ML023400156

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2pm Transcript of Public Meeting Between NRC and Firstenergy Nuclear Operating Co. Davis-Besse Power Plant
ML023400156
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 11/13/2002
From: Collins S, Farber M, Grobe J, Hopkins J, Christine Lipa, Anthony Mendiola, Douglas Simpkins, Thomas C
NRC/NRR/DLPM/LPD2
To: Fast J, Grabnar J, Loehlein S, Myers L, Ross M, Schrauder R, Mackenzie Stevens
FirstEnergy Nuclear Operating Co
References
Download: ML023400156 (152)


Text

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2 PUBLIC MEETING BETWEEN U.S. NUCLEAR REGULATORY COMMISSION O350 PANEL 3 AND FIRST ENERGY NUCLEAR OPERATING COMPANY OAK HARBOR, OHIO 4 ---

Meeting held on Wednesday, November 13, 2002, at 5 2:00 p.m. at the Oak Harbor High School, Oak Harbor, Ohio, taken by me Marie B. Fresch, Registered Merit Reporter, and 6 Notary Public in and for the State of Ohio.

7 PANEL MEMBERS PRESENT:

8 U. S. NUCLEAR REGULATORY COMMISSION 9

Mr. John "Jack" Grobe, 10 Chairman, MC 0350 Panel Anthony Mendiola, 11 Section Chief PDIII-2, NRR Christine Lipa, Projects Branch Chief 12 Douglas Simpkins, NRC Resident Inspector Christopher Scott Thomas, 13 Senior Resident Inspector U.S. NRC Office - Davis-Besse 14 Jon Hopkins, Project Manager Davis-Besse Sam Collins, Director of the Office 15 Of Nuclear Reactor Regulation Marty Farber, System Health Inspector 16 FIRST ENERGY NUCLEAR OPERATING COMPANY 17 Lew Myers, FENOC Chief Operating Officer 18 Robert W. Schrauder, Director - Support Services 19 J. Randel Fast, Plant Manager James J. Powers, III 20 Director - Nuclear Engineering Steven Loehlein, 21 Manager - Quality Assessment Michael J. Stevens, 22 Director - Nuclear Maintenance Mike J. Ross 23 Manager - Operations Effectiveness John J. Grabnar, 24 Manager - Design Basis Engineering 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

2 1 MS. LIPA: Good afternoon.

2 I would like to extend a welcome to the public and to 3 FirstEnergy for coming to this public meeting.

4 Im Christine Lipa, and Im a member of the NRCs 5 Oversight Panel and Im also Branch Chief in NRCs Region 6 III Office; and I have overall responsibility for NRCs 7 Inspection Program at Davis-Besse.

8 Well go through the rest of the introductions in a 9 few minutes. I want you to refer to our agenda that we 10 have over on our left. The purpose of todays meeting is 11 to discuss recent NRC oversight activities and 12 FirstEnergys progress on their Return to Service Plan.

13 This meeting is open to the public, and there will 14 be opportunities before the end of the meeting for the 15 public to ask questions of the NRC. This is considered a 16 Category One meeting in accordance with NRCs policy on 17 conducting our public meetings. And like I said, before 18 the meeting is adjourned, we will make opportunities for 19 questions.

20 Were also having this meeting transcribed to 21 maintain a record of the meeting, and the transcription 22 will be available on our web page. Its usually about 3 to 23 4 weeks after the public meeting.

24 In the foyer today, you probably received an agenda 25 and some handouts. And, you will also see one of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

3 1 handouts is the November edition of our monthly 2 newsletter. Weve been doing that for three times in a row 3 now. Also, there are meeting feedback forms that you can 4 use to provide feedback to us on the format and the content 5 of the meeting.

6 I would like to start off with introductions on the 7 NRC panel here today. On the far left, we have Doug 8 Simpkins, who is the Resident Inspector of the Davis-Besse 9 Plant.

10 And, next to him we have Jon Hopkins. He is the 11 Project Manager in Headquarters Office in NRR for Licensing 12 Activities.

13 Next to Jon is Tony Mendiola. Hes Supervisor at 14 NRR for Licensing Activities of Davis-Besse.

15 Next to Tony is Sam Collins. Sam is the Director of 16 the Office of Nuclear Reactor Regulation at Headquarters.

17 On my left is Jack Grobe, and hes the Senior 18 Manager in the Region III Office, and hes also the 19 Chairman of the Oversight Panel.

20 To my right is Scott Thomas. And Scott is the 21 Senior Resident Inspector at the Davis-Besse facility.

22 And, next to Scott is Marty Farber. And Marty 23 Farber was the lead for the System Health Inspection, one 24 of the inspections that we recently completed at the 25 facility.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

4 1 Also, from the NRC in the audience we have Viktoria 2 Mitlyng. Shes our Public Affairs Officer. There is 3 Viktoria.

4 And, we have Jay Collins. He is General Engineer on 5 rotation at the Davis-Besse facility and hes offering the 6 slides for us today.

7 Weve also got Nancy Keller, who is out in the foyer 8 greeting everyone with the handouts, and shes the Office 9 Assistant for the Davis-Besse Inspector Office.

10 And also Rolland Lickus. Who is our state liaison 11 from Region III.

12 And the transcriber is Marie Fresch from Norwalk, 13 Ohio.

14 Okay. Before I turn it over to the FirstEnergy 15 folks, I wanted to see if there are any representatives or 16 public officials in the room. I know I saw Jere Witt. Do 17 you want to stand up and introduce yourselves.

18 MR. WITT: Jere Witt, County 19 Administrator.

20 MS. LIPA: Jere.

21 MR. ARNDT: Steve Arndt, 22 County Commissioner.

23 MR. KOEBEL: Carl Koebel, 24 County Commissioner.

25 MS. LIPA: Okay. Thanks.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

5 1 And, if you would like to introduce your staff, 2 Lew.

3 MR. MYERS: Yes, thank you.

4 We have some people in the audience. Bob Saunders, 5 the President of FENOC. Also, Gary Leidich, our Executive 6 VP is here. Bill Pearce is also in the audience, Vice 7 President of Quality.

8 There is, our first slide, there has been some 9 change. Remember when we first started on the public 10 meetings, we talked about the senior management changes 11 that were made at Davis-Besse, and also at FENOC. This 12 first slide up here, I want to talk a little bit today.

13 We have a new position with Fred Glese. Hes not 14 with us today I dont think, but Fred is the Manager of 15 Human Resources. And hes very much involved with, in our 16 Leadership in Action Programs, the Management Programs that 17 we use to develop our supervisors management skills across 18 our site. So, that position has been added.

19 Additionally -- next slide. And, Fred also reports 20 to Debbie Sergi, our new Manager in FirstEnergy that I 21 didnt show, thats called Talent Resource Manager. And 22 thats a new position at FirstEnergy. We think its very 23 important.

24 Also some other people that I show on the next slide 25 is, we have, I talked about Fred Glese.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

6 1 Steve Loehlein is with us today. Steve is at the 2 end of the table, will be presenting. You know Steve 3 Loehlein, you know already from the Root Cause 4 Investigation, and Technical Investigation. He did such a 5 good job, we decided to make him Quality Manager. So, hes 6 now part of our team.

7 And Randy, who is in the office audience. We brought Randy 8 in to focus on Safety Conscious Work Environment. We 9 talked some about Safety Conscious Work Environment at our 10 other meetings. We know thats very important, so we have 11 Randy to really focus in on the Safety Focus Work 12 Environment on our site.

13 Dave Gudger is here. And Dave is over from our 14 Perry Plant. Has a Bachelor in Science Degree. Six years 15 experience. I think 14 years at Carolina Power and Line Light.

16 Hes also certified. Hes running our Corrective Action 17 Program. And, you know, that was one of the programs that, 18 that we had real concern about, and the AIT letter.

19 And then Greg Dunn is with us today also. Greg 20 holds a Bachelor of Science Degree. Hes from our Perry 21 Plant. Hes also an SRO for them. He has 22 years of 22 experience in Operation and Outage Management and were 23 really happy to have Greg with us.

24 And Jean Riegle Rinkle is next to him. Jean is our field fuel 25 person, does all our nuclear fields fuels.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

7 1 One of the people not with us, gentleman named Pete 2 Roberts. We brought him in to be, hes on the night shift, 3 thats the reason hes not here. The Manager of 4 Maintenance. And, thats a change also. So, Pete comes to 5 us. He has a Bachelor of Science Degree in Nuclear 6 Engineering. He was a System Engineering Manager at 7 another station. Has 18 years of experience in SRO; 8 certified from our Perry Plant. So, he left our company, 9 went to another company and we brought him back. So, were 10 happy to have him back at this time.

11 So, thats some recent change we have made in the 12 management level. I wanted to fill you in on some of those 13 areas before we got started today.

14 To my left, at the end of the table is John 15 Grabnar. John came to us by Perry Plant. He was an SRO, 16 went through the SRO training, came over in charge of 17 Design Engineering. Glad to have him here also. Hell be 18 talking about -- as you know, we had some issues with the 19 reviews of, System Reviews; and we want to talk to you 20 about some of the issues we found there. Hell be doing 21 that today.

22 Jim Powers is next to him. You know Jim. Jim is 23 going to talk about System Reviews.

24 Ill discuss some of the Management Reviews, how 25 thats going. Weve talked about that before.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

8 1 Randy doesnt really have a part today, so were not 2 sure what hes doing up here. No, we wanted him up here.

3 And Mike Ross is with us, supporting Randy. We 4 brought Mike Ross in, because hes an operational expert.

5 And thats what we consider him. Hes really focusing on 6 the operational ownership of our plant. Well let him give 7 you the status of that.

8 Mike Stevens is last on the schedule.

9 Steve Loehlein, the last thing we wanted to talk 10 about Value-Added from our Quality Group; and hes in that 11 position. I think theyve taken some really good steps.

12 Hes going to brief you on that.

13 And finally, Bob Schrauder, who will talk to you 14 about the reactor vessel head, so well hear more from 15 him.

16 Let me get started with the desired outcomes.

17 MS. LIPA: Lew, I was going 18 to go through the rest of the agenda before turning it over 19 to you.

20 MR. MYERS: Okay.

21 MS. LIPA: If thats all 22 right.

23 Just one question on that slide, on the dark 24 blue "New to Position". Is that since a certain date? The 25 next slide, up one.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

9 1 MR. MYERS: You know, some of 2 those, the last time, and I just sort of described the new 3 ones since then.

4 MS. LIPA: Okay.

5 MR. MYERS: So, the FENOC 6 Organization continues to change somewhat. And, the focus 7 on the issues that we had at the Davis-Besse Plant to 8 strengthen us there, and FENOC also at the management 9 level, bringing people in.

10 When we were here the last time, I know you talked 11 about the changes we made in the senior managers. Im just 12 updating on the changes we made in management level, some 13 of the actions weve had. Just a continuing process.

14 MS. LIPA: Okay, thank you.

15 The next thing I would like to cover on the next 16 slide is just a summary of what we talked about at last 17 months public meeting on October 16th.

18 During this meeting, the Licensee FirstEnergy 19 presented and we discussed a variety of topics. I want to 20 go through some of the highlights.

21 We talked about the, FirstEnergy gave a discussion 22 of the restart progress, including some major milestones 23 and some projects that have been completed. Their 24 integrated schedule for completion of activities and 25 performance indicators to measure performance in various MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

10 1 areas.

2 The next item was the Reactor Vessel Head 3 Resolution. And they updated us on the containment vessel 4 and shield building restored and the vessel head was in 5 place.

6 On the Containment Health Assurance. FirstEnergy 7 provided updates on work going on in containment. A lot of 8 work going on in containment, including the containment air 9 cooler refurbishment and redesign and a big project on 10 emergency sump.

11 On System Health Assurance, last time they discussed 12 the results of their ongoing reviews of various systems, 13 and that they had identified numerous discrepancies that 14 would be screened through the process and needed to be 15 evaluated and most have been corrected before restart.

16 The next building block that they updated us on was 17 the Program Compliance Reviews, and they gave us brief 18 updates on the progress in this area.

19 And then probably the biggest part of last months 20 meeting was the Management and Human Performance 21 Improvement Plan, and FirstEnergy discussed that there are 22 several specific reviews and investigations and root causes 23 that have been completed. And one of those is outstanding, 24 not yet completed. And that the results of all those 25 various activities still need to be integrated to show the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

11 1 complete picture, and improvement inititives are taking 2 place in parallel with this work.

3 They also updated us on their plans to address 4 Safety Conscious Work Environment concerns.

5 The next slide that I have that I want to update 6 everybody on was some recent NRC, well, Restart Checklist, 7 which has been revised on October 30th. And there are 8 three pages of the Restart Checklist. This is also in your 9 handout.

10 And then the other thing I wanted to spend a little 11 more time on today was the results of some recent NRC 12 inspections as they relate to specific checklist items.

13 So, you may have to flip back and forth a little to follow 14 along, but lets go first to the slide that says, "Results 15 Of Recently Completed NRC Inspections" and well start 16 there.

17 Now, the results of these inspections are also 18 summarized in the November monthly newsletter. So, that 19 has more details than what I have in your packet today.

20 The first item that I want to cover is Reactor 21 Pressure Vessel Head Replacement Activity. And that covers 22 checklist item 2.a. And this inspection exited on October 23 24, which is when the NRC completes their inspection and 24 has a formal exit meeting with the FirstEnergy officials.

25 And that report will be 2002-07 and we estimate that that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

12 1 will be out about 30 days from the exit.

2 And findings from that inspection were that the 3 replacement head met the applicable codes and it was an 4 acceptable replacement. And the NRC also reviewed the 5 Technical Root Cause that FirstEnergy submitted and 6 concluded that the Licensees analysis was plausible.

7 There is an item thats still remaining before that 8 checklist item can be closed, and that is the post 9 replacement pressure test of the pressure vessel. And this 10 is an ASME Code related test that would be required just 11 before restart. So, thats established as checklist item 12 2.a.

13 The next item is Checklist item 2.b, and this is 14 Containment Vessel Restoration, and this is really the work 15 that they did to open up the concrete part of the 16 containment and the metal part of containment to get the 17 new head in and the old head out.

18 This inspection exited on October 24th, and that 19 also will be in a Report 2002-07, which will be about 30 20 days from that exit date, and these reports will be 21 available on our web page.

22 And this inspection reviewed the concrete repair and 23 the welding of the containment vessel, and reviewed the 24 welding records and radiographs of the welds. And the 25 inspectors found that the activities were well controlled MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

13 1 and implemented.

2 One item thats remaining on that checklist item is 3 the IORT ILRT of the containment. This is a pressure test to 4 ensure the vessel meets the requirements.

5 The next item is checklist item 2.c. This is 6 Structures, Systems and Components Inside Containment. And 7 this exit was held on October 24th. That inspection report 8 will be 2002-12. This is actually part two of a 9 Containment Extent of Condition Inspection. We provided a 10 summary of part one a couple months ago.

