ML071640189

Submittal of the Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan for the Davis Besse Power Station - Year 2007

ML071640189
Person / Time
Site:	Davis Besse
Issue date:	06/11/2007
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Caldwell J Region 3 Administrator
References
1-1494
Download: ML071640189 (37)

Text

FENOC 550 1 Noiih S!aie Route 2 FirstEnergy Nuclear Operating Company Oak Haibor Ohio 43339 Mark B.Bezilla V!ce Presidevi - Nucleai Docket Number 50-346 License Number NPF-3 Serial Number 1- 1494 June 11, 2007 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region 111 2443 Warrenville Road, Suite 2 10 Lisle, IL 60532-4352

Subject:

Submittal of the Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan for the Davis-Besse Nuclear Power Station - Year 2007

Dear Mr. Caldwell:

The purpose of this letter is to submit the assessment plan and related information for the year 2007 independent assessment of the Davis-Besse Nuclear Power Station (DBNPS) Organizational Safety Culture and Safety Conscious Work Environment. The Nuclear Regulatory Commission (NRC) letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order, (letter DBNPS Log Number 1-4524) requires submittal of the external assessment organization, including the qualifications of the assessors and the scope and depth of the assessment plan, ninety (90) days prior to the assessment .

In accordance with the Confirmatory Order, the FirstEnergy Nuclear Operating Company (FENOC) is submitting the Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan, including the identification and qualifications of the assessors. The onsite portion of the assessment is scheduled to commence on October 29, 2007, with this portion of the assessment lasting approximately two weeks. A final debrief with the DBNPS staff, marking the end of the assessment, will be conducted by December 14, 2007. The final assessment report and action plans, if required, will be submitted to the NRC within 45 days following the final debrief.

RECEIVED JUN 1 3 20n7

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1494 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Raymond A. Hruby, Jr., Manager - Regulatory Compliance at (419) 321-8000.

J LJS - Commitment List - Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan - Year 2007 - Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Assessors and Qualifications - Year 2007 cc: USNRC Document Control Desk DB-1 NRC/NRR Project Manager DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1-1494 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by FirstEnergy Nuclear Operating Companys (FENOC) Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please notify the Manager - Regulatory Compliance (4 19-321-8000) at the DBNPS of any questions regarding this document or associated regulatory commitments.

COMMITMENTS DUE DATE None NIA

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1494 Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan - Year 2007 (5 pages to follow)

ORGANIZATIONAL SAFETY CULTURE AND SAFETY CONSCIOUS WORK ENVIRONMENT INDEPENDENT ASSESSMENT PLAN - YEAR 2007 NUMBER:

COIA-SC-2007 ASSESSMENT AREA:

Organizational Nuclear Safety Culture, including Safety Conscious Work Environment PURPOSE:

The purpose is to provide an independent and comprehensive assessment of the status of the existing Organizational Nuclear Safety Culture, including the Safety Conscious Work Environment (SCWE), at the Davis-Besse Nuclear Power Station (DBNPS). The assessment will be performed in accordance with the requirements of the March 8,2004, Confirmatory Order Modifying License No. NPF-3, and Davis-Besse Business Practice DBBP-VP- 0009, Management Plan for Confirmatory Order Independent Assessments. The assessment will be used to identify areas for improvement requiring corrective actions with action plans and observations for other improvement opportunities. The assessment will review the areas for improvement that were identified in the 2006 Independent Assessment and it will also be used to assess the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities in this performance area.

The final assessment report will provide an overall concluding statement of the effectiveness of the Organizational Safety Culture using the rating categories of DBBP-VP- 0009.

INDEPENDENT ASSESSMENT TEAM:

SCOPE:

The Independent Assessment Team will evaluate the following areas associated with Organizational Nuclear Safety Culture, including the SCWE:

1 . The Overall Organizational Nuclear Safety Culture at the DBNPS, including the following key cultural elements and sub-elements:

a. Nuclear Safety Values, Behaviors and Practices 0 Nuclear Safety Standards and Expectations Nuclear Safety as Top Priority 0 Operational Nuclear Safety Identification of Potential Nuclear Safety Issues Timely Resolution of Identified Nuclear Safety Issues Effective Resolution of Identified Nuclear Safety Issues 0 Continuous Improvement of Nuclear Safety Performance 0 Confidence in the Effectiveness of the Corrective Action Program for the Identification and Resolution of Adverse Trends Adverse Effects of Workload on Nuclear Safety Page 1 of 5

b. Safety Conscious Work Environment (SCWE) 0 Indicators and precursors of a potentially chilled work environment, including personal experience of receiving negative reactions for having raised potential Nuclear Safety issues or concerns.

- Influence of the General Site Environment on the SCWE

- Influence of Peers on the SCWE

- Influence of Supervision on the SCWE

- Influence of Functional Organization Management on the SCWE

- Influence of Site Senior Management on the SCWE 0 Demonstrated willingness to Take Appropriate Action

- Willingness to Inform Supervision or to Document a Potential Nuclear Safety Issue/Concern

- Willingness to Escalate a Potential Nuclear Safety Issue/Concern to Management

c. Employee Concerns Program (ECP) Effectiveness 0 ECP as an Acceptable Alternative Path for Reporting/Pursuing Potential Nuclear Safety Issues or Concerns 0 Overall Employee Confidence in the ECP 0 Bases for Employee Confidence in the ECP The Overall Nuclear Safety Culture, including the following key cultural elements and sub-elements, which correspond to the NRC RIS 2006-1 3 Safety Culture Components, will also be assessed:

a. Human Performance Cross-Cutting Components 0 Decision-Making Resources Work Control 0 Work Practices

b. Problem Identification and Resolution Cross-Cutting Components 0 Corrective Action Program 0 Operating Experience 0 Self and Independent Assessments

c. Safety Conscious Work Environment Cross-Cutting Components 0 Environment for Raising Concerns 0 Preventing, Detecting and Mitigating Perceptions of Retaliation

d. Other Safety Culture Components 0 Accountability 0 Continuous Learning Environment 0 Organizational Change Management Safety Policies Page 2 of 5

3 . The Nuclear Safety Culture Assessment (NSCA) will also include an assessment of key elements of the General Culture and Work Environment (GCWE) at the DBNPS, as industry experience indicates that low GCWE ratings are frequently precursors of potential future challenges to the Nuclear Safety Culture (NSC). In this regard, the NSCA will address environmental and programmatic areas that are important to overall performance and morale and that may have an interdependent relationship with the NSC.

