marie B. Fresch & Associates 1-800-669-DEPO (3376)
87 1 off?
2 MR. ALLEN: Scott, you know, 3 we've gone from an 18,000 something to 12,000. I don't 4 think we had 6,000 easy things to go pick off, so.
5 MR. THOMAS: I don't want to 6 minimize it by saying easy, but there are some of your 7 corrective actions that are easier to fix than.
8 MR. ALLEN: What we focus 9 the organization on and what we track and trend every 10 week is how are we doing resolving those issues that 11 have safety significance versus those items that are, 12 say, nonsafety consequential, nonconditions adverse to 13 quality.
14 And, so, for instance, on the latest graphs 15 that I've seen, we continue to trend downward on the 16 items that have the safety significance. And we're 17 trending down much less lower or maybe more flat lined 18 at certain times on the items that are nonconsequential 19 with respect to safety.
20 The maintenance items, they're all laid out 21 and scheduled per the equipment work weeks, you know, 22 per the normal work week progress. So, it's just as the 23 equipment trains or equipment is available to work on, 24 we perform those.
25 And then, engineering, which is a significant Marie B. Fresch & Associates 1-800-669-DEPO (3376)
88 1 piece of the backlog, we started again with the highest, 2 most risk significant safety systems to work through all 3 the issues related to those.
4 So, we feel like we have a very balanced 5 approach and strategy to make sure we maintain the right 6 focus on the safety significant items.
7 MR. LOEHLEIN: I would like to 8 add to that, Scott. In the engineering end, I would say 9 it's more typically there are those items that take, 10 become harder, but they just take more time because they 11 involve modifications and specification replacement 12 items and so forth. Some of that work is even going to 13 be implemented until 14 RFO, so we have all the 14 preparation work to do between now and then. And they 15 tend to populate the items that we're going to be doing 16 later.
17 So, the smart thing to do, which we've been 18 doing now, is a lot of the smaller items that we can do 19 now or act on now and taking care of in parallel perhaps 20 with those longer duration implementation.
21 So, we think we have a good methodology we're 22 applying to make sure we get to all of them during Cycle 23 14 that we want to get to, but it is basically true that 24 those that take longer to develop are the ones that are 25 going to be done later in the period.
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89 1 MR. THOMAS: Okay.
2 MR. REYNOLDS: Your backlog 3 reduction effort, is that being accomplished by extra 4 overtime by your current staff, or the addition of 5 Davis-Besse staff, or the use of staff from outside 6 Davis-Besse, but from FENOC or from contractors, or all 7 the above?
8 MR. BEZILLA: Yes.
9 MR. REYNOLDS: All the above, 10 okay. So, you expect, I guess, when you get down to 11 your workload, that you no longer have your extra 12 contractors, your extra FENOC staff, your extra 13 Davis-Besse staff and overtime?
14 MR. ALLEN: That's correct.
15 MR. REYNOLDS: You don't have, 16 I guess, lessons learned from this reduction, in how to 17 deal with that when the time comes, reduction in 18 personnel, if that's the case?
19 MR. ALLEN: Steve, one of 20 the strategies we're using, for instance, this is while 21 we're utilizing one of the procedures in condition 22 reports. This is what we're working on in the 23 Operations Department. We want to set up a backlog 24 effort to go deal with the backlog. Okay. Meanwhile, 25 we want the Operations Department to be set up in Marie B. Fresch & Associates 1-800-669-DEPO (3376)
90 1 dealing with incoming, right, so, we can get to the part 2 that's set up to deal with real life incoming and 3 maintain steady state.
4 Then as the backlog works off, we can disburse 5 our resources back to wherever they came from. And when 6 the backlog effort is gone, we will have been tracking 7 and trending on how we're doing on what we'll call our 8 managed workload.
9 So, we're trying not to let those become 10 confused in resources, intermingled there, if you will.
11 We're trying to make sure we can manage our daily 12 business and then we measure and monitor our backlog 13 reduction.
14 MR. REYNOLDS: Sure, I 15 understand. I was just thinking. I think when you're 16 talking about the Safety Conscious Work Environment 17 Survey, you implied or I inferred that part of that 18 negative trend may have been the result of the 19 reorganization with some people. And since you have 20 extra staff for your backlog effort, I was asking you, 21 were you going to do anything different or were you 22 sensitive to that impact by letting those people go when 23 the time came?
24 MR. BEZILLA: Steve, when we 25 went through the reorganization, we said what do we need Marie B. Fresch & Associates 1-800-669-DEPO (3376)
91 1 to run steady state. And Davis-Besse said, we're not at 2 steady state, so we're going to need additional 3 resource resources. So, we kept a number of temporary assignment 4 individuals and we brought in some contracted resource resources 5 to work on specific projects.
6 What we'll do, as Barry said, as those work off 7 over the next year plus, we get down to our normal 8 workload, we'll see if our resources can sustain the 9 incoming and just maintain that level.
10 And we know we may have to adjust some resources at 11 the site level or fleet site level to make sure that 12 happens, but right now we think we have the right, I'll 13 say, staffing supplemented by either temporary assigns 14 or our contracted resource to work this backlog down and 15 get us to steady state.
16 MR. REYNOLDS: I guess I'm not 17 making myself clear. I understand that you got the 18 right staff, and you're supplementing that, but even 19 though you went to the right staffing level, you implied 20 that that had a negative impact on the Safety Conscious 21 Work Environment Survey, if I understood you correctly.