11 During this inspection that just exited on October 12 24th, the inspectors found that plant personnel were 13 properly trained and qualified and used quality standards 14 in identifying components that could be affected by boric 15 acid. The main purpose of this activity was to verify the 16 adequacy of the Licensees activities to walkdown all the 17 systems and components in containment to see if there were 18 any that could be affected by boric acid.

19 The Licensee identified several items and entered 20 those items into the Corrective Action Program or Work 21 Control Process to resolve them. There are several items 22 that remain before this checklist item can be closed; those 23 include, there is an issue on the lower vessel nozzles. We 24 discussed that at length at the last public meeting. That 25 will be an unresolved item. Another item is the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

14 1 containment air coolers. There is an unresolved item on 2 the power cables for those coolers. And also there is an 3 unresolved item on conduit conductivity.

4 Then there are several other open items that 5 FirstEnergy is tracking on their Corrective Action Program; 6 and those include the codings coatings in containment, the sump 7 modification, and there is some environmental qualification 8 questions on some junction boxes. So, those are the open 9 issues that remain before that checklist item can be 10 closed.

11 The next item, which is checklist item 2.d, which is 12 Systems Outside Containment, Ill let Marty Farber, who has 13 the lead for that inspection, give you some results.

14 MR. FARBER: Good afternoon.

15 As Christine said, my name is Marty Farber. Im a Senior 16 Reactor Inspector in the Division of Reactor Safety in 17 Region III; and Im here to discuss the NRCs inspection of 18 the System Health Assurance Building Block.

19 System Health Assurance is one of the seven Building 20 Blocks that was developed by FirstEnergy as part of their 21 Return to Service Plan. This was intended to ensure that 22 the systems in the plant are in a condition that can 23 support safe and reliable operation.

24 The program was comprised of two fundamental 25 approaches. The first part, there were five very important MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

15 1 systems that were examined in detail, including looking at 2 their design basis to identify any latent issues and to 3 provide reasonable assurance that these systems could in 4 fact perform their safety and accident mitigation 5 functions.

6 The second portion of it was called System Health 7 Readiness Reviews, and there were 31 other important 8 systems that were examined, but in this case, they did not 9 go into that design basis or calculation portion of the 10 inspection.

11 The question would be, why did the NRC choose to 12 inspect System Health to the depth that we did? First and 13 foremost, it was important for us to know that if the 14 behaviors that caused the degradation of the reactor vessel 15 head, whether these may have led to degradation of other 16 reactor plant systems.

17 Second, we can tell something about how well 18 Management and Human Performance corrective actions are 19 taking hold by how well the Licensee FirstEnergy executes 20 the program. To this end, we had six fundamental 21 inspection areas that we were looking at.

22 First, review and evaluate the Licensees Building 23 Block, Program Plan, and applicable parts of FirstEnergys 24 Return to Service Plan and some other documents that I have 25 up there. In this case, the Building Block is the System MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

16 1 Health Assurance Program.

2 We wanted to take a look at a risk informed sample 3 of their implementation efforts for the program. What this 4 would include, well be examining all five of those 5 detailed reviews and a selection from the 31 less detailed 6 reviews.

7 We had an area to assess the Licensees independent 8 oversight for the program. What this entailed was 9 examining the monitoring that was done by Davis-Besse 10 Quality Assurance Organization and to examine the 11 independent system reviews that were performed by 12 FirstEnergys Corporate Oversight Department.

13 We wanted to evaluate the adequacy of FirstEnergys 14 performance indicators, for this particular System Health 15 area. We wanted to review the things that they learned 16 from implementation in these performance indicators, and 17 review the actions taken in response to the data.

18 FirstEnergy elected to monitor data, such as review 19 completion and the rate of closing issuing condition 20 reports. What we did is we evaluated that information. We 21 watched how FirstEnergy interpreted it and what actions 22 they took as a result.

23 We wanted to perform an independent inspection to 24 verify FirstEnergys results of one of their Latent Issues 25 Reviews, thats the detailed reviews, to examine three MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

17 1 significant systems; service water, high pressure 2 injection, and high voltage electrical distribution, the 3 4160 volt system.

4 We also wanted to classify, see how the Licensee 5 classified, and see if we agreed with sampling of issues 6 that came out of their reviews from the discovery portion 7 of the System Health Assurance Plan.

8 The Licensee has a classification scheme. We have 9 examined that. And what we want to do is assure that they 10 properly classify the issues that they find and how they 11 resolve them.

12 To accomplish all of this, we staffed the NRC team 13 with nine people that had a wealth of design and 14 operational experience. We drew from within Region III.

15 We got inspectors from Region IV, which is based out of 16 Arlington, Texas, and we had two experienced design 17 consultants who were part of this effort.

18 Where we stand right now. We began this inspection 19 on September the 3rd and completed the actual inspections 20 on November the 8th. We held a formal exit this morning 21 with FirstEnergy. Four of the six inspection areas that I 22 talked to you of are done. The remaining two areas will be 23 inspected after the System Health Review Reports are 24 completed and reviewed, and then well come back another 25 time to examine corrective actions that they take for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

18 1 issues that they discovered.

2 The results of our inspection to-date are that we 3 determined that FirstEnergys process for doing these 4 System Health Assurance Reviews is acceptable. FirstEnergy 5 identified that there were problems in calculation and 6 design basis information.

7 We did closely monitor their implementation. I want 8 to make sure you understand there is a differentiation. We 9 examined the process and concluded it was adequate. Then 10 we also examined how well they implemented. We determined 11 that they did an adequate job of implementation.

12 With regard to their oversight activities, we 13 reviewed them and we concluded that those were also done 14 acceptably.

15 The corporate self-assessment was thorough and 16 identified some deficiencies. Our own team identified a 17 large number of issues in the area of design basis, 18 testing, and corrective actions.

19 At the meeting this morning, we informed FirstEnergy 20 that there were multiple examples of failure to ensure that 21 the plans design bases were accurately reflected in 22 drawings, specifications and procedures.

23 There were several examples of failure to properly 24 test systems. And there were several examples of failure 25 to take corrective actions for identified deficiencies.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

19 1 There was also one technical specification violation 2 for failure to test the high pressure injection system 3 after the modification that was made.

4 Having gone through all this, what remains in front 5 of us looking forward on System Health Assurance; 6 FirstEnergy is evaluating their review results and the 7 results of the NRC inspections for possible expansion of 8 the System Health Assurance Program, especially in the area 9 of design basis and calculations.

10 The NRC will return to further examine System 11 Health, at the very least when all of the detailed review 12 reports are approved. We will also return at a later date 13 to examine corrective actions when enough of those actions 14 have been completed that we can select the most significant 15 ones for inspection.

16 Thats all. Thank you.

17 MS. LIPA: Okay, great.

18 Thanks, Marty.

19 Then, the last inspection I would like to update is 20 the recent Resident Inspection results. And this is from, 21 mostly from Scott Thomas and Doug Simpkins; and this is the 22 daily inspection of activities on the site, such as 23 testing, engineering reviews and temporary plant 24 modifications.

25 The recent exit, and these occur approximately every MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

20 1 6 or 7 weeks, was on October 4th. And that inspection 2 report is 2002-10; and that was issued on September 30 --

3 November 30, and that is available on our web page.

4 The results of that was one non-cited violation of 5 inadequate procedure for building scaffolding and the 6 scaffolding blocked safety related ventilation for the 7 emergency diesel generator.

8 And, also observations in that report of minor 9 significance, but they were still observations of ongoing 10 weaknesses in engineering, operations and maintenance that 11 FirstEnergy is correcting. So, that inspection report was 12 issued October 30, excuse me, and it is available on our 13 website.

14 The next slide, what I would like to cover is some 15 continuing NRC inspections. Most of these have already 16 started. Im just giving an update. There is a summary of 17 these on the front page of our November newsletter.

18 The first one is Organizational Effectiveness and 19 Human Performance Inspection. And, that inspection is 20 evaluating FirstEnergys Root Cause Analysis associated 21 with management organizational effectiveness and human 22 performance factors that led to the degradation of the 23 vessel head. And that is an ongoing inspection and hasnt 24 exited yet.

25 The second activity is the Program Effectiveness MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

21 1 Inspection, and that inspection is reviewing the plants 2 progress in creating more effective programs for certain 3 safety significant programs, such as corrective actions, 4 boric acid, corrosion control, modification control and 5 others.

6 And then the final continuing NRC inspection are the 7 two resident inspectors that continue daily inspections, 8 and that is always underway.

9 There are also some upcoming activities that I 10 wanted to brief you on. On November 20, the Lessons 11 Learned Task Force will be holding a public meeting here at 12 7 p.m., on November 20, to present their findings and to 13 receive comments from the public.

14 Also, right now a tentative date, November 26, were 15 looking to set up two public meetings at headquarters, and 16 were planning to have phonelines available for people who 17 wanted to call in and participate. And those two meetings; 18 the first one will be a meeting in the morning to discuss 19 the extensive modification to the containment sump that 20 FirstEnergy has been designing, and then in the afternoon, 21 the second meeting in the afternoon will be to discuss the 22 lower nozzles. And, we discussed this issue last time.

23 There is a lot of things that the Licensee has been looking 24 at, plans for testing, and theyve been investigating and 25 coming up with some options. So, that afternoon meeting MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

22 1 would be an opportunity to share those with us and with the 2 public.

3 So, thats all I have for now. I would like to turn 4 it over to FirstEnergy for your presentation.

5 MR. MYERS: Thank you.

6 We have several Desired Outcomes today. The first 7 one is to demonstrate, as we discussed last time, the 8 value-added by our Quality Assessment Organization.

9 I told you what Steve Loehlein is in that position.

10 Steve came to us from our Beaver Valley Plant. Improved 11 performer there. Has experience in operations, 12 engineering, is SRO certified. Hell talk about our 13 quality efforts today. We think were very proactive with 14 that.

15 Then, we want to demonstrate the progress of some of 16 our key Building Blocks, specifically, we want to talk 17 about the head, reactor head, and thats ready to go.

18 Some of the System Reviews. We sort of talked about 19 that. As we did the System Reviews, we found we always 20 said wed do the five line latent issues reviews and then come 21 back and do an assessment with those totals. We need to 22 change the scope that we would; and, we have decided we 23 need to look at some other things.

24 And then were going to brief you on the status of 25 some of our management actions. As I told you awhile ago, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

23 1 we changed the senior team quite a bit when we first came 2 here. Were really working hard now. We have a very 3 strong technical team, who many of them are down below, we 4 shared with you awhile ago and were taking a lot of other 5 management actions.

6 Finally, we want to talk to you about our plans on 7 the lower vessel penetration. We talked about that in the 8 last meeting. Since that time, weve met with our vendors 9 a couple times. Had a very large meeting about a week 10 ago. Looked at all the alternatives and have came up with, 11 decided on a game plan going forward that we will share 12 publicly here and with the NRC on the 23rd of this month, I 13 believe. So, we have a game plan going forward there not 14 only of inspection, but repair if we need to.

15 Finally, were going to talk to you about our, we 16 told you awhile ago, sort of, as we did the System Reviews, 17 we came to, the Davis-Besse Plant is a very old plant.

18 Going back and looking at accounts and stuff like that is 19 difficult. So, were still looking for some accounts, we 20 find. We think we have some issues in calculation areas, 21 and were developing a game plan to go forward with that 22 now, basically a new approach. John Grabnar will share 23 that with you today.

24 Finally, wed like to talk about our schedule review 25 or scheduled milestone, if thats okay. If we dont make MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

24 1 it, thats okay also.

2 I would like to get started with Quality Assessment 3 Value-Added.

4 Steve.

5 MR. LOEHLEIN: Thank you, Lew. Ill 6 try to speak up until this microphone comes up. Im really 7 happy to be here today on behalf of the Quality Assessment 8 Organization, and the work were doing. And I wanted to 9 speak just for a minute about the nature of the business, 10 Quality Assessment.

11 What we do is really a lot like what the NRC does, 12 we find problems, and this is a tendency to perceive as 13 negative. So, we talk about Value-Added Quality 14 Assessment. I think we can really look at it as something 15 we want to do, since we want to find problems and resolve 16 them before they impact nuclear safety. Thats really our 17 role in the organization; to be a barrier, independent 18 barrier, whose only job is to assess the organization.

19 Specifically -- the next slide please. At this 20 time, weve got three major responsibilities. Weve got to 21 ensure the plant is ready to restart and operate safely for 22 the long term. Weve got to ensure the staff is ready to 23 restart and sustain safe performance. And weve also got 24 to ensure our own effectiveness of the Quality Assessment 25 Organization.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

25 1 So, in my presentation today, Ill be talking to you 2 about how our assessment activities are organized in 3 relationship to the sites Building Block Plans. Ill give 4 you some examples of our performance to date in the Quality 5 Assessment area. And I would like to discuss what our 6 organization is doing to demonstrate the strengthening of 7 our own effectiveness.

8 Next slide, please.

9 First, in Assessing the Plant and Staff Readiness.

10 What we have done is weve aligned ourselves with the 11 Building Blocks. What were applying is really a 12 three-step approach. First is confirm the acceptability of 13 Building Block Plans itself. And weve completed that 14 assessment in six of the seven plans.

15 Next in the phase that were really active in right 16 now is the oversight of the plans as they are being 17 conducted. And the key to this area is the independent 18 parallel efforts that were doing to measure the 19 effectiveness of those plans. Ill show you the examples 20 of some of the things weve done.

21 And finally, the last phase would be evaluate the 22 effectiveness of the plans based on the results that come 23 out of them.

24 As I said earlier, most of our three-step process 25 has been in step two of the process, which is the oversight MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

26 1 process. Ill take you through a number of the individual 2 Building Block Plans and report on an item of interest in 3 each one of them.

4 Next slide, please.

5 The first is as it relates to Reactor Head 6 Resolution Plan. We had an issue develop out of the Direct 7 Field Observation of contractor qualification activities 8 for the containment rebar cad-welding. In this case, we 9 found issues with inadequate documentation to support the 10 activity in the field, and we had issues with the 11 contractors through NRC oversight of that activity. Took 12 those issues to the contractor, who immediately stopped 13 work. We directly observed his plan for remediation and 14 provided heavy oversight to ensure that that activity went 15 off correctly, which it did.

16 MR. GROBE: Steve, before 17 you go on, did you have any observations regarding the line 18 organizations oversight of that contractor work?

19 MR. LOEHLEIN: The supervisor 20 alignment, you mean the supervisors in maintenance?

21 MR. GROBE: FirstEnergy, 22 whoever had responsibility for project management of that 23 activity in FirstEnergy.

24 MR. LOEHLEIN: Yes, as a matter 25 of fact, project manager was the person who we went to for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

27 1 his resolution of the issue when we first identified it, 2 and he was involved with our contacting the contractor. At 3 the time the contractor didnt happen to be there at the 4 time that we spotted these particular deficiencies. QA was 5 when we identified them. He was notified and participated 6 in the, in the reaction we took with it.

7 MR. GROBE: For contractor 8 quality, the first lines of defense are the contractor 9 organization itself and its quality assessment; seemed the 10 second line of defense would be FirstEnergys Project 11 Management Oversight; then the third line of defense would 12 be your oversight assessment.