4. The NSCA will also include an assessment of the following two key cultural metrics related to Leadership, Management and Supervisory Behaviors & Practices because they are indirectly related to the SCWE. Low metric ratings may be leading indicators of potential future challenges to the SCWE.

Quality of Communications with the Workforce 0 Environment of Trust and Mutual Respect

5. Evaluation of the effectiveness of the DBNPS actions to address previously-identified Areas for Improvement in the Nuclear Safety Culture, including the Safety Conscious Work Environment. This evaluation will include the Areas for Improvement and the Areas in Need of Attention that were identified in the 2006 Independent Assessment as they relate to Nuclear Safety Culture and Safety Conscious Work Environment.

6. Evaluation of the effectiveness of DBNPS self-assessment activities and self-identification of performance weaknesses.

INDEPENDENT ASSESSMENT TEAM:

John C. Guibert, SYNERGY Consulting, Team Leader 0 Howard A. Levin, SYNERGY Consulting 0 Timothy K. Snyder, SYNERGY Consulting Dennis Winchester, SYNERGY Consulting (Contingent Team Member)

Aldo Capristo, Nuclear Management Company - Point Beach Nuclear Plant, Peer Reviewer John Audas, TXU Power - Comanche Peak, Peer Reviewer The FirstEnergy Nuclear Operating Company (FENOC) has selected SYNERGY Consulting Services Corporation (SYNERGY) to perform the 2007 Assessment.

SYNERGY has extensive experience in conducting Nuclear Safety Cultural Assessments for the commercial nuclear industry, having performed more than 100 Nuclear Safety Cultural Assessments, including 48 nuclear power plant sites, 76 nuclear power plants and 2 gaseous diffusion plants. By virtue of the extent of SYNERGYS Nuclear Safety Culture Assessment activities, they are in a position to provide a meaningful fiame of reference for the assessment results.

Mr. John C. Guibert will serve as SYNERGYS project manager for the Independent Assessment. He will be assisted by Mr. Howard A. Levin and Mr. Timothy K. Snyder. All three of these individuals are principals of SYNERGY Consulting Services Corporation. Mr. Dennis Winchester is a contingent member of the Independent Assessment Team. His participation is dependent upon the final scope of the NSCA following analysis of the survey results. Mr. Aldo Page 3 of 5

Capristo and Mr. John Audas will serve as industry peer members of the Independent Assessment Team, Biographies of the Assessment Team members are attached.

SCHEDULE:

0 June 1 1, 2007: Develop, review and submit assessment plan to the NRC.

0 September 4 through September 2 1 , 2007: Administration of the Nuclear Safety Culture Assessment Survey to DBNPS employees and long-term contractors.

0 October 29 through November 2,2007: Personnel interviews and behavioral observations conducted onsite.

0 December 14,2007: Draft Assessment Report provided to FENOC/DBNPS management and conduct of final debrief (marking completion of the assessment).

December 2 1,2007: Final Assessment Report provided to FENOUDBNPS management.

Final Assessment Report and action plans (if required by findings) will be submitted to the NRC within 45 days of the completion of the on-site assessment.

ASSESSMENT METHODS:

The Assessment Team will utilize the following methods for the conduct of the Independent Assessment. The information obtained through each method will be integrated to reach conclusions and to identify potential Areas of Strength. Areas for Improvement (AFls), Areas in Need of Attention (ANAs) or other opportunities for continued improvement.

1. A Nuclear Safety Culture Assessment survey developed by SYNERGY will be used. The survey questionnaire will be very similar to that used for the 2006 Independent Assessment in order to ensure coverage of all of the necessary cultural attributes and to provide a sound basis for 2006-2007 direct trending information. All DBNPS employees and long-term contractors will be provided the opportunity to participate in this survey.

SYNERGY will utilize cultural assessment models and reporting formats to analyze and report the numerical results of the written survey. Results will be provided at various organizational levels. Individual Functional Organizations that are considered to be organizational out 1iers w i 11 be i den t i fied .

2. The Nuclear Safety Culture Assessment survey will include several opportunities for participants to provide write-in comments. The write-in comments will be analyzed by SYNERGY to validate the numerical survey results, to identify recurring themes, to obtain additional insights related to the underlying reasons for the numerical survey ratings and to identify (if applicable) additional issues not previously identified through the survey ratings.

3. The Assessment Team will conduct confidential personnel interviews of selected (by the Assessment Team) DBNPS personnel. These interviews will support a variety of assessment objectives, including the following:

To obtain information to support an assessment of the effectiveness of corrective actions taken by DBNPS to address the AFIs and ANAs identified through the 2006 Independent Assessment of the NSC and SCWE.

Page 4 of 5

To obtain information to support an assessment of the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities related to the NSCISCWE.

To obtain information on RIS 2006-1 3 attributes that are not amenable to being assessed through an all hands survey of the workforce.

To validate/obtain information on the underlying reasons for low numerical survey ratings provided by individual Functional Organizations identified by SYNERGY as 2007 outliers with respect to industry norms criteria.

To validate that the numerical survey ratings provided by individual Functional Organizations with low survey participation are representative for those organizations.

4. The Assessment Team will conduct documentation reviews. Documents that will be reviewed include, but are not limited to, the following categories:

Policies and programs related to the Nuclear Safety Culture and the Safety Conscious Work Environment.

Information related to the effectiveness of corrective actions taken by DBNPS to address the AFIs and ANAs identified through the 2006 Independent Assessment of the NSC and SCWE.

Information to the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities related to the NSCISCWE.

Information related to RIS 2006-1 3 attributes that are not amenable to being assessed through an all hands survey of the workforce.

These documentation reviews will be complemented by personnel interviews with personnel responsible for the implementation and oversight of such policies, programs and activities.

5. The Assessment Team will observe selected DBNPS activities to supplement information obtained from the above methods.

ASSESSMENT PLAN APPROVALS:

Prepared by: Date: June 8, 2007 John C,Guibert, Team Lead

\

Approved by: c \ - - Date: b(tp7 Lonxtraus$P?pject Managsr Approved by: Date: 1.!8/07 Executive Sponsor Page 5 of 5

Docket Number 50-346 License Number NPF-3 Serial Number I - 1494 Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Assessors and Qualifications - Year 2007

( 6 pages follow)

Biographies of Independent Assessment Team Members The following biographies are summary in nature. Additional details will be provided upon request .

Mr. John C. Guibert Independent Consultant SYNERGY Consulting Services Corporation Mr. Guibert will serve as SYNERGYS Project Manager for the Independent Assessment of the Organizational Nuclear Safety Culture at DBNPS. He served as Project Manager for the 2006 Independent Assessment of the Organizational Nuclear Safety Culture at DBNPS. He has previously served in this capacity for more than fifty similar Cultural Assessments.