22 MR. BEZILLA: That's correct.
23 MR. REYNOLDS: My question was, 24 when you get rid of the supplemental staff, even though 25 it's, you know, you think it's the right thing to do; Marie B. Fresch & Associates 1-800-669-DEPO (3376)
92 1 are you going to management that from a communication 2 standpoint, so you don't have a negative impact on your 3 Safety Conscious Work Environment, if you're truly doing 4 the right thing.
5 MR. ALLEN: Yes.
6 MR. REYNOLDS: So, people don't 7 have a misperception -- misconception and has a 8 negative; you are doing the right thing, you have a 9 negative impact. That was my question, maybe I wasn't 10 clear.
11 MR. ALLEN: I believe Mark 12 talked earlier about reviewing and assessing the data, 13 and then we're, with the management team, getting groups 14 of folks together to ask them why folks say this; why do 15 they feel that; why do they get that perception. Try to 16 understand, you know, the issues that you're discussing.
17 And, we'll take that data along with Doctor 18 Haber, the action plans, and we'll take, in response to 19 that, should help us look for the future activities 20 where if we need to do, apply those lessons learned in 21 the future also, Steve.
22 MR. REYNOLDS: Okay.
23 MR. BEZILLA: Let me add one 24 thing, Steve. When we get to the spring of 2006 and we 25 get through the outage we should be at the 4 to 6 Marie B. Fresch & Associates 1-800-669-DEPO (3376)
93 1 thousand level. And the people ought to say, we can do 2 this, this isn't a problem, it's a normal work-week type 3 stuff, and only occasionally due to emergent issues or 4 problems do we have to come in and spend extra time.
5 So, the goal is to get us in that mindset, so 6 when we get there, and the extra help goes away, it's 7 like "No problem. We're good." Okay. That's where we 8 want to end up.
9 MR. REYNOLDS: Right. I see.
10 It would just be disappointing in December of 2006 or 11 November of 2006 there is a negative trend of Safety 12 Conscious Work Environment and that's because we let all 13 the extra people go. Well, you didn't apply lessons 14 learned. That's my point.
15 MR. BEZILLA: Got it.
16 MR. ALLEN: Next slide.
17 Thank you.
18 Next, I'll provide a brief update on our 19 Mid-Cycle Outage preparations. Our Mid-Cycle Outage is 20 scheduled to begin January 17th. Our major projects 21 include our Once-Through Steam Generator Eddy Current 22 Testing, also our Reactor Vessel Head and Under Vessel 23 Inspections, also Boric Acid Corrosion Control 24 Inspections, and also Reactor Coolant Pump Inspections.
25 Specifically, for the Reactor Coolant Pump Marie B. Fresch & Associates 1-800-669-DEPO (3376)
94 1 Inspections, Engineering has developed specific 2 inspection criteria in accordance with regulations and 3 ASME sectional letter requirements to inspect pump cover 4 to gasket leakage to see, determine if any leakage 5 exists.
6 If we do find reactor coolant pump outer 7 gasket leakage in either reactor coolant pump; 2-1 or 8 2-2, then we'll replace both reactor coolant pumps 2-1 9 and 2-2. So, we have that criteria established by 10 engineering. We'll perform that inspection. If we do 11 have a leakage past the outer gasket, we do have 12 contingency plans to go replace both pumps and the 13 motors for that replacement and also refurbish; and 14 that's on deck.
15 Our special projects --
16 MR. GROBE: During this 17 Mid-Cycle Outage?
18 MR. ALLEN: During this 19 mid-cycle, Jack.
20 Our special projects group is developing full 21 contingency plans for that contingent effort.
22 MS. LIPA: Do you plan to 23 walk down all four pumps to look for leakage or just 24 these two?
25 MR. ALLEN: Just these two.
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95 1 These two have not been replaced; the other two were 2 previously replaced and we know the gaskets were in good 3 shape. These we believe are in good shape, have 4 confidence that they will make it to 14 RFO with no 5 leakage, but we do want to be prepared; and if they do 6 have leakage past the outer gasket, then we want to 7 replace both during this mid-cycle.
8 MR. REYNOLDS: Do you happen to 9 know when the last time the other two, when those 10 gaskets, outer gaskets were replaced?
11 MR. BEZILLA: On group one, 12 Steve?
13 MR. REYNOLDS: Pardon?
14 MR. BEZILLA: On group one.
15 MR. REYNOLDS: The two you're 16 not going to inspect.
17 MR. REYNOLDS MR. BEZILLA: This past 18 outage, I believe. Right?
19 Yes, that's correct.
20 MR. REYNOLDS: Thank you.
21 MR. ALLEN: In preparing for 22 the mid-cycle, we've had two fleet reviews of our outage 23 readiness. We've had a six-month readiness review in 24 July. And we also had a two-month readiness review this 25 past November. Additionally, since that time, we also Marie B. Fresch & Associates 1-800-669-DEPO (3376)
96 1 performed weekly outage project readiness reviews with 2 the senior management team.
3 From an execution perspective, the Maintenance 4 disciplines are walking down all their mid-cycle orders.
5 And Operations is developing a playbook, if you will, 6 which assigns throughout shutdown, outage, and startup, 7 individual tasks at individual levels, who we plan on 8 performing certain tasks.