13 MR. LOEHLEIN: Thats correct.

14 Thats exactly right. Thats what we would expect.

15 We also know that the site right now is carrying on 16 a number of parallel activities, which tends to stress the 17 organization. So, we dont, wed be unrealistic to expect 18 they would be there on top of every activity at every 19 moment. So we, you know, I think we all work together in 20 assuring the quality. I must have misunderstood the 21 question.

22 MR. SCHRAUDER: Jack, we did have 23 line management oversight of that. Our project managers 24 had identified certain issues, quality issues with the work 25 that was going on. We were addressing them on a case by MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

28 1 case basis. The QA observation of training activities and 2 that was what Ill call the straw that broke the camels 3 back, essentially making sure the stop work was replaced.

4 That had to do with the Quality Assurance Oversight of the 5 project, but our project managers were on the job and were 6 identifying deficiencies and correcting them on the spot.

7 MR. LOEHLEIN: This issue really 8 was, to clarify this, was a qualification issue, which 9 meant the actual field activities were not being 10 conducted. That was the reason why we at QA were in 11 particular interested, because its an item we like to look 12 at before it results in any actual field work; the place we 13 want to be in terms of preventing issues.

14 MR. MYERS: We did have some 15 issues we think with contractors during this issue, made 16 some changes there; is that not correct?

17 MR. LOEHLEIN: That is correct.

18 The contractor himself took direct action with some of the 19 people involved in terms of their standards, and took 20 corrective action.

21 MR. GROBE: I dont want to 22 diminish the value of the Quality Assurance Organizations 23 identification of these issues, but a couple meetings ago 24 we heard about a contractor who was working on the polar 25 crane, and deficiencies were identified by several levels MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

29 1 of management above the project manager; and, heard that 2 same discussion of stressed organization, lots of 3 contractors.

4 I think youre finding on cad-welding was probably 5 several weeks ago, but I was wondering, maybe you can give 6 me the answer later if you dont have it now, but what 7 actions FirstEnergy is taking to strengthen its contractor 8 oversight?

9 MR. STEVENS: I can answer 10 that. Weve gotten together with the project managers 11 group, taken a look at how we have the organization 12 structure put together to implement the work. We just last 13 week revamped and reorganized our work support center, the 14 project manager structure, as well as integrated some of 15 the projects into the maintenance organization and made 16 sure that we had correct ratio, if you will, of FirstEnergy 17 Davis-Besse employees with the contractors.

18 In addition to that, Ive met with each of the 19 leads, the superintendents and the supervisors of our 20 contracted work force to make sure we understand what the 21 standards are for working at the plant, and the expectation 22 for work quality.

23 We also, to prevent putting the work force in a 24 situation where they may have been pressed for time or 25 trying to execute the work without it being ready, which MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

30 1 would maybe set up an event, weve instituted ready 2 meetings during the day pretty much every day of the week 3 to watch all the major projects to make sure we understand 4 what the level of readiness is, what the needs are; and 5 then in addition to that, weve scheduled the managers some 6 field observations, as well as tightened up our 7 observations of work activities in the plant.

8 Ive personally talked with several of the project 9 managers, who I felt like we werent meeting the standard 10 in every case. In other words, weve gotten some 11 indication looking at the observations that were not where 12 we need to be with foreman groups or work packages.

13 And got some feedback from the project managers, 14 toured the area with the project managers, visited with the 15 supervisors that are responsible for that work, corrective 16 behavior in the field.

17 And got to the point now, where I go out and I look 18 and I see the right behavior, can reinforce the positive 19 behavior and start reinforcing, looks like were doing 20 correctly, and its changed.

21 Im not saying, this is the skeptical side, the 22 oversight, we still have to manage that, but it is 23 changing; the performance is improving as a result of 24 that.

25 MR. GROBE: Okay, thank you.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

31 1 MR. FAST: Jack, just to 2 reinforce that, what Ill term an anecdotal piece of this; 3 I made a tour on Saturday morning visiting all the major 4 projects. In every case, there was a supervisor and 5 project manager on the scene. Those were in the 6 containment projects.

7 But just to reinforce what Mike is telling us, I 8 have seen that we have much better oversight. So, as I 9 visited the containment sump and decay heat valve pit, 10 containment air coolers, the refueling machine 11 modifications underway; every project had a supervisor, 12 direct supervisor oversight, something I look for when I do 13 field walkdowns and observations, as well recognizing 14 direct project management support.

15 MR. GROBE: Okay, thanks, 16 Randy.

17 MR. LOEHLEIN: Ready to move on 18 to next slide.

19 Under Containment Health, I would like to point out 20 Independent Field Walkdowns. This is where the QA people 21 went out on their own, not as part of an engineering team 22 with anyone else, find the criteria we were looking for, 23 for conditions in containment or extended condition.

24 And the results of that, what we found is that the 25 containment health walkdowns were fully effective. We MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

32 1 found nearly duplicate reports on each of the areas from us 2 in line. So, we found that to be an effective thing that 3 was done. Some of the minor differences we found were 4 mainly cosmetic; differences in opinions of what is 5 cosmetic and things to do now.

6 We also, point out below, it identified some issues 7 in qualification and work packages area related to the 8 valve contractor. And this is a case where there is a 9 lineup with what some of the other managers were saying, 10 when this was first revealed, there might be some issues 11 here with qualification of work packages. And the line 12 organization got involved with this right away, and this 13 was taken care of before it resulted in kind of issues with 14 plant components.

15 MR. MYERS: That same 16 contractor is pretty much involved with the valve work 17 after the draindown. And weve met with them, I met with 18 the person, made sure we got good integration of our 19 maintenance group with that team. We believe thats why 20 its going to go very well. We were assigning each and 21 every valve to one of our managers to look at, because we 22 dont want to come back up and have problems.

23 MR. LOEHLEIN: Thats another 24 reason we took a hard look when we did, we knew the 25 contractor was going to do a lot of the valve work and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

33 1 important valve work and the deep drain while were in 2 this. We wanted to make sure we had any issues 3 straightened out before we did that work.

4 MS. LIPA: Steve, did you 5 have any examples of the design basis issues that you 6 identified?

7 MR. LOEHLEIN: Yeah, kind of 8 things that come to mind that I recall is that we had 9 identified an issue with a containment air cooler fan flow 10 and questioned the design basis for that flow rate.

11 Another is air temperature is measured down in the air 12 coolers, and some question whether that properly identified 13 the possibilities of stratification in containment. There 14 were a few others, but they were identified on future 15 reports. Ive given you the details on that, that we 16 have.

17 MS. LIPA: Thank you.

18 MR. LOEHLEIN: Im sure 19 Mr. Farber is ready to say hes already seen them.

20 Next slide, please.

21 Under the Program Compliance Plan, here weve been 22 very active in observing the operation of the Program 23 Review Board, and we have confirmed that that board has 24 been both intrusive and effective in their reviews. In the 25 concept of independence, we identified six selective MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

34 1 programs to reviewing independently, so we can compare our 2 results against what the line organization reports in that 3 review.

4 Now, the six weve selected, none of those have yet 5 been reported as complete by the line organization, so we 6 issued no formal report on a finding on those yet.

7 Next slide.

8 System Health Assurance. Once again, I would point 9 out the independent reviews were doing. We selected three 10 independent systems to look at, using the process thats 11 established to do it. And, one of those three has been 12 completed by the line. Its 125 volt, 250 volt VC, which 13 Mr. Farber I think commented on as well.

14 We did find generally that that review was 15 successfully done. We found a number of conditions that 16 were not especially significant, that we did put on our 17 condition reports.

18 MR. GROBE: Before you go on, 19 Steve, the last bullet or the last dash, I guess on that 20 slide; could you expand on that just a little bit?

21 MR. LOEHLEIN: That really represents 22 what showed up on many condition reports when the QA 23 Evaluator originally went through the process. We tended 24 to go a little deeper and evaluated our responses to 25 commitments and to condition reports historically, and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

35 1 aligned them when we went through the same process.

2 So, we wrote down on a condition report. Would not 3 evaluate what that means in total yet. We are going to do 4 three systems, and write a report on what we think of all 5 this. Preliminarily that was our assessment of that 6 particular review. So, those aspects will be more 7 extensively done. That was just between us and them.

8 Next slide, please.

9 Under Management and Human Performance, key thing 10 thats happened in recent weeks has been in the case 11 study. I thought I would share with you how Quality 12 Assessment Organization got involved with this. From the 13 beginning, we made sure we were involved with all of the 14 developmental activities that were conducted over in 15 training, and participated in lots of feedback on what we 16 saw in the train the trainer type of classes, and content.

17 I went to several of them myself, having done the 18 root cause, to make sure that root cause was accurately 19 portrayed as related to the lessons we needed to learn.

20 Then, what we did, when it came time to roll it out, 21 the day before the site had the roll out, QA had a live 22 presentation conducted by Dave Eshelman, who did the video 23 assisted by others. We wanted to do a couple things with 24 that. We could then assess the significant difference in 25 the value of the live presentation and videotape that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

36 1 people would see. It also gave us a chance to prepare for 2 the presentation that would be done the next day; what we 3 would be looking for at various site groups.

4 Then, we did an observation of divide and conquer, 5 basically, the entire QA organization. And there is very 6 few of these case study presentations that we do not 7 participate in or lets say observe. And then, when we 8 were done observing, we got together as a team and 9 discussed what future communication activities we thought 10 would be useful for the site.

11 What we found was that case study was effectively 12 done; effective in that most of the employees seemed to be 13 really embrace the opportunity to understand the case study 14 and move forward from it. We provided a condition report 15 that as a result of that recommends some additional 16 communication in and management might take on to build on 17 those, what was done in case study.

18 We also have taken the case study results to the 19 other two sites. I myself, I went to Perry and Beaver 20 Valley to participate in case study discussions with the 21 Employee Assessment Organization.

22 I might also mention on here, we did a case study of 23 the Management Observation Program and that was ruled out.

24 Once again, quality assessment tried to get out there 25 early, see what the issues might be there, in the early MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

37 1 days.

2 Initially we found with the observations, there 3 times when their issues deserved a condition report to be 4 generated for the organization to deal with, and there were 5 times we found that they were not being reported that way.

6 We wrote that up, reported that to the line. We were 7 already starting to see some improvement in that area in 8 the observations that were looking at now.

9 Next slide.

10 Outside of these Building Blocks Plan work that we 11 do, we still have our normal Quality Assessment activities 12 that we conduct, and we report on these on a quarterly 13 basis. Ill point out a few bullets of noteworthy issues 14 we had on the most recent report.

15 Maybe the second one here is a good one to talk 16 about, Radiation Protection Area. We had an issue 17 identified on a condition report which a high radiation 18 area is protected by a floor plug had, nearby had a lift 19 ring available for use, had not been secured, that 20 theoretically someone could have used to lift the floor 21 plug and violate the high radiation area. Did not occur, 22 but potential was there.

23 The QA Evaluator through his investigation found 24 that, that had happened some months back, a similar thing, 25 with a lift ring in an area like that. So, we wrote a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

38 1 condition report requiring a higher level evaluation to 2 find out why the action we took some months ago did not 3 prevent this action or this thing from happening again.

4 My final slide.

5 MR. MENDIOLA: Before you leave 6 that slide, slide 14 there, can you characterize that 7 fourth dash a little more for our understanding.

8 MR. LOEHLEIN: The non-destructive 9 examination. That was a case where we found that the field 10 welds had been installed on these flow meters that 11 incorrectly did not call for a radiograph. We found that, 12 pointed that out.

13 MR. MENDIOLA: Okay. So, the 14 response of the closeout of that item has been done?

15 MR. LOEHLEIN: Whats happened is 16 the line has responded to that and since found that was a 17 case where they actually should have been called for, 18 taking care of, I dont recall if they have been done yet.

19 MR. COLLINS: Steve, I have one 20 question about the overall trend on your slide 14. How 21 many of these would you expect in an ideal situation to be 22 part of the poor planning process rather than being found 23 during the work processes? In other words, there are two 24 stop works and one last item here, as Tony mentioned, that 25 appears to be, thats probably a department modification, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

39 1 right?

2 MR. LOEHLEIN: Right.

3 MR. COLLINS: So, part of a 4 modification package. Is it your expectation that as part 5 of a job process and work order, modification package, that 6 that would include promulgating experience that you would 7 go back and look at the trends of corrective action. You 8 indicated a concern about QA issues. You cant ask perhaps 9 QA to bring that to the table as a part of the preparation?

10 MR. FAST: The field would be 11 responsible, the line organization would be responsible for 12 ensuring that thats do-able. So, thats available by our 13 report management. We didnt catch that in process.

14 MR. COLLINS: Is that data 15 available? In other words, I know youre revamping your 16 Corrective Action System looking at your trends, looking at 17 historicals. These are historical issues perhaps. Youre 18 changing your processes. Is that type of information 19 available to your staff to build a work package?

20 MR. STEVENS: Yes. The 21 information associated with issue reports that are 22 documenting this?

23 MR. COLLINS: Right.

24 MR. STEVENS: And corrective 25 actions to be evaluated, corrective actions will fall into MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

40 1 it, and well look to improve.

2 The stop work order for the fuel work went as a 3 result of direct observation where we had grid strip damage 4 and its effects. We understand that violation, and issued 5 a stop. I thought that was pretty good.

6 The stop work order for the inadequate work with the 7 feedwater heater. We had a contractor subcontracted to 8 replace that heater and build it in place, like if it was 9 in their shop. We took the documentation, married it with 10 the work order, had him working to his document and ours.

11 We got oversight, looked at that and said, hey, this isnt 12 in accordance with our control work procedure. We stopped.

13 We got the work documents. Married together. And 14 proceeded on, so.

15 And, we dont, we didnt have a procedure for that.

16 We didnt intend to finish that work order to the field 17 that way without the vendors instructions with it. And 18 project manager and supervisor overseeing that intended to 19 build the heat shield to do that, and incorporate their 20 documentation at the end. That was a misunderstanding of 21 how we would be working on a piece of equipment.

22 So, we corrected that; and we did a review cursory, 23 didnt see any other areas where we had that kind of 24 situation where were relying on vendor information to do 25 the work actually in the field and have shelter where MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

41 1 youre trying to control it, in that case.

2 The non-destructive examination was right out of the 3 retest. Take that off of the design, either comes from our 4 retest procedure, retest requirements, or its part of the 5 design change package. And what was recognized was we 6 didnt specify the radiograph for the weld.

7 We have to do that, and it got missed through the 8 review. More of a, that being part of the modification, 9 that was more of a human performance review to 10 specification, than it was a procedure compliance or work, 11 work issue. You had to know that at some level of 12 technical knowledge the type of weld and specification.

13 We took that and reviewed that back through the 14 Quality Control Organization, I believe, who went and 15 reviewed all the other welding that we were making to make 16 sure that we didnt have any others out there without 17 adequate retest.