Mr. Guibert has over 35 years of nuclear experience. He is a graduate of the United States Naval Academy and Catholic University (MSNE). Currently, he is a principal and founder of SYNERGY Consulting Services Corporation (founded in 1992). He co-developed SYNERGYS Comprehensive Cultural Assessment methodology - a process that establishes objective measures of nuclear safety and general culture based upon models of high performing enterprises.

He was formerly Senior Vice President and Chief Operating Officer of a major technical and management consulting firm serving the commercial nuclear power industry. Prior to that, he was responsible for the development and management of a nuclear consulting practice focused on improving the performance of operating nuclear power plants. His other previous experience includes management positions with another major nuclear consulting firm, technical and management positions with the Nuclear Regulatory Commission and service as an officer in the Navys nuclear power program.

Page 1 of 6

Mr. Howard A. Levin Independent Consultant SYNERGY Consulting Services Corporation Mr. Levin has over 30 years of commercial nuclear experience. He is a graduate of Massachusetts Institute of Technology. Currently, he is a principal & founder of SYNERGY Consulting Services Corporation (founded in 1992) where he is involved providing organizational development, cultural and leadership assessment services including diagnostic, remedial and performance enhancement consultation. He co-developed SYNERGY'S Comprehensive Cultural Assessment methodology - a process that establishes objective measures of nuclear safety and general culture based upon models of high performing enterprises. SYNERGY has applied this methodology in more than a hundred assessments covering the majority of the U.S. commercial nuclear power plants and several others worldwide.

Over the last several years, Mr. Levin developed enhanced 360 degree leadership evaluation models for use in mentoring and equipping leaders. He was formerly, Chief Operating Officer of a large technical and management consulting firm.He was with the Nuclear Regulatory Commission in the1 970's where he was involved in both operating reactors and new plant licensing.

In the 1980's, he was involved in providing services to management including independent technical reviews, organizational and programmatic consultation, business process enhancement, and other advisory and analytical services. In his early career, he held positions with an architect-engineering firm where he was involved in the analysis, design and construction of nuclear power plants.

Page 2 of 6

Mr. Timothy K. Snyder Independent Consultant SYNERGY Consulting Services Corporation Mr. Snyder has over 35 years of experience in providing management and engineering consulting services to the nuclear power and other industries. He is a graduate of the University of California - Berkeley. In January of 2006, he became a principal of SYNERGY Consulting Services Corporation.

During the preceding eight years, Mr. Snyder worked as an Associate of SYNERGY, participating in the performance of comprehensive cultural assessments and improvement projects at more than twenty nuclear power and he1 processing facilities. In his consulting practice, he has specialized in management consulting focused on producing significant organizational performance improvements. His areas of management expertise include operational performance, safety and workplace culture, effective management practices, work process analysis and design, information system management, and procedure effectiveness. Mr.

Snyder has also worked as an Associate of Little Harbor Consultants in the performance of safety culture assessment and improvement projects for a nuclear facility, a major oil pipeline, and a DOE nuclear waste management contractor. In his early career, he held positions with two major nuclear consulting firms.

Page 3 of 6

Mr. Dennis A. Winchester SYNERGY Associate Dennis A. Winchester provides expert consulting services to the commercial nuclear power industry, specializing in the areas of nuclear oversight, safety culture assessment and safety culture-related programs and processes.

Mr. Winchester has served as an industry peer in the safety culture assessments at the Davis-Besse Nuclear Power Station (2006) and at the Palo Verde Nuclear Generating Station (2007).

He was also responsible for managing safety culture assessment activities at the Salem and Hope Creek Generating Stations (2006).

From May 2005 through July 2007, Mr. Winchester served as PSEG Nuclears Vice President of Nuclear Assessment. In that capacity, he was responsible for providing leadership and oversight for nuclear assessment activities at the Salem and Hope Creek Generating Stations. In addition, he had executive responsibilities for implementation of the work environment improvement initiatives associated with the safety conscious work environment and employee concerns program improvements.

Mr. Winchester has 25 years of nuclear power plant experience. Prior to joining PSEG Nuclear, he served as the acting Nuclear Oversight Vice President and Director of Nuclear Oversight Programs and the Ombudsman for Exelon Corporation. Mr. Winchester has worked in a quality assessment management capacity for Exelon Corporation and Commonwealth Edison (merged to form Exelon) in successively increasing levels of responsibility since 1982. In these roles, he made important contributions for performance assessment and improvement of the nuclear facilities owned and operated by Exelon and Commonwealth Edison.

Mr. Winchester has been actively involved in Industry Quality leadership forums. He participated as a working committee member in the ANS 3.2 Operating Quality Standard and sat on the Main Committee of the ASME Quality Standard, NQA-1. He was Chairman of the Nuclear Quality Management Leadership forum.

Page 4 of 6

Aldo Capristo Business Support Manager Nuclear Management Company - Point Beach Nuclear Plant Mr. Capristo is presently the Business Support Manager, Point Beach Nuclear Plant, responsible for all business support functions including Security, Emergency Preparedness, Information Technology, Finance, Supply Chain, Administration, Procedures and Strategy. Other positions during his eight-year employment with Nuclear Management Company (NMC) include Director of Employee Concerns with responsibility for management of the Employee Concerns Program (ECP) at all NMC facilities, and Nuclear Oversight Manager. Prior to his employment with NMC, Mr. Capristo was the ECP Manager at two other nuclear facilities. Other nuclear power plant experience includes positions as Radiation Protection Supervisor and Manager, Radioactive Waste Shipping Manager and Radioactive Waste Disposal Coordinator.

Mr. Capristo has 17 years nuclear power plant experience, of which, more than seven years in the area of ECP. In addition, Mr. Capristo served as Engineering Laboratory Technician in the United States Nuclear Navy, with responsibilities that included daily operational water chemistry and radiological controls and nuclear power school fundamentals instructor, earning the award of Master Training Specialist.

Page 5 of 6

John W. Audas Industry Peer Reviewer TXU Power Comanche Peak John W. Audas has been employed by TXU since 1985 and is currently the SAFETEAM Manager (Employee Concerns Program Manager) at the Comanche Peak Station.

Mr. Audas has over 30 years of nuclear power industry experience and five years experience in the petro-chemical industry. Prior to joining TXU, he held engineering positions at two nuclear Architect Engineering firms and performed as Engineering supervisor at a nuclear facility.