9 So, we're getting that all laid out so 10 individuals performing those activities will have plenty 11 of time to prepare for those operational activities.
12 So, from a mid-cycle perspective and in 13 closing, we believe we are poised for success in the 14 mid-cycle outage. We will improve the material 15 condition of the plant. And our shutdown outage safety 16 implementation will be set.
17 Any questions on mid-cycle preps? If not, I 18 would like to turn the presentation over to Ray.
19 MR. HRUBY: Thanks, Barry.
20 Good evening.
21 As Barry said, my name is Ray Hruby. I'm the 22 new Manager of Nuclear Oversight, and I'm looking 23 forward to working here at Davis-Besse in an independent 24 oversight capacity to help to improve the performance of 25 this station.
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97 1 Senior management team here has already 2 discussed some of the recent progress the station has 3 made. Quality Oversight Organization agrees that some 4 progress has been made; however, there is still room for 5 additional improvement in several areas here at 6 Davis-Besse.
7 Today, I will be presenting some of the 8 Quality Oversight Organization's independent 9 observations. And some of those observations include 10 the third quarter assessment report findings, and also 11 the Safety Conscious Work Environment interviews that we 12 conducted in Nuclear Oversight.
13 MR. THOMAS: Ray, can I ask 14 you a quick question before you get started?
15 MR. HRUBY: Yes.
16 MR. THOMAS: I looked ahead, 17 I cheated a little bit, to see what you were going to 18 talk about. I have a specific interest, if you could 19 cover as part of your discussion, the specific 20 functional area that's Operations, where you talk about 21 control room conduct and environment, surveillance 22 tests, inspection schedule, technical specifications 23 program, operator rounds and logs, chart quarters, and 24 seminar readiness; and, specifically, the fact that in 25 all those areas, nothing was rated higher than Marie B. Fresch & Associates 1-800-669-DEPO (3376)
98 1 marginally effective.
2 And I just wanted some insights from QA, why 3 you think that is so. So, if you could weave that into 4 your presentation, I would appreciate it.
5 MR. HRUBY: I understand, 6 you want some quality oversight insights on Operations' 7 recent performance?
8 MR. THOMAS: That's correct.
9 MR. HRUBY: I want to begin 10 by presenting some of the results from the Quality 11 Oversight Organization's third quarter assessment.
12 Quality Oversight audited 25 primary elements, 13 13 program areas in the four functional areas during the 14 third quarter. Continuous assessment process also 15 continued to be implemented.
16 There are four performance categories that are 17 used to rate the effectiveness of programs and primary 18 elements. These ratings are fully effective or 19 effective, not fully effective or satisfactory, 20 marginally effective, and ineffective.
21 During the third quarter as shown on the 22 slide, six primary elements were rated as fully 23 effective, twelve were rated as satisfactory, and seven 24 primarily element were rated as marginally effective.
25 The following is an overview of the primary Marie B. Fresch & Associates 1-800-669-DEPO (3376)
99 1 elements that were rated marginally effective. And in 2 the Operations area, the primary elements of the control 3 room conduct and environment and surveillance tests 4 inspection schedule and technical specification program 5 were both rated marginal.
6 I'm going to try to answer some of Scott's 7 question.
8 What we're seeing is that Operations has 9 improved in the conduct of some activities, like prejob 10 briefs and also some areas in control room 11 communications; however, there are other areas that need 12 to be improved.
13 One of these that we've seen is conducting 14 multi-discipline prejob briefs. And, we've seen a 15 number of instances where the Operations group and the 16 IAC group perhaps did not perform a collective prejob 17 brief. And what happens is there could be a 18 miscommunication. We've seen at least one incident that 19 was caused by that, or at least a combination prejob 20 brief may have contributed to that.
21 There are other cases where -- and again, 22 we're seeing some of the same attention to detail issues 23 that the line is observing; people pulling the wrong 24 procedures. And I think some of that has to do with 25 maybe a need for improvement in peer checking, Marie B. Fresch & Associates 1-800-669-DEPO (3376)
100 1 self-checking skills, implementation of Human 2 Performance enhancement tools that we have, the 3 event-free tools that we talk about.
4 Those are some of my insights. I don't know 5 if that --
6 MR. THOMAS: Well, I assume 7 you presented your, you know, you haven't waited until 8 the completion of your reports to share the insights 9 with management. I guess, I ask your opinion, have they 10 been receptive, have the issues been entered in the 11 Corrective Action Program, that effective corrective 12 actions been at least proposed if not fully implemented 13 to address your issues?
14 MR. HRUBY: Well, the 15 Quality Oversight group wrote a number of condition 16 reports; a number of them dealt with procedure 17 compliance, steps not adhered to. Some of them had to 18 do with records not being sent to records management, 19 which also is procedure compliance issue.
20 We've seen some instances where operator 21 response to enunciator annunciator alarms needs to be improved.
22 Those were documented in condition reports by the 23 oversight group and put in the Corrective Action Program 24 and assigned to line management and they are responding 25 to those identified conditions.
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101 1 MR. THOMAS: Okay.
2 MR. HRUBY: Another area 3 that was rated marginally effective was in the work 4 management area, and it's the primary element of 5 Maintenance work practices.
6 The Engineering area is also rated marginally 7 effective and that was a reconciliation over the last 8 two years. The Engineering area, which is all the 9 primary elements, was reconciled during the third 10 quarter.