18 MR. MYERS: I really believe, 19 you know, that its one of these, you cant win. If 20 Quality Assurance finds anything, or we find something, you 21 know. Whats good is, I think, is fixing the problems you 22 find.

23 You know, we want our quality group in the field.

24 We want them to do things. We stop the work and take 25 corrective action. We did that when we found the vendor MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

42 1 problems in training. We found our own problems on the 2 crane. We took the two weeks to make sure that crane was 3 in good stead before we went forward. And we probably 4 couldve justified some of that stuff. We didnt. We made 5 sure it was in good stead until we were satisfied.

6 Then, on the containment you know, were the first 7 company I think in the country to take a big reactor vessel 8 head across the state, wash away your concrete, cut your 9 containment, put your new head in, then plug it back up.

10 If I had to go back and analyze how we did that, its not 11 problem free. We had problems on the vendor procedures.

12 We had problems with the welding. I can tell you a number 13 of problems. But when I stand back and look at it, we did 14 a quality job. We did a pretty quality job, you know.

15 MR. COLLINS: I would agree, but 16 you would acknowledge there is a difference between first 17 in technology and routine work.

18 MR. MYERS: Yeah. And we had 19 about 1200 or 1300 contractors in there. The more we were 20 in the field watching, we know whats going on. And I 21 expect our quality group to find some things. I feel bad 22 every time they do, we didnt find it ourselves. But in 23 general, with all the work going on, really have going on, 24 I think hopefully concerned about any of the things we 25 find.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

43 1 MR. COLLINS: Thank you.

2 MR. LOEHLEIN: I would also like 3 to point out that one of the reasons we are mentioning stop 4 work orders is because I want to make clear to everyone we 5 wont hesitate to exercise an authority to stop work if we 6 think the timeliness of the situation demands we do so, on 7 something that would affect quality. So, thats, this is 8 an authority we take seriously, we have to exercise.

9 MR. MYERS: Once again, I 10 think most important is when our quality group finds 11 something, they have management support to take the actions 12 they need. I dont think youll find anybody at this table 13 that you wouldnt have that. Thats the environment were 14 looking for.

15 MR. LOEHLEIN: Next slide.

16 My final slide, to wrap up what we discuss today; 17 Strengthening Quality Assessment. What weve done so far, 18 as weve said at prior meetings, that we have done 19 organizational changes. We comment today about management 20 changes.

21 The part were in right now is were, were taking 22 action, for instance, stop work orders, if thats what it 23 calls for; were conducting independent intrusive 24 assessments; were participating in ensuring that case 25 study is well done and presented and the work went out to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

44 1 all those that needed to have that information.

2 In terms of wrap up, I would like to share with you 3 something were doing right now, is the Quality Assessment 4 Program Review. We brought in about six outside experts.

5 Its their job to evaluate the Quality Assessment Process 6 that we have right now, so it will be the best it can be 7 when we restart the plant. Thank you.

8 MR. GROBE: Do you have 9 questions?

10 MR. MENDIOLA: Yes. Steve, my 11 question is actually kind of simple. Basically, Quality 12 Lessons Learned has to be Quality Lessons, and clearly, 13 youre looking at things across the board, whether it would 14 be a hardware issue or software issue and youre getting a 15 lot of input into your organization.

16 MR. LOEHLEIN: Right.

17 MR. MENDIOLA: So, it will surely 18 filter back out to the processes to make them better.

19 My concern quite clearly is, is if you can kind of 20 estimate the size and scope of the work; is it too much out 21 there to do; do you have enough staff to do it all or?

22 MR. LOEHLEIN: Yeah, I would like 23 to answer it this way. Weve gotten really great support 24 from our other sites. We have several people from each of 25 our other sites rotate on assignment to us, and theyre MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

45 1 helping us through the Building Block Assessments. We also 2 have several contractors, give us a lot of experience there 3 on this restart.

4 We have apprised the need to augment staff to do 5 these, what I call, nuts and bolts of the assessments. The 6 long term things that we want to do with our organization, 7 were taking on primarily with our normal staff. They are 8 involved in case studies, for example, and observation of 9 those. And they will be involved quite a bit on this heat 10 drain work, provide a lot of the oversight on that. But, 11 yes, we would recognize that we have a lot of work to do, 12 and lot of staff reporting.

13 MR. COLLINS: Steve, I had a 14 comment perhaps you might want to respond to it. When you 15 look, if youre able to, but Ill point you to slide 7, 16 Responsibilities. Quality Assessment. And focusing on the 17 word ensure. And I guess Im contrasting that with the 18 responsibilities of the line organization, who own these 19 processes and programs.

20 I really am wondering if you have a view of the 21 division of responsibilities between the implementers, if 22 you will, people that work with the processes, own the 23 systems, operate the systems, and quality assessment; and 24 how you would define quality assessment?

25 It appears to me that the value here is, as MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

46 1 indicated by your examples taking them at face value, that 2 youre exerting yourself in these processes, finding good 3 issues, corrective actions are implemented and we can move 4 on. Thats success perhaps for the stage of programs and 5 processes at Davis-Besse as we sit here today.

6 Contrast that with the fact that you look, but you 7 dont find, because things are going well; and, value-added 8 is more confirmatory rather than ensuring; and what that 9 message is to the line organization. Do you have a comment 10 on that?

11 MR. LOEHLEIN: Yeah, I think its 12 interesting. My staff is probably chuckling right now, 13 because Ive had a lot of discussion in staff meetings 14 about the difference in the role of the real people that 15 ensure quality are the line organization, because they all 16 had a chance to be in the line.

17 We are an assessment group. Our job is to have a 18 single-minded focus, not having distraction of schedule and 19 cost and those types of things, only going out and 20 independently assess how effective the organization is 21 implementing the Quality Assurance Program.

22 So, I guess I would chastise myself for having used 23 the word ensure, and Im sure theyre getting a little bit 24 of a chuckle out of that, because Ive chastised them for 25 not recognizing the difference.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

47 1 So, clearly our job is assess, to provide 2 recommendations where we can do so for improvement. And 3 the line organizations job to internalize that they are 4 quality, they are a quality organization, as implementers.

5 So, I agree with that a hundred percent.

6 MR. STEVENS: I can provide an 7 anecdotal example. Last week, week before, we had all of 8 our maintenance supervisor go through a qualification board 9 at the end of completing the practical facts, if you will, 10 for qualification.

11 Steve sat on one of the meetings, boards I chaired, 12 we have managers and we ask questions. And the probing 13 questions; its not an easy board to get through. Steves 14 questions center around line ownership to ensure that were 15 meeting X and in accordance with.

16 And one of the questions he asked was, to one of the 17 electrical supervisors was, how does 10-CFR-50 apply to you 18 in your everyday job. And, when you first hear that, it 19 was, its a little bit, its not something you talk about 20 every day, but it brings home that ownership and that 21 understanding. We implement. Quality assurance is 22 providing the oversight to make sure that were 23 implementing it. That becomes very clear.

24 MR. COLLINS: Thank you.

25 MR. LOEHLEIN: Ill turn it over MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

48 1 to Bob Schrauder.

2 MR. GROBE: I have one more 3 question, if you dont mind. First an observation just to 4 echo something that Sam, observation that Sam made.

5 The findings that youve highlighted today, and 6 certainly not your only findings, just a sampling of your 7 findings; these are not superficial issues, and it takes 8 capable people to find these type issues. I compliment you 9 on that.

10 Do you have within your structure a process where 11 you determine whether or not an item that you identify is 12 something that youre going to follow-up on, an additional 13 focus audit?

14 MR. LOEHLEIN: Really, I dont 15 know if you finished the question; are you finished?

16 MR. GROBE: Go ahead.

17 MR. LOEHLEIN: How we decide to 18 focus on? I will tell you this, Jack, that is part of the 19 program review were doing, because right now what we rely 20 on is sort of inscribed. If we see issues in certain 21 areas, we ask ourselves, is that telling us something and 22 thats how we decide to do a focus assessment in a given 23 area.

24 The trouble with that, we think, is that may not be 25 as objective as it needs to be based on the informational MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

49 1 criteria to really look at the right things. So, as part 2 of the program review as it is now, is one of the 3 challenges we have for our team is to try to advise us on 4 criteria based assessment decision-making which we do, 5 because right now we do rely on exactly what you describe.

6 We like to discuss it with the supervisors, myself, 7 for example, overseeing this area, that area, and focus on 8 that. And theres nothing wrong with that, but its not 9 the criteria base. It may not be the best way to focus our 10 resources. So, were looking at that.

11 MR. GROBE: Our inspection 12 program includes a broad set of baseline inspections, 13 which I describe as a criterion basis inspection program, 14 as well as when we find something that appears to be more 15 substantive to specific targeted inspections, call those 16 supplementals.

17 The issue of contractor control concerns me. Is 18 that something that you consider doing an additional 19 assessment? Ive heard from Mike and Randy, that 20 additional emphasis is being placed on the organization to 21 provide contractor oversight, but had you considered it?

22 MR. LOEHLEIN: I have to admit right 23 now, Jack, I dont know that the status of our, obvious 24 status of the contract issue. We have had different issues 25 with different contractors, we discussed that. And so far, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

50 1 our sense is that they are just that, they have been 2 different issues. And its been more along the lines of 3 the managers here talk about that weve not perhaps as a 4 management team been involved as we need to be, and thats 5 where the actions are going right now.

6 I dont think weve drawn conclusions to do a 7 separate audit in that area yet.

8 MR. GROBE: Okay. Okay.

9 Very good.

10 Any other questions from the NRC. Great. Thank 11 you.

12 MR. LOEHLEIN: Ill switch spots 13 here, so Bob can be well heard.

14 MR. SCHRAUDER: Thank you, 15 Steve.

16 Im Bob Schrauder, the Director of Support Services 17 Organization, and management oversight for the reactor head 18 replacement.

19 Very brief update on where were at with that. I 20 stated last time that our service structure was in place on 21 the reactor vessel head. It is welded on now. All the 22 touch-up paint is done. That job is virtually complete.

23 We have a few cables to reconnect yet, the position 24 indication groups, the control rods. The control rod drive 25 mechanisms are reinstalled on the reactor vessel head and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

51 1 we still have to attach a couple of the lifting devices to 2 replace the head onto the vessel. But that job is very 3 nearly at successful completion now.

4 With regard to the head that we replaced, we have 5 moved that out of the turbine train building into a 6 temporary storage building, out on the dry cask fuel 7 storage pad that we had poured and well retain it in that 8 temporary storage building until after the, after this 9 outage. And, then we intend to take some additional 10 samples off of the head for ongoing research by the 11 industry and the NRC.

12 Then, thats the status of the head.

13 Now, the issue that we addressed last week, Ill go 14 over a little more, and that is with regard to the bottom 15 head of the reactor vessel. As you recall, we had some 16 material going down the side of the vessel, and had Boron 17 accumulated on the bottom nozzle.

18 We were unable to positively exclude through 19 chemical analysis that those Boron deposits on the bottom 20 head were not coming from leakage from the incoming nozzles 21 on the bottom.

22 As Lew alluded to before, we have gotten together 23 with Framatone. They have made recommendations to us and 24 we are proceeding with a plan on what we will do to assure 25 ourselves that the bottom nozzles are not leaking on the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

52 1 reactor vessel head.

2 Ill walk through a couple of those steps with you 3 here. First of all, the first step here we have completed, 4 we thoroughly cleaned the sides and the bottom head and 5 have removed any indication of Boron thats down there 6 now.

7 As we complete this outage, well restore the head 8 on the vessel, then well bring the Reactor Coolant System 9 up to normal operating pressure and temperature. Well 10 hold then that temperature and pressure for 3 to 7 days.

11 We havent zeroed in on the exact amount of time, but 12 approximately a week well have the plant up at normal 13 operating pressure and temperature.

14 Well then bring the temperature and pressure back 15 down. Well remove the insulation off of the vessel 16 again. And we will perform a bare metal inspection, this 17 time prior to restart, so we will have a very good picture 18 before and after.

19 The next slide we show why we think that will be 20 effective. And then, as we complete this outage, bring our 21 unit back on line, we have talked about before, we do 22 intend to do a mid cycle outage. We will take the 23 insulation off the bottom head again. We will reperform a 24 bare head inspection at that time.

25 Then, were also continuing our investigation of our MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

53 1 on-line leak detection system we will install on the bottom 2 head. And, were continuing to look at that. If we can 3 get it in during this outage, we will put it in, in this 4 outage. It is more likely that it will be in the mid cycle 5 outage before we are able to get all the hardware and 6 complete installation of that. But our intent is to put an 7 on-line monitoring system on the vessel, probably will be 8 on the bottom vessel as well as the head.

9 The next --

10 MR. GROBE: Bob, before you 11 go on, could you explain a little more detail why you need 12 to put fuel in the reactor to do this test, and then 13 secondly, how you raise your Reactor Coolant System to 14 normal operating temperature and pressure?

15 MR. SCHRAUDER: Sure. We 16 looked at our ability to bring the system up to its normal 17 operating temperature and pressure without fuel as is done, 18 its a hot functioning test before you go in operation, 19 the equipment used to do that.

20 The issue there is you have to get proper 21 differential pressure through the vessel so that your 22 reactor coolant pumps dont exceed, and rerun it in that 23 condition. So, you have to put in some, something that 24 will simulate the core, basically to give you the proper 25 differential pressure across what is normally the core.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

54 1 The way that you heat up the vessel in this 2 condition is not with nuclear heat, but actually with heat 3 coming off of the reactor coolant pumps themselves. And 4 so, and thats what we usually heat this up to. Even 5 though fuel will be in the vessel, its not nuclear heat, 6 we will be using generator pressure from the reactor 7 coolant pumps themselves.

8 We were unable to get plates, and the equipment 9 thats necessary to create the differential pressure. They 10 just dont exist anymore in the industry. And so, were 11 not able to get that equipment. So, were going to need to 12 put the fuel back in the vessel in order to get the proper 13 differential pressure across the vessel.

14 MR. MYERS: Also, the seal, 15 Bob, the way our incore seal, seal moves in and out. There 16 is a seal at the end of the incore, with them installed, 17 the seal is made up. And so, if you have the incore 18 installed, try running the pumps, that wouldnt be good.

19 And if you pull them out, you cant get a seal. So you 20 couldnt get the pressure. So, you have to have the incore 21 installed to get your fuel to do that. Thats what we need 22 also.

23 MR. COLLINS: Excuse me.

24 MR. MYERS: Those are the 25 conditions thats driving that.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

55 1 MR. COLLINS: I had a question 2 of clarification for you. I understand youll be 3 performing nuclear tests before the NOP/NOT Operation?

4 MR. SCHRAUDER: Integrated leak 5 test on containment?

6 MR. COLLINS: Correct.

7 MR. SCHRAUDER: Yes, sir.

8 MR. COLLINS: Thats to ensure 9 your interior area is intact?

10 MR. SCHRAUDER: Yes, sir.

11 Containment integrated test will be done prior to, before 12 the normal operating temperature.

13 MR. COLLINS: And I think, as 14 far as a leading technology, we would be very interested in 15 your online integrated attempt, realizing its not required 16 by the license. One of the lessons learned through reading 17 the NRC Lessons Learned Report from Davis-Besse is to 18 challenge yourself to go back and look at the existing leak 19 rate requirements specs, when you go through the 20 specifications, or one gallon un-identified, and the other 21 criteria.