Previous positions held while employed at TXU include Licensing Engineer and Project Manager.

Mr. Audas is one of the founding members of the Employee Concerns Program Forum and a member of the forums Board of Directors.

Mr. Audas is a graduate of Georgia Institute of Technology and has a Bachelor of Science and Masters Degrees in Physics.

Page 6 of 6

FENOC FirstEnergy Nuclear Operating Company 4 19-321-7636 Fax 339-321-3582 Docket Number 50-346 License Number N PF-3 Serial Number 1-1496 June 11, 2007 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region 111 2443 Warrenville Road, Suite 2 I O Lisle, IL 60532-4352

Subject:

Submittal of Independent Assessment Plan for the Davis-Besse Nuclear Power Station Corrective Action Program Implementation - Year 2007, Revision 1

Dear Mr. Caldwell:

The purpose of this letter is to submit Revision 1 to the assessment plan and related information for the independent external assessment of the Davis-Besse Nuclear Power Station (DBNPS) Corrective Action Program implementation. The original Corrective Action Program Implementation Assessment Plan was submitted on April 10, 2007, via DBNPS letter Serial Number 1-1490.

In accordance with the Nuclear Regulatory Commission (NRC) letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Contimatory Action Letter, and Issuance of Confirmatory Order, (letter Log 1-4524),

the DBNPS is submitting Revision 1 to the Corrective Action Program Implementation Assessment Plan, including the identification and qualifications of the assessors.

Revision 1 is being submitted because of the need to replace one of the assessors for the on-site portion of the assessment due to staffing changes and conflicting obligations, and to replace one of the peer assessors due to schedule conflicts.

This Assessment remains scheduled to commence on July 9,2007, with the onsite portion of the assessment lasting approximately two weeks. The above changes are identitied with revision bars in the right hand margin of Enclosure 1, Assessment Plan and Enclosure 2, Assessor Qualifications. Revision 1 of the Corrective Action Program Implementation Assessment Plan and the attached biographies supersedes the original submittal in its entirety.

Docket Number 50-346 License Number NPF-3 Serial Number 1-1496 Page 2 of 2 If you have any questions or require further information, please contact Mr. Raymond A.

Hruby, Jr., Manager - Regulatory Compliance, at (41 9) 32 1-8000.

Sincerely yours, JhU6 &d LJS Attachment Enclosures cc: USNRC Document Control Desk DB- 1 NRCmRR Project Manager DB- 1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1496 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by FENOCs Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please notify the Manager -

Regulatory Compliance (4 19-321-8000) at the DBNPS of any questions regarding this document or associated regulatory commitments.

COMMITMENTS DUE DATE None. Serial 1- 1496 contains no new commitments. NIA

Docket Number 50-346 License Number NPF-3 Serial Number 1-1496 Enclosure I Davis-Besse Nuclear Power Station Independent Corrective Action Program Implementation Assessment Plan - Year 2007, Revision 1 (8 pages to follow)

NUMBER:

COIA-CAP-2007 ASSESSMENT AREA:

Corrective Action Program Implementation PURPOSE:

The purpose is to provide the 2007 independent and comprehensive assessment of the Corrective Action Program implementation at the Davis-Besse Nuclear Power Station.

The assessment will be performed in accordance with the requirements of the March 8, 2004, Confirmatory Order Modifying License number NPF-3 and Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments. The assessment will be used to identify areas for improvement requiring corrective actions with action plans and areas in need of attention for other improvement opportunities. The assessment will also be used to assess the rigor, criticality, and overall quality of available Davis-Besse internal self-assessment activities in the implementation of the Corrective Action Program.

SCOPE:

The Independent Assessment Team will evaluate the following areas associated with the Corrective Action Program implementation since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program (August 26, 2006), as follows:

1. Identification, classification, and categorization of conditions adverse to quality

2. Evaluation and resolution of problems

3. Corrective action implementation & effectiveness

4. Trending program implementation & effectiveness

5. Effect of program backlogs

6. Effectiveness of internal assessment activities

7. Implementation of the Corrective Action Program by Engineering

8. Open corrective actions taken in response to the NRC Special Team Inspection -

Corrective Action Program Implementation - Report 05000346/2003010

9. Corrective actions taken in response to the Areas for Improvement (AFI) and Areas in Need of Attention (ANA) identified during the previous independent assessments of the Davis-Besse Corrective Action Program Implementation.

Page 1 of 8

Corrective Action Program Implementation Assessment Plan 2007, Revision 1 I

The Assessment Team will conduct the following activities:

1. Identification, Classification, and Categorization of Conditions Adverse to Quality The 2007 Independent Assessment Team will review activities to assess the effectiveness of the identification, classification, and categorization of Conditions Adverse to Quality for issues identified since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program (August 26, 2006), including:

a. Review and evaluate the identification, classification, and categorization of at least twenty-five (25) selected Condition Reports categorized after Management Review Board (MRB) review.

b. Review a sampling of SAP non-maintenance notifications initiated since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program (August 26, 2006) to determine if the conditions were properly categorized. Analyze these notifications for issues which should have been identified as Conditions Adverse to Quality but were not or were only partially identified.

c. Interview at least ten (1 0) individuals from various parts of the Davis-Besse Nuclear Power Stations management and staff. Ascertain the Davis-Besse Nuclear Power Station staffs commitment to the Corrective Action Program, the extent of their understanding of the Davis-Besse Nuclear Power Stations problem identification process, and their willingness to report problems.

d. Evaluate the adequacy of the Davis-Besse Nuclear Power Stations identification, classification, and categorization of a minimum of twenty (20) corrective actions for sharing operational experience feedback with the industry.

2. Evaluation and Resolution of Problems The Assessment Team will perform an analysis of at least five (5) selected issues or problems that have gone through the entire applicable Corrective Action Program process, to identify strengths and weaknesses in their evaluation and resolution. The Assessment Team will:

a. Analyze the Full Apparent Cause or Root Cause evaluation of at least five (5) selected Condition Reports.

b. Analyze the problems selected above, including cause identification and appropriateness of corrective actions. Determine the Davis-Besse Nuclear Power Stations effectiveness in implementing the Corrective Action Program.

c. Identify any strengths or weaknesses to responses found during the detailed analysis above.