11 In the Procurement area, the primary element 12 of control purchased items and services. In the 13 Corrective Action area, the primary elements of 14 evaluation and also the ASME code work. And last in 15 Training, the primary element of management and training 16 processes and resources.
17 And all these primary elements were evaluated 18 over a two-year period, except for Operations and 19 Procurement, and those were evaluated over a period of 20 one year and 18 months respectively.
21 Next, I want to talk about some of the 22 independent insights and discuss some future focus 23 areas. First, the Corrective Action Program is arguably 24 the most important process in a nuclear power plant.
25 Davis-Besse site has a relatively large backlog of Marie B. Fresch & Associates 1-800-669-DEPO (3376)
102 1 documents, especially condition reports and corrective 2 actions. Although the line organization has made 3 progress in reducing the overall document backlog, 4 management needs to focus priorities on resolving 5 conditions adverse to quality in a timely manner.
6 Second, I want to discuss organizational 7 behaviors. There have been several past incidents that 8 have occurred while restarting the unit from the outage 9 and recovering from the recent August reactor trip.
10 These include previously documented containment spray 11 pump 1-1 breaker modification issue, the previously 12 mentioned feedwater 78 valve near miss issue, and most 13 recently the main steam safety valve issue.
14 Senior management needs to ensure that line 15 organization behaviors continue to meet established 16 standards and expectations, especially when the 17 organization is under scheduled stress.
18 Third, as documented in the third quarter 19 report, the Quality Oversight Organization continues to 20 observe instances where the line organization is not 21 always complying with procedures. Processes are 22 designed to ensure the nuclear power plant is operated 23 and maintained in compliance with the license design 24 basis and other regulatory requirements.
25 Procedures were developed to implement and Marie B. Fresch & Associates 1-800-669-DEPO (3376)
103 1 control these processes. Proper and consistent use of 2 and adherence to procedures is of the utmost importance 3 to ensure these processes are working as designed.
4 Additional management attention is necessary to ensure 5 that individuals understand the importance of following 6 procedures.
7 Next, I want to discuss some future focus 8 areas. The first is, first future focus area is on 9 Operations' performance, specifically in the area of 10 technical specification compliance and also conduct of 11 Operations.
12 The second focus area is the implementation of 13 the recent FENOC reorganization. Since this 14 reorganization is a significant change to the overall 15 FENOC organization, Quality Oversight group has adopted 16 a fleet approach to assessing the impact of these 17 organizational changes on the individual station's 18 performance.
19 Quality Oversight representatives from all 20 three FENOC sites developed a common assessment plan and 21 oversight personnel for implementing this plan by 22 assessing respective station performance using the 23 specific attributes. The results of this assessment are 24 expected to be included in the first quarter of 2005 25 report.
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104 1 The third area of focus is training. The 2 fourth area is the implementation of the Corrective 3 Action Program.
4 In addition to the timeliness issues discussed 5 above, there also been recent issues raised in regards 6 to trending, self-assessments, prioritization, and 7 corrective action closure. And Quality Oversight also 8 identified many of these areas in the Corrective Action 9 Program.
10 The last area is emergency preparedness, and 11 this area is scheduled to be reconciled in the fourth 12 quarter and will be documented in the fourth quarter 13 report.
14 Quality Oversight intends to closely monitor 15 these future focus areas.
16 Are there any questions to this point?
17 Okay, next I want to talk about the 18 Oversight's Safety Conscious Work Environment interview 19 results. Quality Oversight Organization performed an 20 Independent Assessment of Safety Culture/Safety 21 Conscious Work Environment at Davis-Besse by conducting 22 interviews, from October 11th through the 13th of 2004.
23 And the results of these were documented in a quality 24 field observation. I believe you received a copy of 25 those also.
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105 1 82 individuals or approximately 10 percent of 2 the Davis-Besse workforce were interviewed. The results 3 and observations from the Quality Oversight interviews 4 were closely correlated with the results from the recent 5 SCWE survey that Mark discussed in his presentation.
6 I now would like to share some of the more 7 notable observations from the interviews. The first 8 observation has to do with management behaviors.
9 The results indicate that some management 10 behaviors were believed to be an issue by the workforce.
11 Number of interviewees mentioned the previously 12 discussed feedwater 78 valve issue and the 13 reorganization as contributors to this indication.
14 The second observation concerns the recent 15 FENOC organization, reorganization. As previously 16 discussed, the number of interviewees indicates that the 17 reorganization was negatively received by the workforce.
18 Third, a very high percentage of the 19 interviewees believed that our Safety Culture at 20 Davis-Besse supports the safe operation of the plant 21 when the management wants employees to report problems 22 and adverse conditions.
23 The fourth has to do with raising nuclear 24 safety concerns. A very high percentage also believe 25 that they can raise nuclear safety or quality issues Marie B. Fresch & Associates 1-800-669-DEPO (3376)
106 1 without the fear of retaliation.
2 The last observation has to do again with the 3 Corrective Action Program. Results indicate that there 4 have been, there has been a continuous increase over the 5 last three surveys in the number of employees raising 6 issues by the Corrective Action Program. So, we are 7 seeing a positive trend in the use of the Corrective 8 Action Program by the employees to recognize concerns.