22 So, were looking for enhanced ways consistent with 23 some of the technology thats overseas, as you say, to 24 supplement those systems.

25 MR. SCHRAUDER: We do believe MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

56 1 the technology is available for this leak detection 2 system. Its a question of whether we can, the amount of 3 time it will take to get the equipment here, and to 4 complete the design modifications to install it on the 5 vessel during this outage. And as you said, this modern 6 system is used overseas in several reactors.

7 MR. COLLINS: In conjunction 8 with that, of course, that would require a response 9 procedure by operators and perhaps even modification of the 10 simulator has been wanted warranted to deal with the conditions and 11 the expectations of the operators in response to this.

12 MR. SCHRAUDER: Right.

13 MR. GROBE: Just one more 14 thing, Bob. This is the issue Sam is addressing on the 15 need to address. This is an interesting enough issue, but 16 once you finalize your design and have a good grasp on it, 17 may want a meeting with us, just to go through the system, 18 how its going to work. As Sam indicated, how the 19 operators, what kind of operators youre going to have to 20 respond to it. Similar to what youre doing in sump 21 modification.

22 So, we need modification. I think it would be 23 beneficial if you can, then chat with us prior to that.

24 MR. SCHRAUDER: Right, we 25 were planning on that.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

57 1 MR. MYERS: Were pretty 2 excited about this new technology, about the Flus Monitor.

3 MR. GROBE: Okay, go 4 ahead.

5 MR. SCHRAUDER: This graph, 6 the next slide shows a graph of the type of accumulation of 7 Boron you might expect to see for the various leak rates.

8 This was developed for us by Framatone. The original graph 9 of the whole series of how long you held the reactor at 10 normal operating temperature and pressure.

11 I chose 7 days as the example here, but you can see 12 that you would actually begin seeing some Boron deposits 13 for as little as a millionth of a gallon per minute leakage 14 was deposited on the nozzles. And then as you go into more 15 leakage down to ten millionths of a gallon, for example, 16 you see youre up over the inches, in cubic inches of 17 Boron you would be able to detect on the bottom nozzle.

18 So, we believe if there is leakage on the bottom 19 nozzle, we will be able to have the system up and pressured 20 for a week.

21 MR. GROBE: So, this is one 22 graph, 7 days.

23 MR. SCHRAUDER: There are a series 24 of graphs for 3, 7, 10 and 30 days, but it looked like 7 25 days was fairly reasonable amount of time that you would MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

58 1 expect to see any leakage that might be there.

2 I would also like to add that Framatone is 3 continuing to do some laboratory modeling of different leak 4 sizes held at different pressures to verify. This is 5 analytical curve right now theyre creating --

6 MR. GROBE: I dont want to 7 speak for Bill Bateman, but if I was Bill Bateman, I would 8 ask that exact question. What kind of crack tightness are 9 you talking about, what size of crack, two thousand, maybe 10 2,250 pounds per square inch. That would be great 11 information on what leak rate if you would encounter.

12 MR. SCHRAUDER: Then in the 13 event you do find leakage, we have a fix that is designed 14 and in fact has been used in the industry, not on the 15 bottom nozzle, but on the pressurizer, for instance, this 16 type of repair has been made.

17 And, the first, the first thing here is the, you see 18 on the initial nozzle, the first thing you do is come in 19 and youll pull the incore of the tube out of the nozzle; 20 plug the nozzle from the top of the vessel. You can see on 21 there on the top edge of the, still not right, top edge of 22 the, what represents the vessel is the weld, and that is 23 the current pressure boundary for these nozzles.

24 What well do is well cut that nozzle after, cut 25 the nozzle, youll see in the middle picture, goes up about MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

59 1 an inch up into the metal itself on the reactor vessel.

2 Then there is a head welded onto the bottom vessel, a weld 3 put on down there.

4 Then you take a new nozzle and insert it into the 5 opening and then the new pressure boundary weld is a weld 6 thats put on between the nozzle knob and the head that was 7 welded on the bottom of the vessel. So, you remove the 8 pressure valve inside the reactor vessel to the outside of 9 the reactor vessel.

10 The advantage that this fix has for us is, in that 11 nozzle, the replacement nozzle that goes up in there, is 12 not attached to the remaining piece of the old nozzle. So 13 that if you weld this thing on the top and the bottom, one 14 might say you could just do a weld on the bottom of the 15 thing. Thats preemptive, move the pressure valve down to 16 there. The problem with that is, now youve anchored that 17 nozzle on the inside and the outside, and you can induce 18 thermal stresses into that. As the tube has to expand when 19 you bring the vessel up to its temperature and pressure, 20 this allows for thermal expansion in the nozzle itself.

21 MR. HOPKINS: Let me understand, 22 Bob. So, the leak barrier still will be the top weld then 23 essentially, youre saying?

24 MR. SCHRAUDER: The pressure 25 nozzle there will be welded at the bottom.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

60 1 MR. HOPKINS: It will welded.

2 MR. SCHRAUDER: Yes. That will be 3 where your pressure weld is.

4 MR. HOPKINS: Okay. So, by 5 cutting, youre no longer tying the top and bottom.

6 MR. SCHRAUDER: Thats correct.

7 MR. GROBE: Im not sure how 8 accurate this drawing is, but it appears that the new 9 penetration inserting from the bottom is butted up against 10 the one that youre cutting off. Is that going to be a gap 11 there or --

12 MR. SCHRAUDER: Its 13 essentially, it wont be flush up against it, but pretty 14 close.

15 MR. GROBE: It will be a 16 gap, okay.

17 MS. LIPA: And Bob, this 18 is, as I understand what we were talking about, in more 19 detail on the November 26th meeting?

20 MR. SCHRAUDER: Thats 21 correct.

22 MS. LIPA: Tentatively 23 set up for 26th.

24 MR. MYERS: This is on 25 the schedule though, what is it, three days, Bob?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

61 1 MR. SCHRAUDER: Maybe seven 2 days.

3 MR. MYERS: And its been 4 done on the pressurized vessel before, so its kind of 5 unique.

6 The interesting thing is, the bottom of our vessel 7 is the, the pole, where the pole goes into the lowest 8 temperature, we really dont believe there is a high 9 probability there is leakage there. We just cant 10 substantiate there is not leakage there; that we can 11 substantiate we found that Boron there.

12 So, weve cleaned it up and now we can substantiate 13 it. Well find the leak. And we have the repair at hand.

14 This is the repair suggested for us.

15 MR. GROBE: Sam has one more 16 question, which I think I answered correctly. Youre 17 expecting this is going to be a cold prepare code repair not requiring 18 NRC approval; is that correct?

19 MR. SCHRAUDER: Thats what 20 we believe at this time. Were going to look through this 21 and make sure whether we need any approval or not. We 22 dont believe we do.

23 MR. GROBE: Im sure well 24 talk about that a little more on the 26th, but I appreciate 25 your point, Lew, is you dont expect the penetrations to be MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

62 1 leaking, youre just going to be ready with the design to 2 install a repair, if in fact there is one.

3 MR. MYERS: When we took the 4 chemical sample, we didnt, we couldnt validate from the 5 chemical samples that, exactly where the Boron came from, 6 and we couldnt trace it back either, due to insulation.

7 So, the conservative thing to do is do a good inspection to 8 see if there is leak damage. We dont expect it, we can do 9 a little work and if we find it, we repair and fix it right 10 then. Thats our plan.

11 MR. MENDIOLA: Going back to 12 slide 19, your graph slide, what are the two vertical lines 13 there; that one and the one to the right? Those two.

14 MR. SCHRAUDER: Those are 15 miscellaneous vertical lines. They have no meaning at 16 all.

17 MR. MENDIOLA: Okay.

18 MR. POWERS: I think what those 19 are is, the initial dialogue we had Framatone on those, 20 thats the flus monitoring range, ranges of effectiveness 21 for flus monitoring for tracing cracks.

22 MR. MYERS: Thats exactly 23 what those are.

24 MR. SCHRAUDER: They were notes on 25 this. I cleaned them off, or pulled them off.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

63 1 MS. LIPA: Any other 2 questions for Bob?

3 MR. THOMAS: One other thing, 4 Bob. If the flus monitoring system doesnt get installed 5 on the vessel prior to the NOP/NOT check, are there any 6 other temporary monitoring systems that youll put between 7 the insulation and the bottom vessel and monitor for leak 8 during the cold hold period?

9 MR. SCHRAUDER: Not that were 10 aware of at this time. Were looking for potential for 11 cameras and the like, but it is not looking very promising 12 right now.

13 MR. GROBE: Fairly high 14 temperature environment.

15 MR. MYERS: Were looking 16 into having cameras --

17 MR. GROBE: Talk to the coal 18 miner.

19 MR. SCHRAUDER: We are continuing 20 to look for some cameras that will work. Were 21 investigating that.

22 MS. LIPA: Any other 23 questions for Bob, because this would be a good time for a 24 break. So, well start back in ten minutes at 3:40.

25 (Off the record.)

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

64 1 MS. LIPA: Are you ready, 2 Jim? Go ahead.

3 MR. GROBE: Jim, before you 4 start, just quickly. Apparently, some of us are speaking 5 too softly and if there is any inability to hear, please 6 speak up. Mr. Stucker does an outstanding job, and for 7 some reason some of us have our head turned or something 8 like that, and its not, our discussion is not discernible.

9 Please let us know. Thank you.

10 MR. POWERS: Okay. My portion 11 of the discussion today is focusing on System Health 12 Assurance piece of the Building Blocks. And my desired 13 outcome today is to provide a status of the Latent Issues 14 Review and our plan to perform a Collective Significance 15 Review of the results weve obtained.

16 The Collective Significance Assessment consists of 17 rounding up all the findings that we found from different 18 individual valuations and we use to determine areas that 19 require improvement.

20 You recall at the last meeting I brought along a 21 pretty substantially thick report that we prepared on 22 Service Water System whereby our engineers went through the 23 system in a lot of detail checking a lot of attributes and 24 developing a substantial report out on it, also finding 25 some discrepancies.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

65 1 We did similarly report efforts for five systems in 2 total, plus weve been doing what we call System Health 3 Readiness Review Reports on 31 systems, which are important 4 to the safety of the plant.

5 So, we take all those results from those reports and 6 the findings from the reports and we roll them together 7 with self-assessment activities that weve undertaken, 8 particularly in the calculation quality area. We also 9 rolled together with inspection results that Marty Farber 10 described earlier in the presentation. And, we took all 11 that information and put it together and see what its 12 telling us in terms of areas that require improvement.

13 From the Latent Issues Review, which we did on five 14 systems, as you see here, we checked 31 topical areas. And 15 by a topical area, what I mean is calculations, drawings, 16 what we call system design descriptions, quality of the 17 use. There is a number of engineering documents that 18 provide the basis for a system and its design basis.

19 And a process of going through that matrix of doing 20 those checks of all the individual attributes that support 21 system quality. We did over 14,000 individual checks. So, 22 there is a lot of things we went into checking and looking 23 for any sort of discrepancies.

24 Going through it, we found 777 discrepancies, which 25 is about a 5 percent hit rate. And of those our station MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

66 1 Restart Review Board classified 447, as being required to 2 be resolved prior to restart. That was about three 3 percent.

4 So, we checked a lot of activities and we found 5 about a two percent error rate, if you will, in 6 discrepancies.

7 Now, we added to those findings the results of the 8 System Health Readiness Reviews, Self Assessments and 9 Inspection Results and what we found then -- next slide.

10 The topical areas out of those 31 that really call 11 for more attention and improvements are areas of 12 calculation and analysis, electrical calculations, 13 instrumentation and control calculations; and that 14 typically is set point for instruments in the plant 15 mechanical and structural calculations.

16 And also system descriptions, and in this area, 17 there may be discrepancies between references and various 18 numbers and different references that make up our system 19 description manuals. And as a result of those, 20 configuration management shows up as an area that needs to 21 be improved as well. We refer to configuration management 22 as an overreaching program for all the documentation of the 23 plant to be sure that its managed in a way so it is all 24 consistent.

25 So, we consistently groom configuration management MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

67 1 systems with your Corrective Action Program. And these are 2 areas that thinned out, a significant requiring further 3 work. All the issues that we found during our Corrective 4 Action Program and all the issues are going to be addressed 5 per the Corrective Action Program. These issues will 6 require some additional attention.

7 On the next slide then. We also went through a 8 Collective Significance Assessment of what we call common 9 attributes. These are engineering programs, technical 10 programs. And you can see the list of them, high energy 11 line break. Thats for breaks of steam lines, for example, 12 high pressure and temperature lines that affect the 13 equipment. We design for that.

14 Environmental Qualification. We design the 15 equipment so it withstand access conditions.

16 Appendix R is our fire protection program.

17 Seismic qualification of equipment.

18 Temperature effects upon system operability, and 19 this was several issues, but in particular one of the 20 license men requested that I mentioned at the last meeting, 21 that was related to the lake temperature increases and 22 changing our intake water temperature, to coincide with 23 anticipated lake temperature increases, and carrying out 24 the analysis rigorously into the heat exchangers in the 25 systems in the plant.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

68 1 And the Natural Phenomenon, which can be flooding of 2 the lake, if you get a high enough level to flood into some 3 of the sumps and sump pumps.

4 So, these are areas that were going to be looking 5 at in some more detail, and whats been referred to as 6 expansion plans. Were going forth and taking these 7 results that are of a collective significance and looking 8 into the balance of our, making control safety significant 9 systems to assure that they are safe and ready to support 10 restart and continue live operation.

11 The plans are putting together for that now, take 12 into consideration the collective significance, and it lays 13 out our roadmap, if you will, for what were going to do 14 looking into other systems to be sure that the issues are 15 appropriately addressed in our other systems.

16 So, in summary, were in that evaluation phase now.

17 Other collective significance, this is a valuable process 18 to us.

19 The latent issues process, I think you heard Lew 20 talk about that many times in the meeting. It originated 21 out of the Beaver Valley Plant and we brought it to 22 Davis-Besse also. I think weve improved on it 23 substantially, and we plan to utilize it going forward in 24 all of our FENOC facilities on a regular basis during 25 operation of units.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

69 1 So, with that, Im go to turn it over to John 2 Grabnar. John is our Design Basis Manager, and hes going 3 to talk about our plans going forward and addressing some 4 of the issues we found, collective significance.

5 MR. COLLINS: Jim, if I may, I 6 have a question and you may refer this to John if its more 7 appropriate.

8 The findings that you have depicted on slide 23, 9 have those areas been flagged such that if those calcs or 10 portions of those calcs were to be used in the immediate 11 future given the activity at the plant, if that would be 12 known to the engineers?