Corrective Action Program Implementation Assessment Plan - 2007, Revision 1 I

3. Corrective Action Implementation & Effectiveness The Assessment Team will perform an analysis of Conditions Adverse to Quality corrective action implementation and effectiveness since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program (August 26,2006). The Assessment Team will:

a. Evaluate the timeliness of corrective actions for at least twenty (20) Condition Reports.

b. Review the number of repeat condition reports and corrective actions and evaluate the effectiveness of corrective actions.

c. Evaluate the adequacy of the Davis-Besse Nuclear Power Stations implementation of corrective actions for operational experience feedback from the industry.

d. Review the activities of the Corrective Action Review Board (CARB) and evaluate the effectiveness of the CARB.

e. Evaluate the Davis-Besse Nuclear Power Stations Corrective Action Program for broad implementation problems, if the above review indicates the potential for such problems.

4. Trending Program Implementation & Effectiveness The Assessment Team will assess the sites implementation of existing trending programs.

5. Effect of Program Backlogs The Assessment Team will perform an analysis of the effect of program backlogs on organizational and operational effectiveness. The Assessment Team will:

a. Review program backlogs and the trend of the backlogs.

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

6. Effectiveness of Internal Assessment Activities Self-Assessments The Assessment Team will evaluate the effectiveness of the Davis-Besse Nuclear Power Stations self-assessment activities associated with the implementation of the Corrective Action Program. The Assessment Team will:

a. Review the results of Davis-Besse Nuclear Power Station auditsheviews conducted since the 2006 Independent Assessment of the Corrective Action Program. Determine if the auditsheviews were comprehensive and whether effective actions were taken to correct problems or weaknesses identified.

b. Evaluate the effectiveness of self-assessment capability by reviewing findings and corrective actions associated with at least five (5) of the following:

i. Self-assessment reports Page 3 of 8

Corrective Action Program Implementation Assessment Plan - 2007, Revision 1 I

ii. AudiWreviews (including auditsheviews of both onsite and offsite safety committee activities) iii. Evaluations conducted on the implementation of the Corrective Action Program since the 2006 Independent Assessment

c. Determine if the Davis-Besse Nuclear Power Station is aggressive in correcting self-assessment findings on the implementation of the Corrective Action Program by determining whether the corrective actions are adequate, timely, properly prioritized, and that effectiveness reviews are ensuring the desired results.

d. Interview at least four (4) selected individuals involved with the oversight function, as well as the audited organization, to gain their insight on the effectiveness of their effort and the responsiveness of FENOC management and staff to issues raised.

Onsite and Offsite Safety Review Committee Activities The Assessment Team will evaluate the effectiveness of the safety review committees oversight of the implementation of the Corrective Action Program since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program (August 26,2006) by reviewing committee minutes, auditsheviews, or other actions initiated by the committees as they relate to risk significance or major corrective action successes or failures. The Assessment Team will review the following, as necessary:

a. Identify what issues are reviewed by the safety review committees and review at least five (5) actions initiated by the safety committees to identify, assess, and correct areas of weakness

b. Review auditsheviews of the Corrective Action Program conducted since the last Independent Assessment under the cognizance of the offsite safety review committee and determine if the auditheview findings were consistent with such external assessments as INPO, NRC, and consultants

c. Evaluate the Davis-Besse Nuclear Power Stations follow-up to ten (1 0) items, if available, on the Corrective Action Program identified by the safety review committees, including committee-initiated auditheview findings and any recurring problems.

7. Implementation of the Corrective Action Program by Engineering The Assessment Team will evaluate the effectiveness of the implementation of the Corrective Action Program by the Engineering Department. Portions of this evaluation may be included in assessment activities addressed in areas 2, 3,4, and 6 . Areas to be reviewed during the 2007 assessment will include the following, as appropriate:

a. Promptness in initiating Condition Reports for identified conditions adverse to quality

b. Condition Report ownership and appropriate initiator involvement

c. Quality of root and apparent causes produced by Engineering and associated management behavior and guidance

d. Prompt acceptance of corrective actions Page 4 of 8

Corrective Action Program implementation Assessment Plan - 2007, Revision 1

e. Corrective action quality and implementation timeliness

f. Effectiveness of corrective actions to prevent recurrence

g. Support of corrective actions assigned to others

h. Workload management and backlog management

8. Evaluate any Open Corrective Actions taken in Response to the NRC Special Team Inspection Corrective Action Program Implementation - Report Number 05000346/2003010 The Assessment Team will conduct an evaluation of the open corrective actions taken in response to the NRC Special Team Inspection - Corrective Action Program Implementation

- Report 05000346/2003010. The 2007 Independent Assessment Team will identify individual strengths, weaknesses, or slow responses found during an analysis of the open items.

9. Review of Corrective Actions from Previous Independent Assessment of the Davis-Besse Corrective Action Program The Independent Assessment Team will review existing open Corrective Actions and SAP items developed in response to Areas in Need of Attention and Areas for Improvement from the previous independent assessments. The 2007 Independent Assessment Team will identify individual strengths or weaknesses to responses found during an analysis of the open items.

INDEPENDENT ASSESSMENT TEAM (Biographies attached):

Jon Johnson, Advanced Technologies and Laboratories International (ATL), On-Site Lead Investigator Marquis P. Orr, ATL, Team Leader (Off-site)

Kenneth G. Murphy, ATL, Senior Reviewer Paul D. Swetland, ATL, Senior Reviewer David W. Barker, Cooper Nuclear Station, Independent Industry Peer Kim Kieler, South Texas Project, Independent Industry Peer Joseph A. Reynolds, Indian Point Energy Center, Independent Industry Peer Page 5 of 8

Corrective Action Program Implementation Assessment Plan 2007, Revision 1 I

SCHEDULE:

Date I Activity ~~~~~

I June 1,2007 Distribute selected documentation to the CAP Assessment Team members to begin offsite review June 4 to July 9,2007 Preparation Period - Offsite (in-office) review of Davis-Besse material in preparation for onsite assessment July 9,2007 CAP Assessment Team will assemble at plant site to begin site assessment activities July 9 to July 20,2007 CAP Assessment Team performs onsite assessment; Assessment Team provides Davis-Besse with preliminary findings during debrief meeting August 3,2007 Draft report from CAP Assessment Team delivered to Davis-Besse for review and comment; final debrief meeting (marks completion of assessment)

~~~~~

August 10,2007 Davis-Besse comments incorporated and final CAP Assessment report delivered to Davis-Besse management Final assessment report and Davis-Besse action plans (if required by findings) will be submitted to the NRC within forty-five (45) days of the completion of the assessment.

ASSESSMENT METHODS:

The Independent Assessment Team will use an approach similar to the NRC Inspection Procedure 40500, Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems, and NOBP-LP-200 1, FENOC Self-AssessmentBencharking, to evaluate the effectiveness of the implementation of the Corrective Action Program.

The assessment methodology may include any combination of the following:

0 Observing activities Interviewing personnel Reviewing documentation Evaluating or performing trend analysis Reviewing procedures, instructions, and programs Comparing actual performance levels with pre-established performance indicators The following general standards of acceptable corrective actions will apply to the assessment of Davis-Besse Corrective Action Program implementation:

The problem is identified in a timely manner commensurate with its significance and ease of discovery Identification of the problem is accurate and complete and includes consideration of the generic implications and possible previous occurrences Page 6 of 0

Corrective Action Program implementation Assessment Plan - 2007, Revision 1 I

0 The problem is properly prioritized for resolution commensurate with its safety significance 0 The root causes of the problem are identified and corrective actions are appropriately focused to address the causes and to prevent recurrence of the problem Corrective actions are completed in a timely manner The assessment team will review the referenced procedure/documents during the Preparation Period prior to site arrival.

The Assessment Team will identify, as applicable, Areas of Strength, Areas in Need of Attention, and Areas for Improvements as defined in the current revision of Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments. The Team will provide an overall concluding statement on the effectiveness of the Corrective Action Program implementation using the rating categories of DBBP-VP-0009.

REFERENCES:

NRC Inspection Procedure 40500, Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems NOP-LP-2001, Corrective Action Program NOBP-LP-200 1, FENOC Self-AssessmentlBenchmarking NOBP-LP-2007, Condition Report Process Effectiveness Review NOBP-LP-2008, FENOC Corrective Action Review Board Davis-Besse Business Practice DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments Condition Reports and CR Trend Reports, August 26,2006, through July 2007 Past NRC Inspection Reports that are applicable to the area assessed Past applicable Self-Assessments QA quarterly assessments for past four quarters Related Operating Experience since the 2006 Independent Assessment of the Davis-Besse Corrective Action Program CNRB meeting minutes from last four CNRB intervals Field Observation Reports Applicable Section or Area Performance Indicators Previous Independent Assessment Reports and Action Plans (subsequent to first annual assessments)

Page 7 of 8

Corrective Action Program Implementation Assessment Plan 2007, Revlsion 1 1

ASSESSMENT PLAN APPROVALS:

Prepared* / Date: 5;/13/tcD7

, ATL Team Leader Approved by: 1 Date: 5-/Jol07

,Executive Sponsor Page 8 of 8

Docket Number 50-346 License Number NPF-3 Serial Number 1- 1496 Davis-Besse Nuclear Power Station Independent Corrective Action Program Implementation Assessment - Year 2007, Revision 1 Assessors and Qualifications (7 pages to follow)

Jon R. Johnson Senior Executive Consultant ATL International, Inc.

2003-Present : Senior Executive Consultant-Nuclear Safety Member of Off-Site Safety Committee for major US nuclear utility providing advice and guidance on reactor safety and engineering management. Provide regulatory and technical advice to major reactor vendor on Design Certification. Provide management advice and conduct safety assessments for US DOE. Senior safety and security advisor to the NRCs Office of the Executive Director for Operations. Provided advice on risk- informed licensing approaches and inspection techniques for international regulators and utility managers. Chair of Executive Assessment Board for DOE M&O contractor. Member of Executive Team providing regulatory advice and licensing guidance for a geological spent fuel repository for the Department of Energy. Principal expert speaker at nuclear utility manager and regulatory agency workshops for the IAEA. Advise nuclear industry regarding advanced reactor engineering, design and safety policy.

1978-2003: Senior Executive, US Nuclear Regulatory ComrnissIon Deputy Director, Office of Nuclear Reactor Regulation - managed NRCs headquarters program office functions for all operating reactors and research reactors in the US including licensing, engineering/technical review, inspection and oversight programs (ROP), license renewal, maintenance rule implementation. Responsible for training; assessment of operations, maintenance, corrective action programs; enforcement; and emergency response. Supervised development of risk- informed regulations, and operator licensing, advanced reactor licensing, and generic Technical Specification development.

Provided advice on policy matters to the NRC Commissioners, the Congress, and the White House. Directly managed implementation of NRCs Reactor Oversight Process (ROP) including engineering1 technical review, inspection, assessment, enforcement, security, and emergency response functions for all NRCs operating reactors in tk northeast (Region I) and southeast (Region 11). As a senior nuclear safety and engineering consultant, provide advice to national and international nuclear utility and governmental managers regarding nuclear reactor licensing and inspection policy. Advise the nuclear industry regarding advanced reactor policy.

1970- 1978: Nuclear Trained Officer, United Stutes Navy Reactor Mechanical Assistant on nuclear-powered ship, in charge of dual-reactor operations and assessment of nuclear mechanical systems, chemistry and radiological control programs. As Director, Reactor Principles, supervised 15 instructors and 800 students in course of instruction for the application of nuclear physics to a nuclear power plant. Directly superviscd and operated reactors at sea and during a refueling overhaul.

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Marquis P. Orr Senior Program Manager ATL International, Inc.

2000 - Present: Advanced Technologies and Laboratories International, Inc. (ATL), Team member and project manager for performance assessments and site evaluations at U.S.

Department of Energy (DOE) and U.S. Department of Defense (DoD) facilities. Supported development of U.S. Nuclear Regulatory Commission (NRC) safety analysis reports (SAR) and environmental impact statemcnts (EIS) for license renewal and new construction applications.

Responsible for development ofdraft regulatory guides and standard review plans to assist NRC staff with review of license renewal applications. Assisted FirstEnergy with independent assessment of the corrective action programs at Beaver Valley Power Station and Davis-Besse Nuclear Power Plant.