9 That concludes my presentation. Any 10 questions?
11 MR. SUH: Just a question, 12 Ray. I know it's, you haven't been in your position 13 that long. I was wondering what your opinion was of the 14 engineering area. I didn't see that in your focus, list 15 of focus areas. Was that something you considered and 16 just -- I mean, only so many things can go on that list, 17 obviously.
18 MR. HRUBY: We, again, 19 implement the Continuous Assessment Process, so, and 20 also there are some primary elements that were in 21 Engineering and third quarter report. There's going to 22 be some in the fourth quarter report also. And as they 23 continue this assessment process, we're able to look at 24 things independently as we see the need to.
25 We are looking closely at Engineering as we Marie B. Fresch & Associates 1-800-669-DEPO (3376)
107 1 are at the other functional areas, but what I pulled out 2 as my focus areas were the organizations focus areas 3 are, are areas of specific, that merits specific 4 attention.
5 MS. LIPA: Ray, you 6 mentioned earlier that Oversight initiated CRs for some 7 findings, but when you put your conclusions together and 8 present it to the line management, do they also initiate 9 condition reports and do you look to see what kind of 10 condition reports they write or is it mostly just you 11 guys writing the condition reports?
12 MR. HRUBY: Well, to give 13 you an example, we had an issue where Quality Oversight 14 wrote a condition report on the significant conditions 15 adverse to quality of preventative recurrence and 16 remedial actions. We were not satisfied with the 17 timeliness of the resolution of issues. The senior 18 leadership team within a few days took that and convened 19 a special meeting to sit down and review all those 20 corrective actions.
21 So, the organization is responding to the 22 issues that are identified by the quality organization.
23 They are also responding, as I said earlier, in about as 24 timely manner to the Quality Organization identified 25 conditions as they are to the line organization's.
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108 1 As the organization investigates condition 2 reports, there have been instances where they've written 3 additional condition reports based on additional areas 4 that they have discovered other conditions.
5 So, I hope that's answering your question.
6 MS. LIPA: Yes, thank you.
7 MR. REYNOLDS: I have a 8 question. I don't know if it's for Oversight or for the 9 line, but I am referring to your Davis-Besse Cycle 14 10 Post-restart Commitments October 2004 Review. And what 11 we've heard tonight is, I guess, marginally effective in 12 Operations performance and then unsatisfactory ratings 13 in trending, in various groups.
14 And, I would point to a couple items. This is 15 in the Action Commitment Summary Section, page 1 of 5 16 and 3 of 5. I'll start with 3 of 5 first, because 17 Christine brought it up earlier. Action item 9.4. Have 18 it here as complete as of February of 2004, reestablish 19 the Corrective Action Program Trending Process. This 20 would imply that's implemented. And if I go back to 21 page 1 of 5, item 1.6, it says completed June of '04.
22 Says, implement actions to improve trending of major 23 plant evolutions utilizing the management observation 24 program to track performance and feedback.
25 So, there is two Operational Improvement Plan Marie B. Fresch & Associates 1-800-669-DEPO (3376)
109 1 actions that you said were completed in the past, that a 2 more recent assessment says, you know, at least 3 effective and satisfactory.
4 And then the third item you talked about is 5 still on page 1 of 5, item 2.3; says it was completed in 6 March of '04. Says, implement Operations improvement, 7 Implementation Action Plan including strengthening 8 operating crews, including assessment of operators 9 training, operators procedure use, improving command and 10 control, strengthening operation procedures, including 11 foundation of key operating procedures and use of prejob 12 briefs and strengthening operation management.
13 My point here is, you have three items along 14 with several others that you said were complete in the 15 past. And based on what I've heard tonight from your 16 own assessment, some self-revealing findings in 17 Operations and independent assessment, which say what 18 you implemented back then was not effective. And I 19 wondered if you're going to go back and look at these 20 items that you have as complete, and maybe dozens of 21 others that are complete, and see if they truly are 22 complete; where those were signed off as complete 23 before, which truly determine if they were effective or 24 not.
25 MR. BEZILLA: Let me answer Marie B. Fresch & Associates 1-800-669-DEPO (3376)
110 1 that. I'll answer that, Steve. On 9-4, we 2 reestablished Corrective Action Program Trending 3 Process. We did reestablish the Corrective Action 4 Program Trending Process and closed this. We knew there 5 were going to be erasions and we knew it was going to be 6 marginal at best coming out of the shoot because we have 7 been shut down for a number of months during the 8 extended outage.
9 If you jump down to 10.8, it talks about doing 10 assessment activities in the Corrective Action Program.
11 Evaluate the effectiveness of corrective actions taken 12 to improve implementation and improve trend evaluations.
13 So, we have built into the plan checks on that trending 14 program. And just through our normal self-assessment 15 process, this is an area that we knew, as Bob said, we 16 would have to continue to focus on.
17 In regard to the 1.6 item, says, implement 18 actions to improve trending of major plant evolutions.
19 We've initiated management observations for all medium 20 and high risk activities. And to my knowledge, we've 21 not had any issues with medium and high risk activities.
22 There may be one or two, but the majority of 23 those are done I think pretty well. It's routine things 24 that we're having problems on. So, I think the 25 management observation in our, I'll say, commitment to Marie B. Fresch & Associates 1-800-669-DEPO (3376)
111 1 monitor those medium and high risk things, which could 2 get us into trouble from a plant perspective, we do a 3 pretty good job. The duty team has that, and my duty 4 team makes sure we have the right management attention 5 on those tasks.