13 MR. POWERS: All the 14 discrepancies are flagged within the corrective action 15 process, and one of the more significant activities weve 16 undertaken at the plant in the past several weeks is to go 17 through the process of laying out the communications 18 channels that need to occur, for example, people that are 19 working in calculation topical areas versus system 20 engineers that are working to get their systems ready for 21 restart, and looking at the list of issues that need to be 22 corrected and have those communication channels set up, so 23 people know who is working on what issue.

24 So there is a major set of activities occurring, if 25 you will, and weve gotten all the engineers involved MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

70 1 together to talk about that. And its an area we need to 2 communicate as we go through this aggressively, because 3 there are a lot of activities going on parallel.

4 MS. LIPA: Sam brings up a 5 good point. I hadnt really thought about this before 6 either. If you have a calculation that you find a problem 7 with, you write a condition report on that, and then 8 somebody tries to solve that problem. Is that calc then 9 quarantined so its not used somewhere else?

10 MR. POWERS: Well, the 11 condition report is written against the calculation. And 12 going through the, what we call our press database that 13 lists all the conditions reports and what theyre written 14 against, the activities go on, the engineers need to be 15 familiar with, Chris, and know whats in there in terms of 16 issues that have been written against calculations.

17 MR. GRABNER: Thats one of the 18 issues, Christine, that we are aware of and we are 19 concerned about. Were working on doing that to make sure 20 as part of our review process, first of all, the engineers 21 in the different disciplines are aware of the calculations 22 that have been in question. And we have lists of various, 23 various sorts of condition reports versus calculations, and 24 open items that still remain open from a program that Ill 25 talk about in a few minutes.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

71 1 So, were putting those altogether to make sure that 2 as the owners accept for review upon the modification work, 3 we take into account that A, there are calculations out 4 there that have been that may need to be revised, and could 5 be that we have some other calculations that were working 6 on. And we will have to, were going to make sure were 7 using it in some of the design work going forward.

8 MR. POWERS: Typically, what 9 happens is the supervisor involved in the areas, for 10 example, the analysis group or the service water system 11 that Ive talked about issues, lake temperature and service 12 water, they are aware of the ramification of the systems 13 going into the plant. So, the contracted work thats 14 proceeding under their direction, they have that direct 15 communication and are working at laying out the sequencing 16 of, you know, whats important and the steps which need to 17 occur if the calc has to get revised, when to support the 18 ultimate logic train through the plant. So, its an 19 ongoing process with the supervisors.

20 MS. LIPA: Seems like you can 21 probably have a similar thing with drawings or procedures, 22 where you find a problem while youre solving the problem, 23 that a drawing or that procedure is sitting there where 24 somebody could use it.

25 MR. MENDIOLA: To your knowledge, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

72 1 is there any licensing actions in-house occurring in the 2 NRC review or any recent NRC amendments that we have 3 approved that are affected by any of these discrepancies, 4 that we should be aware of?

5 MR. POWERS: Nothing comes to 6 mind. Two active license amendments or requests that we 7 have had relate to the code applications that, Tony, 8 theres no application on those. And I dont believe that 9 we have any other, currently any other submittals in 10 place.

11 The one we would need that does come to mind, that 12 we need to look into, is the calc on power free 13 modification that we had in pressure resistance. And I 14 think there is one request for additional information on 15 that, that remains to be answered, and thats an area we do 16 need to check and be sure that application is still 17 examined.

18 MR. MYERS: Can we go back --

19 MR. MENDIOLA: The reason I 20 asked -- sorry, Lew. The reason I asked, had to do with, 21 you said more than a few times, the temperature of the heat 22 sensor and things like that, I was wondering if any recent 23 amendments that we allow, or approved, if you will, had, 24 were affected by any of this?

25 MR. POWERS: The one that comes MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

73 1 to mind that actually involves most of the, many of the 2 issues centering around the service water system is the 3 application made for the lake temperature increase, and the 4 difficulties; part of the difficulties were experiencing 5 is in the dialogue with the staff on reaching approval, was 6 taking a design basis consideration that the plant could be 7 cut off from the lake, the canal could be cut off from the 8 lake by an earthquake, for example, and needs to be able to 9 cool the water recirculating now.

10 And when thats a consideration for design, 11 temperature goes up, and that affects our margins of the 12 plant. And so, although that one was approved, its 13 something were looking at a little more closely to see, 14 you know, the basis of approval, if we could work to do 15 more technical work and have further dialogue with staff on 16 that, thats the basis for that improvement.

17 MR. MYERS: What we do, were 18 taking action to go back, go back a year or two, and look 19 at previous approvals we had and bounce it off of this 20 stuff. We can do that pretty easy. So, were taking 21 action to do that. As we sit here, we dont know.

22 MR. HOPKINS: Just to expand 23 that a little bit, you mention here instrumentation control 24 calcs. And again, Im wondering now about set point values 25 and allowables in technical specifications, are those MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

74 1 detected, you know, that were not aware of?

2 MR. POWERS: That needs to be 3 checked, Jon. Thats part of the assessment that were 4 doing in that area is take a look at those critical 5 calculations and certainly those values or set point values 6 of that population.

7 MR. HOPKINS: Okay. So, thats 8 part of your evaluation phase now?

9 MR. POWERS: Thats correct.

10 MR. MENDIOLA: I assume youre 11 talking specifics rather than the methodology. When you 12 said, set point methodology is still sound, your 13 calculations on this are still sound in the way that you 14 calculate your allowables and methodologies; and its just 15 basically on a specific case where they may be a set point 16 that needs to be recalculated?

17 MR. POWERS: What we want to be 18 sure is when a set point has been calculated, that all the 19 associated tolerances and inaccuracies and instrument loop 20 are included in that appropriately. And so the issues that 21 have occurred that have been found in the set point calc 22 area, well be looking at, you know, I say bundling all 23 those issues together, looking at them collectively, and 24 looking at each specific issue.

25 If there is any issues that occur that, that merit MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

75 1 looking broadly across the board at, for example, aspects 2 on set point, for example, thats what well be doing, to 3 make sure that the methodology is sound across the board in 4 this area.

5 MR. MENDIOLA: Thank you.

6 MR. GRABNER: Okay. Good 7 afternoon everyone. Again, Im John Grabner, Manager of 8 Design Engineering at Davis-Besse. I wanted to share with 9 you this afternoon a process that were undertaking to 10 resolve the design-related issues that weve uncovered 11 between our Latent Issues Reviews, the Safety Systems 12 Design Performance Capabilities Inspections, as well as 13 some of our own self-assessments; and talk about not only 14 resolving those, the five systems that weve done latent 15 reviews for, but also for across the other population of 16 important systems of the plant.

17 First of all, as a result of the number of issues 18 that weve identified, Ive issued a functionality review 19 to be performed that will focus on whats the ultimate 20 effect in total of the questions that have been asked on 21 the ability of the five latent issues systems to actually 22 perform their important function. That assessment is 23 currently in progress and we expect that to be done by the 24 end of the month.

25 Secondly, being new to the plant, I had, I didnt MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

76 1 have a good picture of all the design basis activity that 2 have been performed here in the past, so we had a timeline 3 commission, which is down here on the wall to the left. If 4 I could have Chuck here point out as I call some things 5 out. Just point out some big picture items in red.

6 The red bars on top indicate periods of plant 7 operation. The blue bars below them indicate periods of 8 plant shutdown. This timeline starts in 1985, and runs to 9 the present.

10 The green bars in the middle, that first green bar 11 indicates the Davis-Besse course of action, which is the 12 plan we undertook beginning in 95.

13 The second long green bar is our Design Basis 14 Validation Project. Now, Design Basis Validation was a 15 project we committed to as part of our response to the 16 letter from the NRC, the industry received regarding design 17 basis information, commonly referred to as the 10-CFR-5054 18 letter.

19 And in there we took a look at our system 20 description manual, as well as our design criteria manual, 21 which are two documents that we prepared as part of that 22 course of action back in the 80s, and those comprised a 23 design basis of the plant.

24 So, we looked across 29 of our most important 25 systems with this Design Basis Validation Program, and we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

77 1 have a course on every one of those 29 important systems to 2 take a look at all the important features of each system 3 and look for where calculations or analysis supports that 4 that function can be performed.

5 Now, our preliminary review to-date shows these are 6 very good documents. Theyre high quality. They do have 7 limitations. And Ill talk about in the next slide how 8 they correlate with the questions weve had so far. But 9 they provide for us a very valuable resource. And, had we 10 followed through completely with all the issues that were 11 asked back in the late 90s, we would have a lot more 12 issues today that we can talk about.

13 MR. GROBE: John, before you 14 go on, you indicated a third bullet down under Design Basis 15 Validation, that it validated Systems Descriptions and 16 Design Criteria Manual. Were there any deficiencies 17 identified during that process?

18 MR. GRABNER: Yes, there were.

19 We referred to, there is a data base of open items.

20 Originally there were about a thousand, roughly a thousand 21 open items. Now we have 275 or so of those still open 22 today. And the, in fact the third green bar over there, 23 which started around March or April time frame this year, 24 indicates the renewed focus we took on closing out those 25 275 actions. Weve applied a lot of resources to doing MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

78 1 that, and suspect those will be closed out by the end of 2 this year.

3 So, yes, there were a lot of issues. A lot of them 4 were issued, not all of them were answered correctly or 5 completely, however; so, and were finishing that up now.

6 So, from our Latent Issues Reviews, I talk about 7 latent issues. Ill add into here other, of course, 8 activities that we perform on our five most important 9 systems. We do have a number of design basis questions 10 that have been raised.

11 Looking through these, and again, this is all 12 somewhat preliminary in nature. A lot of these issues have 13 been previously identified in this Design Basis 14 Validation. A number of them are merely questions and 15 really arent issues. I couldnt find this calculation, we 16 find actually we do have it. Other cases we thought we 17 didnt do testing and we find a test report.

18 However, there are a number of potentially important 19 issues that were not previously identified that were 20 identified either by Latent Issue Reviews or one of the 21 other reviews that were conducted. So, what were working 22 with, of course, is whats the difference between those 23 two.

24 So, many of the areas that werent previously 25 identified by the way are in topical areas that Jim had MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

79 1 talked about earlier; flooding, environmental 2 qualification, energy line break design, those were topical 3 areas that were not looked at in detail during Design Basis 4 Validation, because specific credit was taken to previous 5 inspection and assessment activities, which by the way are 6 allocated on the bottom half of the timeline, which shows 7 the assessment and inspection activity both internal and 8 external thats gone on through the timeline.

9 So, that brings us to our resolution approach. And, 10 if we start here, first of all I will point out that this 11 is all conducted within our Corrective Action Program. We 12 have condition reports for every one of these issues thats 13 been identified, in many cases multiple condition reports.

14 So, the first task that were currently undertaking 15 as we speak is consolidating, eliminating the redundant 16 condition reports, so were not answering the same question 17 twice; consolidating similar calculations or similar 18 condition reports, so when we do things such as revise a 19 calculation, we have all the issues combined together so we 20 can do it once.

21 So, we take those condition reports and we ask 22 ourselves, first of all, is there a potential impact on 23 safety function or operability. Either one of those, a yes 24 to either one of those questions is going to require that 25 we resolve the issue and run the ground prior to deciding MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

80 1 how to act.

2 So, once we now group to the balance of the number 3 of conditions or issues that are potentially safety 4 significant, we look at how many of those have been 5 previously identified under the Design Basis Validation 6 Program. And, what that does for us is provides us a more 7 efficient way of looking at the extended condition, because 8 weve already looked at 29 systems under Design Basis 9 Validation; and we verify the issues, these open items, on 10 each of those 29 systems, we can revalidate the answer, 11 make sure we answer completely and correctly, if its 12 already been answered. We follow through to make sure it 13 gets answered and is still open.

14 Then, there is going to be a number of issues that 15 will fall out as a no to that question to say, its 16 important to safety or operability, it was not identified 17 by Design Basis Validation. For those, we have to do an 18 extended condition in our Corrective Action Program, and 19 apply those to all the important systems of the plant to 20 make sure its not a generic issue.

21 Thats essentially our methodology were going to be 22 using here to try to make sure that the issues that we know 23 of are solved, and that the issues that we know that have 24 application to the other systems are also applied 25 appropriately.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

81 1 So, this is an approach that weve developed. We 2 believe its based on sound engineering principles. We 3 have our new engineering principles expectations manual, 4 which I believe youre all familiar with. We talked about 5 that in the past.

6 Were applying that new level of rigor and concern 7 to the open items, not simply accepting the answer that was 8 provided maybe five years ago. And well take a look at 9 every one of those again, its important prior to restart, 10 and make sure weve answered it right.

11 MS. LIPA: So, John, are you 12 talking about the 275 open items?

13 MR. GRABNER: Im talking about 14 the 275, plus even were going to look at the ones already 15 closed, because there are some of those that we found, in 16 fact a couple that were identified by Martys group, where 17 we didnt bottom line if we would have answered the 18 question using todays standards more completely, we would 19 have found the issue and addressed the problem then.

20 MS. LIPA: And have those 21 open items been put to Corrective Action Program?

22 MR. GRABNER: The 275 open items 23 have been rolled into the Corrective Action Program, so 24 they are tracked in the Corrective Action Program.

25 MS. LIPA: Thank you.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

82 1 MR. COLLINS: John, I have a few 2 questions if I could, right before summary. If you want to 3 cover them during the wrap up, please defer me to that.

4 Who owns the design basis of the plant? Is it 5 system engineers, is it design engineers?

6 MR. GRABNER: Design engineers.

7 MR. COLLINS: Design engineers.

8 And you have a design engineer for each system or how do 9 you specify that?

10 MR. GRABNER: We have, thats 11 one thing were looking on. Thats one of the deficiencies 12 actually were tracing. We dont have design engineers 13 assigned specifically to systems. Thats one of the items 14 were looking at in terms of realigning.

15 So, we do get that assignment, so we can feel more 16 ownership directly. Were really broken down 17 discipline-wise, and its not clear always system by system 18 where that applies.

19 MR. COLLINS: Okay. So, thats 20 a go forward approach you need to establish?

21 MR. GRABNER: Thats correct.

22 MR. COLLINS: How is the system 23 now used? Do you have a readily available automated means 24 for engineers to access the design basis of the plant and 25 to search for the latest calcs? Do you intend to have MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

83 1 one, or how are you going to transform this information 2 when you have confidence in it, do you have a process that 3 can be applied?

4 MR. MYERS: Let Jim answer 5 that question. Do you have an answer?

6 MR. POWERS: Ill jump in on 7 that. At the Perry Plant, we used an electronic design 8 basis information system called Atlas, that we worked with 9 General Electric to extract much of their design basis 10 information out of San Jose, and get it electronically 11 assessible to the engineers. We even scanned in some of 12 the old memos from the original system designers out 13 there. Its electronically available on desktops.

14 Sort the information by accident and, you know, 15 design parameters and functions for the systems, anyway you 16 want to slice it and dice it. It helps the 5059 writers do 17 their jobs and the reviewers and the modification 18 preparers. And so, we had success with it there, and were 19 going to bring it to both this plant and our Beaver Valley 20 Plant. Thats ongoing now. Thats one of the improvements 21 that wed like to kick that into gear and get that up, 22 because we do want to capture this information to be sure.