1992 - 2000: Science Applications International Corporation (SAIC), Joined SAIC to assist DOE with program development for inspection, decontamination, decommissioning, and disposal of obsolete and formerly utilized nuclear weapons buildings and facilities. Assisted DOE Headquarters with the development of intra-departmental administrative procedurcs to standardized activities for construction project reporting between DOE headquarters, field offices, and laboratories. Revicwed technical scope, approach, and budget of Armenian nuclear power plant in Yerevan, Armenia for US-AID and the World Bank as part of loan rcqucst verification. Evaluated impact of existing and proposed Federal regulations on radioactive and hazardous waste disposal facility being built for U.S. DOE in Hanford, Washington. Managed cost-benefit evaluation of decontamination and decommissioning (D&D) options for U.S. Army disposal of shut down nuclear power plants. Developed cost and performance guidelines for Quality Assurance (QA) and Inservice Inspection (ISI) and chemical decontamination program and procedures at Lucent Technologies.

0 1983 - 1992: Duquesne Light Comnpany, Beaver Valley Power Station, Served as Site Maintenance Support Coordinator for dual unit commercial nuclear power plant. Responsible for Supervised maintenance enginccrs and technicians supporting the Site Maintenance Department at a 2-unit nuclear power plant. Served as Maintenance Dept. representing to on site safety review committee. Responsible for review and analysis of proposed plant activities to verify compliance with NRC license requirements and safety regulations. Lead investigator for accident and equipment performance failures. Investigated accidents and occurrences for safety and root cause of failure. Performed off-site assessments of maintenance and repair parts manufacturing facilities for capabilities and compliance with NRC and ANI-QA requirements.

1978 - 1983: Wheeling-Pittsburgh Steel Corporation, Served as Corporate Mechanical Engineer responsible for environmental compliance audits, installation of major plant upgrades, and the design and implementation of new environmental remediation programs for rolling mills, continuous casting facilities, and foundries. Member of engineering team charged with upgrading the company's 80" hot strip mill. Worked with plant performance improvement team as Pollution Control Engineer. Rcsponsible for the design, development, and installation of pollution abatement and performance enhancement projects at various steel manufacturing facilities and processing plants. In charge of the design and installation of various air. water, and soil pollution control projects at coke and steel processing plants.

1974 - 1978. Bla\r'-Knox Foiindty and Mill Machinery Corporation, Project Enginecr for modernization and expansion of large capacity iron and steel foundry. Responsible for design and installation of foundry mold manufacturing system and pneumatic sand transport system.

Supervised maintenance and repair crews in large capacity machine shop.

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Kenneth G . Murphy Senior Nuclear Safety Engineer ATL, International, Inc.

1999 - Present; Senior Nuclear Safety Engineer. Provides a broad range of nuclear and non-nuclear safety consulting services in the areas of safety analysis, accident investigation, safety management system improvements, process safety management, probabilistic risk assessment (PRA), and field assessments. Currently supporting Department of Energy (DOE) in its complex-wide efforts in improving its nuclear safety requirements and oversight.

1988 - 1999; United States (US) DOE, Director of the Safety Technology Division, and Chemical Safety Team Leader. Initiated the Departments Probabilistic Risk Assessment (PRA) overview program of production and test reactors. Founding Editor of DOEs Risk Management Quarterly. Upgraded the Departments safety analysis report (SAR) in order to reflect new thinking on improved analyses, use of PRA, risk management, and human factors. Supported Defense Programs in its effort to start the Savannah River production reactors and the Rocky Flats facilities. Initiated DOEs Chemical Safety Program to bring the safety of DOEs chemical activities on par with its nuclear operations. Helped establish strong ties with chemical industry safety experts and catalyzed interest in DOE to network with industry safety experts.

1984- 1988; US Nuclear Regulatory Commission (NRC) Region I, Special Test Programs Section Chi$ Prior to section chief position, was Technical Assistant to the Director of the Division of Reactor Projects, working with resident inspectors on Three Mile Island (TMI) action items, initiated special inspections, developed temporary instructions and assured their completion by the resident inspectors. Planned resident inspector counterpart meetings. As Technical Assistant to the Director of the Division of Reactor Safety, planned and led six major PRA-directed inspections at Light Water Reactors, which uncovered safety-significant weaknesses in management programs, plant operations, equipment maintenance, and system testing. Directed the activities of six to eight inspectors. Developed an inspection module to document the newly-developed inspection techniques that used PRA. In addition, supported the Regional Administrator and Division Directors by providing reliability and risk analysis used for decision-making. As section chief, managed a section that conducted specialized and augmented team inspections, eg., main coolant integrity, electric power, emergency heat removal, and loss of containment (Event V) inspections.

1972-1984; US NRC Office of ResearcWOffice of Nuclear Reactor Regulation, Various Nuclear Engineering positions. Used insights from PRAs to recommend changes in safety regulations, plant design, and procedures. Performed reliability analyses for the reactor protection systems of the four major reactor vendors in support of the Anticipated Transient Without Scram Rule.

Determined effectiveness of safety systems to minimize release of radioactivity. Formulated regulations on design basis accidents and control room habitability and assisted in their implementation.

1962-1972; US Atomic Energy Commission (AEC) and Hittman Associates, Various Nuclear Engineering positions. Developed a number of computer programs for radiological transport.

Conducted life and qualification tests of Snap 19 generators. Performed core and shielding calculations for the Military Compact Reactor. Performed duties as AECs field representative overseeing the construction of the High Temperature Lattice Test Reactor and the Plutonium Recycle Experimental Facility while at Hanford.

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Paul D. Swetland Senior Executive Consultant ATL International, Inc.

1998 - Present; Senior Executive Consultant. Conducted Component Design Basis Audit and NRC inspection preparation and follow-up at Kewaunee Power Station (January-February 2007). Independently assessed Davis Besse corrective action program implementation (August 2006). Performed comprehensive root cause analysis for the Davis-Besse corrective action program and implemented corrective action program restart improvement plan for the Davis-Besse NRC Inspection Manual Chapter (IMC) 0350 recovery effort (September 2002 - June 2003). Generated NRC operator license exams for Duke Power and Florida Power and Light Company plants. Assessed operator license candidates at St Lucie, McGuire and Catawba. Conducted audits of the fire protection program at Prairie Island.

1980 - 1997; US NRC, Branch Chiex coordinated NRC inspection findings, allegations, and performance assessments for the Limerick, Peach Bottom, and Susquehanna nuclear generating facilities. Conducted corrective action program effectiveness inspections at Limerick. As Senior Resident Inspector for Millstone, Haddam Neck, and Maine Yankee, planned, coordinated and conducted safety inspections to verify maintenance of public health and safety and compliance with NRC regulations and directed the site inspection staff.

Participated in integrated and readiness assessment team inspections at Haddam Neck, Indian Point and Millstone. As Projects Section Chief, managed the NRC inspection, performance assessment, enforcement, and events response programs for the Salem/Hope Creek, Susquehanna and Indian Point nuclear generating facilities. Supervised field office personnel, including resident inspectors and clerical personnel. Led integrated performance assessment (DET precursor) and augmented incident team inspections.