6 And the 2.3, I think it was, talks about the 7 Operations improvement, about strengthening the crews, 8 providing training, et cetera. We did that. We did 9 those things and we closed it. Now, does that mean 10 there is not room for improvement? No. Does that mean 11 we're not going to have mistakes or errors or areas of 12 improvement? No.
13 But we'll continue to monitor those. This was 14 a point in time, we took those actions, right, and now 15 we'll continue to monitor our performance; and if we 16 have to take additional actions, we'll do that, but our 17 processes are set up so we do periodic self-assessments, 18 we do focus self-assessments; oversight periodically 19 looks at those things with their program.
20 So, you know, these things were done. At a 21 point in time we said, okay, that's good, done. Now, 22 does that mean there is not going to be a hole or 23 something reappear? I can't tell you no. We'll just 24 continue monitoring, and as those things come up, put 25 them in our Corrective Action Program and we'll go Marie B. Fresch & Associates 1-800-669-DEPO (3376)
112 1 address them.
2 MR. REYNOLDS: Okay.
3 MR. BEZILLA: Okay. Next 4 slide, Kevin.
5 So, just briefly in closing, I would like to 6 thank you guys for your time, your questions and your 7 challenges. I and my team are committed to ensure a 8 safe and conservative operations at Davis-Besse and 9 we'll work hard at improving both of our critical 10 assets; that being our people, and our plant. Thank you 11 very much for the opportunity.
12 MS. LIPA: Any further 13 comments?
14 MR. GROBE: I always have 15 further comments. As many of you know, this is my last 16 Davis-Besse public meeting. There has been a few of 17 them since we started this a couple years ago.
18 I wanted to share with you that I have great 19 confidence in the future effectiveness of the 20 Davis-Besse Oversight Panel. First, the team is an 21 outstanding team led by Christine and the Region III 22 staff, Dave Passehl and Scott Thomas, as well as the 23 Bill Ruland and Gene Suh and Jon Hopkins at 24 headquarters. Exceptional team, and I know they'll 25 continue doing exceptional work.
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113 1 But, of equal importance is Steve Reynolds.
2 Steve and I have known each other for awhile. He got an 3 excellent start in his career with the NRC. He was 4 trained in Region III, and went off to headquarters and 5 did a lot of exceptional work in headquarters; including 6 he was a critical cog in the recovery of the Millstone 7 plant for the NRC side of the ledger. Came back to 8 Region III and has held a number of management positions 9 in Region III, and for the last two years has been 10 Acting Director of the Division of Reactor Projects, 11 which is arguably the most challenging management 12 position at Region III.
13 So, I have absolute confidence of Steve's 14 leadership in the panel. So, I leave with the panel in 15 very good hands. I think we've made a lot of progress 16 over the last couple of years. You have a very 17 significant challenge ahead of you.
18 One of the key root causes of the Davis-Besse 19 situation prior to February of 2002 was that management 20 wasn't setting the right expectations. Let me phrase 21 that a little differently. The staff perceived 22 management's expectations as, in one direction, which 23 was not the direction that management wanted. The 24 outcome of that was a stronger focus on production costs 25 and schedule and a lesser focus on what should be the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
114 1 prevalent priority, which is safety.
2 And, the most recent Safety Conscious Work 3 Environment Survey results indicate that staff is 4 perceiving in an increasing number of individuals that 5 management is not placing priorities on the right, the 6 right activities.
7 Now, I don't want to leave any impression that 8 this is anything like what the first survey was after 9 the shutdown, because it's not, but your challenge is to 10 find out how you set perceived expectations in the minds 11 of your staff and what you do to influence those; and 12 how you're going to effectively measure what your staff 13 is expecting, believes you're expecting of them, and 14 making sure that that trend is, is reversed.
15 And that's a big challenge. And, given what 16 you've been through over the last two and a half years, 17 I have confidence that you're up to it. I have 18 confidence that this panel will monitor you effectively 19 and hold you accountable.
20 And, I look forward to some day in the future 21 hearing that Davis-Besse is under the routine reactor 22 oversight process, but that's certainly not today.
23 Good luck. Anybody else?
24 MR. BEZILLA: Could I go back 25 for a second? I was remiss. Jack, I got caught up in Marie B. Fresch & Associates 1-800-669-DEPO (3376)
115 1 the meeting here. I also would like to extend my thanks 2 and appreciate and pass on Lew's thanks and 3 appreciation.
4 I'm not sure we would be here today without 5 you and your team's, I'll say, leadership and challenges 6 and questions. And, so, I just would like to thank you 7 and it's been a privilege. And good luck in the future.
8 I'm sure our paths may across again in your 9 new role, so I wish you the very best.
10 MR. GROBE: I know they 11 will.
12 MR. BEZILLA: And for Steve, 13 hopefully, we won't have as many opportunities with you 14 as we've had with Jack, but we look forward to working 15 with you, and working through the 350 Process and we 16 also would look forward to the day when we get back to, 17 I'll say, normal regulatory oversights. So, Steve, 18 we'll be able to continue working closely with you and 19 your team to make that happen.
20 MR. REYNOLDS: Thank you.
21 MR. BEZILLA: So, thank you 22 both, and, Jack, really thank you in your efforts. Good 23 luck in your future to you.
24 MR. GROBE: Thanks.
25 MS. LIPA: Well, in the Marie B. Fresch & Associates 1-800-669-DEPO (3376)
116 1 interest of time, what I would like to do is take a five 2 minute break and be prepared for public questions and 3 comments. Five minutes.