23 What were concerned about is the demographics of 24 the plant through the technical staff, and there is going 25 to be turnover occurring over probably the next five to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

84 1 seven years, retirement starts. Bringing in younger staff 2 now, entry level staff. We need to turn over that 3 knowledge. And we see the tools to capture this thing are 4 critical to us to continue improving that.

5 MR. COLLINS: Thank you.

6 MR. MYERS: We said something 7 yesterday about having the right tools. Its painful going 8 back here and looking for the information, were still 9 looking for information through the records and 10 everything. And its there a lot of times, but with the 11 technology we have, it should be a lot easier to attain.

12 And we put that in place.

13 We really designed the system at our Perry Plant 14 when I was there. And our engineers raved about it all the 15 time, our system and design, but we didnt bring it over 16 here. Were going to do that.

17 MR. COLLINS: A comment would be 18 that this multiple purpose, reestablishing and confirming 19 the design basis of the plant, of course, one is the 20 existing safety basis of the plant in a confirmatory way, 21 is always important. The other is ensuring that in a 22 go-forward sense rather than a legacy sense that that 23 information is available to be applied. And I think thats 24 where youre going perhaps with your future initiatives.

25 Im curious about the 97-5054F there. You indicated MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

85 1 there are some legacies having to do with quality to those 2 findings. Are you in to broaden the scope of your response 3 to 97-5054F letter? Are there any lessons learned that you 4 found of your sampling that are causing you to question the 5 implementation of the actions from that 5054?

6 MR. POWERS: No, we havent 7 really looked at that yet, specifically. The areas that 8 John described, there is a follow through on the action 9 items, Design Basis Validation that was done. We know we 10 need to follow through on that.

11 There was also the four topical areas that we talked 12 about, that were excluded because recent external QA 13 assessment, self-assessment and inspection activities. It 14 was felt at that time those programs were in good 15 standing.

16 Now what were finding as we go through this, were 17 taking some discrepancies that have been identified and 18 were in the process of looking at that to see whats the 19 significance of them, whats the validity of them, and then 20 well go through the process of looking at the 5054F and 21 see if there is any lessons learned to report.

22 MR. COLLINS: Thank you.

23 MR. MENDIOLA: I have a process 24 question. Your two decision blocks here, Resolution 25 Approach. Who does those, who makes those decisions and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

86 1 what process are you using or is there any special process 2 they use to make those decisions?

3 MR. GRABNER: That would be, 4 thats, when we set up to do that, we set up system teams 5 that consist of system engineer, a design engineer who is 6 assigned, as well as technically some contract help to both 7 the teams. They are doing this resolution process on a 8 system by system basis. They will hone the resolution of 9 all those open items and will ensure theyre done to their 10 satisfaction.

11 They will be the ones also who will be doing the 12 screening and they will be documenting the results of that 13 as part of the Corrective Action Program as every one of 14 these issues again is in the Corrective Action Program.

15 So, there should be trail, an explanation of that decision 16 and have that documented in the Corrective Action Program.

17 MR. MYERS: Our program all 18 along has been set up so were using our CR process, now 19 we roadmap this. We have our CR going through a screen 20 committee that Mr. Schrauder chairs, and they classify them 21 as restart and nonrestart in that committee.

22 MR. MENDIOLA: So, then I would 23 understand that when the decision, for example, that first 24 decision is made, whether it affects safety or functional 25 operability, the answer is no, so then the CR is resolved MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

87 1 and it shows up in front of this committee to, if you will, 2 quality check the decision. And subsequently, the same 3 thing would occur on the second decision block depending on 4 its outcome.

5 MR. GRABNER: Thats correct.

6 It may not, well, I have to take it back. First of all, 7 this population of CRs have already been identified by the 8 Restart Station Review Board as being restart related.

9 Well take those. The ones we feel do not have to be 10 resolved prior to restart, because it goes through one of 11 those blocks, well have to take that back to that board 12 with an explanation to present all of those items and 13 explain the rationale for concluding these are not restart 14 items.

15 MR. MENDIOLA: So, there is a 16 little bit involved, obviously, there is a process and what 17 you just discussed there, some standardization in the 18 approach, closing on each of these, if you will, the same 19 as you go through the entire list of design related CRs?

20 MR. GRABNER: Thats correct.

21 MR. HOPKINS: I have a specific 22 question. Are you reviewing the control room envelope?

23 Is that possibly expanded largely inappropriately or not, 24 or that part of your design basis review?

25 MR. POWERS: We are not looking MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

88 1 at the size of the control room envelope. I dont know 2 whether were looking at that from a technical perspective 3 in terms of any size of it; however, we are looking at the 4 control room habitability and leakage testing.

5 MR. JOHNSON: All right.

6 MR. GRABNER: I dont recall any 7 issues we have identified specifically raise questions 8 regarding the envelope itself.

9 MR. HOPKINS: But youre looking 10 at the building?

11 MR. POWERS: Yes.

12 MR. MYERS: Are you ready for 13 summary?

14 MR. GRABNER: In summary, we 15 believe we have developed a process that will let us 16 efficiently and effectively go through, screen the issues 17 we have, resolve them down, the issues, and resolve those 18 with the highest priority of those which have a potential 19 to affect function. And, again, the teams of people that 20 will be performing this work are the system engineers, 21 design engineers, and complimented by contractor staff.

22 MR. MYERS: I would like to 23 take a couple moments to talk about our Management issues, 24 and Human Performance Action Plan that we have.

25 Next slide.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

89 1 As you remember our issues, we broke all the issues 2 down, took several reports, and we broke everything down 3 there in the areas of Nuclear Safety Culture, Standards and 4 Decision-Making, Oversight and Assessment, 5 Programs/Corrective Action and Management/Personal 6 Development.

7 Were not, Im not going to talk much about the 8 programs today. I think that Steve did a good job of 9 oversight. Im going to give you some of the actions taken 10 in some of the other areas.

11 Some significant improvement initiatives weve 12 completed so far is we completed a training program for 13 Safety Conscious Work Environment at our plant. We went 14 through 210 of the 250 site supervisors, from contractors 15 and our supervisors. So, weve done that.

16 That training program is about four hours long. A 17 major commitment of time. Its designed to ensure that our 18 supervisors are very proactive with our personnel when they 19 address concerns. So, that is our desire. Our supervisors 20 to go from reactive to proactive when it comes to personnel 21 concerns.

22 Additionally, weve completed 98 RHR assessments of 23 our FENOC personnel. What is that? Well, thats an 24 industrial psychologist, that we said, some of our other 25 means, were going to go baseline our staff. Weve MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

90 1 completed that.

2 What we committed to, what it means, is we would 3 look at behaviors and do an assessment of each individual 4 thats a supervisor in Operations, Engineering, Work 5 Management, Chemistry/Radiation Protection, Quality 6 Assessment. Im here to tell you, weve gone above that.

7 Weve interviewed all of our managers. Weve done 8 our directors and our FENOC executives. And were now 9 moving to the directors at our other plants.

10 Next slide.

11 MR. GROBE: Lew, before you 12 go on, could you give me a sense of what attributes, 13 performance attributes you examined in these assessments?

14 MR. MYERS: Certainly. You 15 know, we looked at each of our people, and you know, we 16 went back and used our Leadership in Action guidelines that 17 we assess people by. Everything is broken down into 18 safety, teamwork, accountability and ownership, which is 19 sort of the FENOC values. Then we have criteria on each 20 one of the values were looking for to make sure that 21 people understand our standards just as well.

22 You know, we have some issues there that we got to 23 go deal with. Probably the whole population, ten areas of 24 issues that we want to go deal with. But, there was some 25 good things that really came out of that review, and the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

91 1 people that are at our plant are there because they want to 2 be there because its a good place to work in the area, 3 and they feel like its a good asset to the area, and good 4 place to work. Theyre pretty vocal about that.

5 We learned a lot from that review, and weve already 6 had a round table review with our senior management team, 7 myself.

8 How long was it, Randy; five, six hours? Went over 9 each individual, and action plans going forward.

10 From a Safety Conscious Work Environment, weve 11 brought Randy in. Hes developed a plan already. That 12 plan has been communicated and distributed to all of our 13 employees. We completed the case study training of 864 14 employees. And, one of the things that we really stressed 15 is, we sit down as senior management team and developed a 16 set of standards that we want our employees to hold us to, 17 and we shared those with each and every employee; and Ill 18 talk some about the results in a moment.

19 We revised our Leadership in Action Training already 20 too, based on reviews weve done of this issue. And weve 21 already went out and trained, using new Leadership in 22 Action models, 17 new supervisor personnel.

23 And additionally, our Chief Operating -- Chief 24 Executive Officer of our company, Pete Burg. Hes been to 25 our plant four times since May. But, last Tuesday, he came MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

92 1 down and spent all day at the plant and met with two 2 different sessions; one at 7:00 at night, one in the 3 afternoon, with our employees, an All-Hands Meeting.

4 Really talking about doing the job right, safety the first 5 time, and setting the standards that he expects at our 6 nuclear plant. And, for him to come down four times and 7 spend the entire day like he did last week is pretty 8 exceptional.

9 Our four Cs meetings. I really enjoyed those 10 meetings.

11 MR. GROBE: Just a question 12 on that last slide, Lew.

13 MR. MYERS: Yes?

14 MR. GROBE: The Safety 15 Conscious Work Environment area. Without going into detail 16 or specifics on any issues that are brought up through 17 either our Allegation Program or your Safety Conscious Work 18 Environment Program, do you have any insights gained from 19 the types of issues and the number of issues that are being 20 brought to our attention as compared to the number and 21 types of issues that are being brought to your attention 22 through your, I cant remember what you call it; common 23 goal?

24 MR. MYERS: You know, many 25 times I would give you, there was some questions about, you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

93 1 know, the confidentiality of our program, and the 2 willingness of people to use that. What weve done is we 3 brought Randy in. Randy established his plan already.

4 And one of the things, another thing weve done is 5 put independent investigators in there, so were not going 6 back to the line organization doing investigations. And 7 what were trying to do there is really show our employees 8 this is a very confidential program. And go from a 9 situation where its a reactive program, Randy is trying to 10 set a program where were actually meeting, all the 11 meetings have been more proactive, to go out and look for 12 concerns now. And I think were going to find that very 13 successful.

14 Randy, youre out there now. Do you have any 15 comments there?

16 MR. HUEY: I would just 17 reinforce.

18 MR. MYERS: You can go up to 19 the speaker there.

20 MS. FRESCH: Would you state 21 your name?

22 MR. HUEY: Im Randy Huey. I 23 would just reinforce what Lew said, that we are discouraged 24 by the fact that the amount of use, traffic we have with 25 the existing offensive program does not, is not ahead of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

94 1 what were seeing coming in from the NRC. So, combine that 2 with the survey that we did, showed a less than acceptable 3 confidence on the part of the employees at the plant in the 4 existing program.

5 We are in the process of putting in place this month 6 an expanded employee concerns process that will have 7 essentially two major elements that we think will improve 8 that, the circumstances of the employees lack of 9 confidence.

10 One, is that it will be more independent, instead of 11 being more or less a brokerage for employee concerns where 12 an employee comes to the ombudsman, and then that concern 13 is just directly turned over to the responsible 14 supervisor.

15 Well be doing more independent investigations 16 because we will have an in-house, either in-house 17 independent investigator or we will have the resource of an 18 outside investigator to investigate more cases. Weve 19 only opened ten cases this year. I expect to see that turn 20 around with our, with our new ECP.

21 And, the second feature of it will be to meet with 22 employee groups when we get this thing, get procedures in 23 place.

24 In addition to publicizing it in the various 25 communications journals, like a newsletter, were going to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

95 1 go out and meet with, across the board with, at the plant, 2 with groups of employees to explain and get a little bit of 3 dialogue on it, on what the capabilities of this program 4 are going to be and encourage people to use it.

5 And, I think that my experience has been that most 6 employee concerns involve failures and breakdowns in 7 communications. So, were going to have emphasis on not 8 only the ECP personnel, talking to the employees, but 9 getting their supervisors to be demonstrating on a 10 continuing basis that employees concerns are a top 11 priority and they will not be discouraged.

12 MR. GROBE: Thank you.

13 MR. MYERS: Go ahead.

14 MR. GROBE: Just a question, 15 Randy, now that youre standing in front of the microphone; 16 two questions. When do you anticipate having this new more 17 robust program in place?

18 MR. HUEY: Procedure is being 19 worked on today. I expect to have procedures in place by 20 the end of December, and have, start these meetings that I 21 mentioned by the end of the year.

22 MR. GROBE: I would suggest 23 that you think about not waiting until you have the new 24 procedure in place to start making a one-to-one interface; 25 one-on-one interface.

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

96 1 MR. HUEY: Well, in that 2 regard, Im attending some of these Four C Meetings, and 3 based on your comment, maybe Ill start attending more too.

4 Lew has deferred to me to talk with the employees about, 5 during those meet meetings about what this new process is 6 going to do, and Ive had some feedback following those 7 meetings by employees saying that what they hear is good, 8 and theyll be interested in seeing how its implemented.

9 MR. MYERS: Were not sitting 10 back. I mean, were actually getting out and were acting 11 on it.

12 MR. COLLINS: Thank you, Lew.

13 Randy, one question if I may, first grievance. Will 14 this program be subject to independent auditing by QA or 15 some oversight towards its effectiveness? Have you gotten 16 that far yet in its implementation and how you would define 17 success for its effectiveness?

18 MR. LOEHLEIN: We havent 19 discussed whether QA would provide that or someone else 20 would. I dont know if Bill knows the answer to that, 21 Pearce?

22 MR. PEARCE: Im sure that we 23 will provide some oversight of the program once we get the 24 program established, but as of yet, we havent got the 25 program in place, so then we can look at how were going MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

97 1 to provide oversight, but Im sure the answer is going to 2 be positive to your question, we will provide some level of 3 oversight.

4 MR. COLLINS: So, you would, I 5 guess in a more general way, my question would be 6 appropriate to say, that you would provide all of the 7 normal processes and checks and balances for an onsight or 8 Licensee program, including performance measures and 9 success material and oversight?

10 MR. PEARCE: That is correct.

11 MR. COLLINS: Training, those 12 types of things?

13 MR. PEARCE: That is correct.

14 MR. COLLINS: Thank you.

15 MR. GROBE: Randy, dont go 16 away yet. I think -- I appreciate your emphasis that the 17 first line of resolution of employee concerns is the 18 relationship between employee and their supervisor, and the 19 next line is going to the managers, next line would be 20 going to you, and then if theyre still not satisfied or at 21 any time they can certainly come to us.

22 The thing that concerns me and has a sense of, 23 causes me to have a sense of urgency in this issue, is I 24 believe that were at a rate of about 3 to 1 allegations 25 coming to the NRC as what are coming to you, and that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

98 1 should be substantially in the other direction.

2 So, I think you need to take some pretty prompt 3 action to regain the confidence of your staff, that in 4 those several opportunities they have to resolve concerns 5 within house, certainly they always have the opportunity to 6 come to us.