1979 - 1980; Maritime Program Administrator, Bath Iron Works. Administered a $1.5 million government research and development contract for the commercial shipbuilding industry.

1973 - 1979; US Navy, As Senior Instructor, Submarine Officers Basic School; coordinated the curriculum development and instruction of a 12-week course in all aspects of submarine design, safety and operations. Supervised six instructors and up to 120 students. As Sonar Instructor, Naval Submarine School; developed and taught submarine sonar technology courses for naval officers. As Weapons Department Head on SSN 680; managed all aspects of submarine weapons and sensor system operations and maintenance. Responsible for the training, development and administration of a staff of 25 degreed engineers, skilled technicians and laborers. Designated best Weapons Department in the Squadron. As Engineering Division Officer on SSBN 640; directed the operation, maintenance and overhaul of various naval nuclear propulsion and support systems. Supervised 20 nuclear-qualified technicians, and managed the ships radiological protection and chemistry programs.

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David W. Barker Root Cause Supervisor Cooper Nuclear Station 0 2005 - present; Cooper Nticdear Station; Root Cause Supervisor. Oversight and maintenance of the site root cause investigation process. Supervise core team of dedicated root cause investigators which lead all significant site investigations.

Define investigator qualification and proficiency standards. Establish and implement effectiveness standards/process and monitor results for inclusion in proficiency training.

2002-2005; Harris Nzrclear Planr; Corrective Action Program Owner. Oversight and maintenance of Corrective Action Program and Root Cause Investigation processes, monitoring program status against performance indicators, developing/implementing initiatives for improvcmcnts, and chair site daily meetings for review and classification of new Condition Reports. Chair for site Root Cause Review Team which performed peer and management reviews of root cause investigations. Site lead for critical root cause investigations.

0 1995-2002;Harris Miclear Plant; Engineering CAP Lead Section Evaluator.

Engineering representation in classification and acceptance of Condition Reports, site lead for root cause investigation teams, performance of trend analysis of Engineering Condition Reports to detect and document adverse trends. Self-assessment and benchmarking coordination for Engineering section. Qualified system and design engineer.

0 1991 - 1995; Harris Nircfecir Plant; Regulatory Affairs CAP Specialist. Oversight and maintenance of site CAP process, root cause investigation process, and action item tracking process. Led root cause investigation teams. Performed site-wide Condition Report trend analysis.

0 1983-199I ; Harris Nuclear P lant; QA/QC Senior Specialist. Led performance-based assessments in the areas of operations and maintenance.

1975-1983; US Navy Szihmarine Sewice; Completed all training and qualifications as a nuclear plant operator at the S5G prototype. Served aboard the USS Whale (SSN 638) qualifying on all (S5W power plant) watch stations up to, and including, supervisory positions in the propulsion plant engine room.

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Kim Kieler Quality Audits Supervisor South Texas Project 0 2006 - present; South Texas Project; Quality Audits Supervisor, Responsible for the scheduling and performance of all station audits. Supervise lead auditors that lead all station audits. Maintain oversight of Master Scope Lists for continuous in field monitoring in support of audit objectives. Supervisory responsibilities include condition report screening and significance determination including initial cause and event code assignment.

0 1989 - 2006: South Texas Project; (Multiple roles) o Qualified Lead Auditor in 2000, Responsible for oversight and leading numerous plant audits, team member and led NUPIC audits and surveys.

All audits include departmental corrective action program evaluation.

o CAP Supervisor 1995 Supervisory responsibilities include condition report screening and significance determination including initial cause and event code assignment.

o Quality Inspector Level I1 1989, multi-discipline (Mechanical; Electrical; I&C; Civil; Visual Weld VT-1, 2, 3; Receipt Inspection and Material Testing) Perform in-field Quality Inspection activities during refueling outages.

0 1982 - 1989: South Texas Project; Ebasco Constructors Inc., Quality Inspector Level I1 Civil discipline. Responsible for inspection of various civil activities during the construction phase of the South Texas Nuclear Project.

0 1978 - 1982: South Texas Project; Brown & Root Inc., Quality Inspector Level I1 Civil discipline. Responsible for inspection of various civil activities during the construction phase of the South Texas Nuclear Project.

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Joseph A. Reynolds Supervisor Corrective Action and Assessments Entergy Indian Point Energy Center 2002-present. Entergy Nuclear Northeast - Indian Point Energy Center; Corrective Action and Assessment Department Supervisor - Provide overall proactive management of the site corrective action process function including support for cause investigations, training of site personnel and assisting same in preparing stand alone quality condition report responses.

Accountable for corrective action department budget monitoring, short-term and long term staffing, development, compensation, and related human resource needs for 6 assigned employees. Coordinated the integration of the CA&A Department processes and procedures at IPEC (organization changed from a two single unit sites, to one two unit site), and fostered continued standardization of procedures and processes throughout Entergy Nuclear (North and South) Fleet. Co-developed Fleet living Corrective Action Program Performance Index, providing daily status, and site to site performance comparisons using technology, based on fleet performance standard trending.

2000-2002: Entergy Nuclear Northeast - Indian Point Energy Center; Site Operating Experience Program Specialist - Accountable for the review, distribution, use and resolution of Industry Operating Experience to foster site process/program/systems performance improvement. Developed and performed training to site personnel in the use, value and access to industry operating experience databases. This included all work planning, supervisors and personnel who evaluate plant issues from all department (support and line) organizations. Actively participated in industry Operating Experience Conference meeting at Callaway Power Nuclear Power Plant and as a peer participant in a Learning Organization assessment at Waterford 3 Nuclear Power Plant.

1998-2000: Consolidated Edison - Indian Point Station Unit 2; Nuclear Mechanic Technician - Responsible for performing corrective and preventive maintenance repairs to plant electrical and mechanical components. Qualified in support activities (work permit holder, fire watch, confined space monitor, asbestos worker, radiological control worker, etc) as needed to support repair activities.

1976-1998: United States Navy - Nuclear Mechanical Operator; Retired Nuclear Chief Machinist Mate - Managed all aspects of the operation and maintenance of all mechanical systems associated with Naval Nuclear Power Plants. Directly responsible for the development of 15 staff personnel including training, qualification, continued professional development and all human resource associated activities. During this period, assigned to key positions of increasing authority including instructor, recruiting, and public affairs positions associated with the operation and promotion of Naval Nuclear Power plants.

Qualified as Shift Manager on three different Naval Nuclear Power plants.

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TlliFnONl FIRST ENERGY CO 419-321-7581 OAVISSESSE NUCLEAR POWER PLANT 6601 N S T R T 2 I ..

Mr James Caldwell 2 Regional Administrator U S NRC, Region 111 2443 Warrenvllle Rd , Suite 210 U Lisle, IL 60532-4352 1 ,,,55, ,,,,,Ob'lU IZ bbb 5% 22 1001 ObUU

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