4 (Off the record.)
5 MS. LIPA: What we would 6 like to do is offer anybody who is a local member of the 7 public who has a comment or question for us, the 8 opportunity to come up. When I was making introductions 9 earlier, I neglected the local county officials.
10 I know I saw Jere Witt back there. Would you 11 like to stand up and introduce yourself, Jere?
12 MR. WITT: Jere Witt, 13 County Administrator.
14 MS. LIPA: Thanks, and 15 Steve.
16 MR. ARNDT: Steve Arndt, 17 Ottawa County Commissioner.
18 MS. LIPA: Any other local 19 public officials? Okay, thanks.
20 And if either of you two has a comment or 21 question, come on up.
22 MR. WITT: Thank you, 23 Christine.
24 We would like to make a comment. On behalf of 25 Ottawa County, Jack, we would like to thank you for all Marie B. Fresch & Associates 1-800-669-DEPO (3376)
117 1 your efforts with the 0350 Process. I certainly from a 2 personal note would say you've taught me a lot. I've 3 learned a lot through this process.
4 And it really, I think you've been fair.
5 You've asked the tough questions that needed to be asked 6 and dealt with this in a professional manner. And we 7 really just would like to thank you for your efforts and 8 look forward to working with this board as we move 9 forward.
10 I do have one comment. I certainly understand 11 the need for the oversight and all the things that 12 you're doing here and the plant is doing, but my comment 13 is, let's also keep in mind that we don't get so caught 14 up in surveys and those kind of things that we bog the 15 employees of this plant down to the point where they 16 can't do the job they have to do.
17 And I think as you go forward, I would ask 18 that you weigh those two issues as we make requirements 19 on the plant and on the employees here, to make sure 20 that they have the time to get their job done and not 21 always be responding to surveys or some other type of 22 questions.
23 You know, that's a tough call, and that's a 24 fine line, but just a comment to keep that in mind in 25 the future. Thank you.
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118 1 MR. GROBE: Thanks, Jere.
2 Just an observation and I don't know if you 3 folks appreciate this, but Steve and I have collectively 4 been involved in quite a few of these type of plant 5 recoveries over the years. And, in none of the 6 recoveries that I've been involved in and I don't think 7 Steve has been involved in, have we ever experienced the 8 type of dedication and commitment to the community that 9 we've seen demonstrated by the Ottawa County 10 Administration and Board of Commissioners. And it's 11 very impressive.
12 And I think a lot of the success of the public 13 outreach aspects of this panel can be attributed to the 14 commitment and dedication of the Ottawa County 15 government, so I appreciate that.
16 I think your comment, Jere, I appreciate it, 17 and I think it's a good comment for Mr. Bezilla to 18 consider in how he decides to move forward in this area.
19 MS. LIPA: Okay, do we have 20 any local members of the public who would like to come 21 up and ask a question or provide a comment to us?
22 MR. GROBE: Only easy 23 questions, save the tough ones for next time.
24 MR. CUFF: Jack, I've had 25 the opportunity to speak with you before.
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119 1 Mr. Reynolds, I appreciate the opportunity to 2 speak with you.
3 I come before you, my name is Jeff Cuff. I'll 4 introduce myself as two people. I am one of the five 5 shift managers here at this unit, running an operating 6 crew. I also humbly state that I am the supervisor who 7 reviewed the last surveillance test that ended in the 8 Operations missed boric acid heat trace test.
9 And I have two things that I would like to 10 just present to the panel. That is, the changes that 11 occurred not only in myself, but in my operating crew, 12 since that mistake was made seven weeks ago.
13 I have looked at more surveillance tests in 14 the last seven weeks than I probably have in the last 15 seven years. I have seen a lot of -- each time, it's 16 interesting that you come in on your own time, you look 17 at a surveillance test with a new set of eyes, a new set 18 of circumstances. And I've written more condition 19 reports in the last, probably, four or five weeks than I 20 have in the last two or three years on procedures, 21 because I now look at how different people view a test 22 and how they perform it based upon that.
23 And, I can tell you a simple thing of an 24 operator on a test that I reviewed had N/A'd a step, 25 marked it nonapplicable. It was a bulleted item inside Marie B. Fresch & Associates 1-800-669-DEPO (3376)
120 1 a step, and he inappropriately marked it nonapplicable.
2 I sat down with him and I discussed it and I said why 3 did you do that.
4 And we looked at the procedure, and out of 5 that came as we sung down, it wasn't just a, "I marked 6 it wrong incorrectly". It was the way this procedure is 7 formatted lends you to the error.
8 So, maybe we performed it a hundred times and 9 never made the error. This time we made it. There was 10 no consequences. Submitted a condition report. Said, 11 we need to change this procedure.
12 I'm doing more of those. When I find errors 13 on my shift, when I find errors on my peer's shifts, 14 we're driving down to find out why that mistake was 15 made. If it's a simple how they mark the step, we're 16 asking the question; how do you do that.
17 The other thing that I've seen, is I am now 18 driving my supervisors, I have three of them underneath 19 me on my crew. I'm driving them to look at low level 20 issues. How -- are they looking at regular rounds? Are 21 we looking at turnovers? Are we looking at surveillance 22 tests?
23 And I can tell you my observations and some of 24 my peers' observations, we're starting to try and look 25 very hard at low level issues. Are we seeing everyday Marie B. Fresch & Associates 1-800-669-DEPO (3376)
121 1 behaviors? Sometimes we see good behaviors on 2 clearances, but not the same behaviors when they're 3 doing their operating rounds. Why the difference? We 4 coach the operator. Put it in. Do a follow-up item.
5 I don't like to make mistakes, but what I can 6 tell you is from my perspective, and the shift managers 7 of this plant, we are seeking to drive performance 8 issues to the person performing that test provides it 9 error-free; and the test that he is given has no 10 embodied error traps inside of that.
11 Thank you.
12 MR. GROBE: Don't go away so 13 fast.
14 I appreciate your passion. And I was 15 wondering if you could share with us how you have, what 16 you have done to share some of that passion with your 17 peer shift managers?
18 MR. CUFF: We had -- how I 19 shared it with my peers. I share it with my peers every 20 time I do a surveillance review with them, because, for 21 instance, today there was an error on one of the 22 surveillance tests. And what I can tell you is, for the 23 last shift managers meeting, I looked at the five days 24 of comments that we had on all of our surveillance 25 tests, and the comments came down to this. The date Marie B. Fresch & Associates 1-800-669-DEPO (3376)
122 1 wasn't written neatly enough that you could discern what 2 the date was without knowing it was in the date block.
3 We look at, do those numbers stand out by themselves to 4 be numbers?
5 So, in each of these times when we sit down as 6 the off-going crew, the four SROs and the off-going 7 crew, the supervisor reviewing it. We sit down, and I 8 say, "Here's what I'm seeing; you guys do this, this, 9 this really well and here's where you have areas to 10 improve in." And when we find the mistakes, it's the 11 five of us sitting down and saying, "What caused the 12 mistake and how do we correct it?"
13 So, it's done on a sit down at the table every 14 day when you're doing the surveillance test review.
15 Does that answer your question?
16 MR. GROBE: Yeah, thank you.
17 MR. CUFF: Now can I run?
18 MS. LIPA: Any other 19 questions?
20 We can expand the population to anybody in the 21 room who has a question for us.
22 MS. CALLAHAN: Hello. My name 23 is Bridgette Callahan and I'm representing Ohio Citizens 24 in Action.
25 And this is regarding a letter that we sent Marie B. Fresch & Associates 1-800-669-DEPO (3376)
123 1 you, Mr. Grobe, November 30th from Ohio Citizens Action 2 and the Union of Concerned Scientists.
3 It was suggestions of you doing a Mid-Cycle 4 Outage, we felt should be addressed to FirstEnergy. The 5 first suggestion was regarding testing those two pumps, 6 which they already said they would do.
7 The second one was regarding the newly 8 installed Bentley Nevada diagnostic equipment, which 9 they use to diagnose the pump performance. The reason 10 we felt it was warranted that they should do, the NRC 11 should assess the results from this; just to quote a 12 letter from you, Mr. Grobe, to Mr. Myers.
13 Quote, "The team determined that the 14 Licensee's evaluations of the RC case to cover gasket 15 leakage were based upon testing that one did not use the 16 same methodology from outage to outage. Two, did not 17 attempt to normalize the data from outage to outage.
18 Three, did not consider the impact of reactor coolant 19 pressure and temperature conditions on the test results.
20 And, four, was only intended to verify that leak 21 detection lines were open and not blocked. We believe 22 that the NRC should evaluate how FirstEnergy has 23 integrated this data with past data to verify that 24 FirstEnergy is not using this data to ensure the pump 25 was running."
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124 1 Since we didn't get a response to our letter, 2 we were wondering whether that was resolved or your 3 thoughts on that; and of course, it gives me the 4 opportunity to pass this letter on to Mr. Reynolds now.
5 MR. GROBE: I can assure you 6 Mr. Reynolds has seen it. I was in Washington actually 7 when I got it via email from Dave Lochbaum. We put your 8 letter into our process that includes our engineering 9 folks reviewing that specific recommendation, and we'll 10 get back to you.
11 MS. CALLAHAN: Okay, thank you, 12 Mr. Grobe.
13 MR. GROBE: Um-hmm.
14 MS. LIPA: Any other 15 questions or comments for us today?
16 Okay. I would like to thank you all for 17 coming. Right now we're planning on having our next 18 meeting in February. We don't have a specific date yet, 19 but we'll keep the public appraised and the plant 20 appraised of the date as we set it.
21 If there is any questions that you have, we'll 22 be available for a few more minutes up here. Thank you 23 and good night.
24 (Off the record.)
25 Marie B. Fresch & Associates 1-800-669-DEPO (3376)
125 1 CERTIFICATE 2 I, Marie B. Fresch, Registered Merit Reporter, and Notary Public in and for the State of Ohio, duly 3 commissioned and qualified, do hereby certify that the foregoing transcript is a true and accurate record of 4 the foregoing meeting.
5 IN WITNESS WHEREOF, I have hereunto set my hand 6 and affixed my seal of office at Norwalk, Ohio, on the 13th day of December, 2004.
7 8
9 MARIE B. FRESCH, RMR Notary Public, State of Ohio 10 My Commission expires: 10-10-08 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Marie B. Fresch & Associates 1-800-669-DEPO (3376)