7 MR. HUEY: I agree.

8 MR. MYERS: Okay. One of the 9 things weve been doing, each one of the Four Cs Meeting, 10 Ive now met with 280 of our employees. Randy sat in these 11 meetings. And theyre two, two and a half hours each, so 12 theyre pretty timely. Very valuable information comes out 13 of the meetings.

14 What weve done consistently is we have stressed the 15 atmosphere that we want a Safety Conscious Work Environment 16 at each meeting. Theres 280 employees at that plant that 17 Ive personally assured them that thats the atmosphere we 18 want. We want them to bring up issues. And, its okay to 19 come to me, to Randy or whoever, but if they have an issue, 20 we at least want to handle it in a professional matter.

21 And, weve done that at each and every meeting.

22 And the other thing I think we demonstrated is the 23 action we take at each meeting, I think actions at each 24 meeting, we publicize the actions that weve taken in the 25 newsletter. So, I think the employees are receiving MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

99 1 positive feedback. And in fact, Pete Burg was here last 2 week. They commented to him, they find these meetings very 3 valuable.

4 Next area is Town Hall Meetings. There has been 18 5 Town Hall Meetings with our employees to-date. We find 6 those positive also.

7 Do you have any comments, Randy?

8 MR. FAST: Its more like the 9 fireside chat, an opportunity to get with our folks, give 10 them opportunity to bring up things going on at the 11 station. Typically get questions about rumors that come 12 up. Try to create an atmosphere where people can come in, 13 feel like theyre being informed, but as well bring up 14 issues. We get a wide array of questions from our folks, 15 and were most able to resolve those on the spot.

16 We try to build confidence, just another medium to 17 communicate confidence with our employees that we can 18 connect with them and provide them timely updates on things 19 that are going on in the station.

20 MR. STEVENS: We also videotape 21 them and use the videotape for those on the back shift that 22 are not able to attend Town Meetings, so they can hear and 23 recognize whats being discussed.

24 MR. COLLINS: Lew, having heard 25 where you are, if this is an appropriate time, maybe I can MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

100 1 ask a question about an ongoing program.

2 MR. MYERS: Okay.

3 MR. COLLINS: If we were to take 4 a step back and look at the purpose of Safety Conscious 5 Work Environment and the promotion of appropriate safety 6 culture, including a program that captures concerns, and 7 what might cause those types of concerns; clearly, the 8 status of the plant as it exists today with a lot of work, 9 a number of contractors, some highly unusual work, and 10 schedule being important, has all the trappings, if you 11 will, of probably worse case environment, and perhaps more 12 appropriately a significant challenge for Safety Conscious 13 Work Environment Program.

14 Given that your program is admittedly being started 15 up, being established, what do you have in place today; 16 what confidence do you have today that youre not missing 17 opportunities for these types of challenges? Once the 18 plant progresses and restart decision is appropriately made 19 by FirstEnergy, and the NRC takes it into consideration, 20 that embarkment will be a little perhaps benign than what 21 it takes to get there.

22 MR. MYERS: Well, the 23 strategy that I have, and we have, is become proactive 24 through this environment on looking for issues. I can tell 25 you that in each one of the Four Cs Meetings I have, we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

101 1 have been proactive, and theyve given me some issues both 2 in public and in private. I wont say any of them are 3 safety issues right now.

4 Weve also brought Randy in, and he has a lot of 5 experience in this area, to be independent. He reports to 6 Bill. And we put a team of independent investigators with 7 Randy already, and weve communicated that to our site 8 personnel.

9 So, once again, the approach has been a strategy, 10 rather than sitting back in the office and being active and 11 proactive, out in the people looking for issues; whether 12 they be, whether it be contractors, our own employees.

13 Initially, you know, when we trained all the 14 supervisors for, we just spent four hours with each 15 supervisor, and both contractors and our own supervisor, 16 make sure that they were sensitive to addressing employee 17 issues. So, the strategy is to really be proactive in this 18 area.

19 Are we successful yet? I think its quite too 20 early to tell, but we have a lot of things in place 21 already.

22 MR. COLLINS: Do you have 23 majors in place with this interim program? Majors of 24 effectiveness, have you defined success of the program?

25 MR. MYERS: I dont think so, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

102 1 no.

2 Were working that out. Do we have that yet, Bill?

3 MR. PEARCE: No, we dont. Let 4 me say something.

5 I think what weve worked on, what we prioritized 6 first was this; its more important that if there are 7 issues out there, that our folks feel that theyre able to 8 raise the issue. So, thats what we prioritize is the 9 first thing. Thats why we did the Safety Conscious Work 10 Environment training with the supervisors and made sure 11 that there is no, that there is no harassment or 12 intimidation issues and that kind of thing.

13 So, that, you know, what we really want is safety 14 issues to make sure we get those captured. And whether 15 its captured in your program or our program is, I guess, 16 somewhat of its more painful to collect it in your 17 program, but as long as they get captured, thats the main 18 issue in what we focused on first.

19 And we brought Randy in and the group of contractors 20 in to do independent investigation, because when we did the 21 survey, one of the issues as you might remember that was 22 brought up in the survey, was the fact that the management 23 when somebody brought up an issue, before they do it, the 24 management folks were hearing about it and going and doing 25 an investigation.

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103 1 Well, we countered that by doing independent 2 investigations. Thats the idea, to make sure we didnt 3 lose issues, safety issues that needed to be brought 4 forward. And so, I think that was the right priority to 5 take on the issues.

6 Now, were moving out from that issue and putting in 7 place a longer term program to make sure that we, within 8 our own house that we collect the majority of the issues 9 and get them investigated in-house. So, thats kind of the 10 sequence that were going through.

11 And weve got more things we havent talked about.

12 Weve got a team put together that looks at all the 13 employment issues that were having; HR issues, and all 14 that kind of thing. And so were collecting and being 15 proactive, as Lew talked about. The Four Cs Meetings are 16 a part of it. So, there is a wide range of issues were 17 dealing with there.

18 But I think that more accurately portrays overall 19 what were doing, rather than just focus on the, you know, 20 which issues are going where.

21 MR. MYERS: The actions were 22 taking are a direct reflection of our survey. Were taking 23 actions that solve issues addressed in our survey. You 24 think thats fair?

25 MR. PEARCE: Yes.

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104 1 MR. MYERS: The first thing I 2 want to go to is first line supervisors, and thats where 3 we thought the issue was, and thats what we attacked 4 first. Okay?

5 Another thing weve done is we have implemented our 6 Management Observation Program that we brought over from 7 our Perry Plant and Beaver Valley Plant. Its 8 computerized, and Ive seen Randy use it personally. Its, 9 we think its an excellent program.

10 And, I think you like it.

11 But, it allows us to take issues and review issues 12 from an implementation standpoint. Weve talked to, we 13 dont think were at the point yet where we can make any 14 determination. We have five hundred observations now. We 15 know that weve seen some issues with supervisors were not 16 coaching and counseling like they should in the field.

17 So, its too early to tell. The problem is 18 implementing, and well give you more information on that.

19 MR. GROBE: Lew, five hundred 20 observations is a lot of observations and if I remember 21 your program correctly, youve got a number of attributes 22 that are listed that people are evaluating in the field.

23 Have you done any tracking or trending of these 24 issues, and do you have any performance indicators or 25 evaluation of criteria for success?

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105 1 MR. MYERS: Yes. And, you 2 know, a month or so ago I went through the various areas, 3 and picked out performance areas that I think we need to go 4 look at. I havent used any of that yet. And Id probably 5 be willing to tell you about that at the next meeting. I 6 think its just too new.

7 MR. GROBE: I would be 8 interested once you get these performance indicators and 9 measures in place in receiving them, as well as the other 10 performance indicators on productivity.

11 MR. MYERS: You like to hear 12 that at the next meeting, well give you information on 13 that.

14 MR. GROBE: That would be 15 great.

16 MR. MYERS: Okay. Another 17 thing is were physically scheduling two of our managers 18 for observation. So, were building the managers into the 19 schedule for these observations.

20 I would like to talk a few minutes about a case 21 study, to tell you I think how that went. That was a 22 major, I dont want to use the word production for us, but 23 a major happening.

24 The case study, which took an entire day with 25 everyone on site. Took an entire day. All the managers, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

106 1 including Mr. Saunders, Gary Leidich, were involved in 2 this, what we call a case study. It was four hours long.

3 It really was not just a case study. It was, first 4 of all, we went over and over what happened in this event.

5 What are the issues that we saw in the event, the 6 timeline.

7 We then went to each department. We didnt do this 8 with multiple groups; we did it with individual groups.

9 Then, we took each group and we looked at how they could 10 have helped prevent this event. How they could 11 contribute.

12 We looked at their standards, talked about the 13 problems, and we talked about the standards of senior 14 management that we just rolled out. And each and every 15 group and each and every person took tests. Passing was 16 80. We completed 864 people.

17 We received feedback from 76 percent of the people 18 that took the test, and the course. The overall ratings 19 were that 96 percent of the people said it met 20 expectations. One hundred percent -- 15 percent indicated 21 that it was one hundred percent successful in their minds.

22 In fact, comments were, why didnt we do it quicker. Well, 23 the reason was, we werent ready quicker.

24 The population across the board was pretty uniform.

25 You look at craft versus noncraft. And if you look at MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

107 1 technical factors versus nontechnical factors. Uniform 2 population.

3 Heres some of the things we got out of that.

4 First, to be successful in the future, they liked what we 5 did here, but we have to walk our talk and be effective.

6 This is just a beginning. We must follow through.

7 Its nice we gave them all this stuff, but we have to 8 follow through at every level.

9 They talked about Bob Saunders coming down and 10 spending his day with them was very positive, as well as 11 Gary Leidich.

12 It was important that we get this out to everyone, 13 but we should have done sooner.

14 And the overall, we think that the feedback received 15 about the presenters, were they did an excellent job on the 16 presentation. And, the presentation consisted of a 17 videotape, so we have that timeline consistent with each 18 department. Then the departmental managers, you know, 19 reflecting how this affects their own department.

20 Another area of concern was managements production 21 versus quality and safety priorities. What were trying to 22 do, what were trying to prioritize, I know Randy has too, 23 is to demonstrate that were willing to stop and take the 24 time we need to address problems.

25 We have done that on the feedwater heater.

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108 1 Weve done that on containment, containment closure, 2 which we talked about awhile ago.

3 Fuel movement stop work.

4 The polar crane work we stopped. We did two weeks 5 there. We took a hard two-week hit in or schedule there.

6 And finally the other day we had problems with 7 moving RCP motors, and we didnt go forward with that until 8 we felt confident that everyone was safe and reliable to 9 move those motors. Thats the message were trying to put 10 out.

11 Theres still some skepticism in our groups about 12 raising issues and fear of reprisal. And we talked about 13 that. Thats what weve got Randy working on. Thats the 14 atmosphere. I can say here that I want to create an 15 atmosphere where people bring up and tell us their issues.

16 And if we can create that atmosphere, well be successful.

17 On the test results --

18 MR. GROBE: Lew, could I do a 19 quick time check? I would like to try to end this portion 20 of the meeting at five, so we have time for the public.

21 Youve got two additional sections. Mike was going to talk 22 about -- two Mikes. Mike Ross was going to talk about 23 Operations, Mike Stevens was going to talk about Schedule.

24 MR. MYERS: I suggest we skip 25 Schedule.

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109 1 MR. GROBE: Well, I think 2 thats pretty self-explanatory, so I think folks can get 3 that and youve talked about it already. I definitely want 4 to get to Operations.

5 MR. MYERS: Okay. Ill 6 finish up now.

7 MR. GROBE: Good.

8 MR. MYERS: From a case study 9 standpoint, the average grade was 93 percent. We had one 10 failure of a past criteria, 80 percent. We remediated that 11 person immediately. And 45 percent of the people made up 12 on the test.

13 So, I feel like I can look the public and you in the 14 eyes now and tell you that we have rebaselined and clearly 15 documented. We understand our departmental standards. We 16 understand with each group how this event happened, and 17 were ready to go forward.

18 With that, I would like to have Mike talk to you 19 about Operations Excellence Plan.

20 MR. ROSS: Good afternoon.

21 My name is Mike Ross and Im the Manager of Operations 22 Effectiveness at Davis-Besse.

23 A little about my background. Ive worked in 24 commercial nuclear power for more than 30 years.

25 Additionally, I spent time in the United States Navy in the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

110 1 Nuclear Submarine Program and also had a tour of duty 2 assigned to Naval Reactors Branch.

3 I have held management positions as Operations 4 Manager, Maintenance Manager and Plant Manager at the Three 5 Mile Island Nuclear Facility for more than 20 years. All 6 but four of my commercial experience years have been in 7 nuclear power plant environment. Two of those four years I 8 spent as a instructor at a test facility, and two years I 9 spent in the corporate office of the Excelon MidAtlantic 10 Regional Group. I held a senior reactor license for more 11 than 25 years.

12 Next slide.

13 I was brought to Davis-Besse to assess the 14 operations staff, and prepare for restart. And above all, 15 assure after restart they had a sustainable level of 16 performance.

17 The RHR group has completed an assessment, as Lew 18 said, for all operations supervisory personnel.

19 Additionally, the first line supervisors were completed.

20 RHR find no or found no individuals that they deemed did 21 not have the ability to go forth and represent the FENOC 22 standards and values, that were really clearly interested 23 in having in the Operations Department.

24 Several personnel, and thats very key personnel, 25 were deemed to be in need of some additional improvement MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

111 1 actions, and those plans are under way now for those 2 individuals.

3 My assessment of the Operations staff, actually 4 centered on the leadership team in Operations. As they 5 will definitely set the standards for health and progress 6 in operation as we set for restart and after restart.

7 Weve got a fairly new team of people involved in 8 operations; the Plant Manager, Operations Manager, 9 Operations Superintendent, and Operations Support 10 Superintendent have all been new within this year. Thats 11 since January of this year.

12 Two shift managers are relatively new to their 13 position; one has been new this year and the other within 14 two years.

15 Plant Manager, while new to Davis-Besse, has many 16 years of nuclear experience and he is a proven manager.

17 The Operations Manager has been a licensed operator 18 at Davis-Besse and has experience in maintenance. He has 19 very good standards and excellent people skills.

20 The Operations Superintendent has an active, I said 21 active SRO license, and is a very knowledgeable and 22 respected long time employee of Davis-Besse.

23 The Operations Support Superintendent also holds an 24 active SRO license, and hes very knowledgeable and is 25 actually sought out for his expertise and source of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

112 1 knowledge and logical approach to doing business.

2 The Shift Managers are all very experienced, and are 3 respected and supported by their groups. This is a very 4 experienced operation leadership team as well. They have 5 good standards and values; and the Operations, Operations 6 Staff is very supportive of this team. Theyre very happy 7 to have this group leading them, and they have confidence 8 that this group will position them in the right direction.

9 Next slide.

10 Recognizing that needed improvements were necessary 11 in Operations, the Leadership Team led by the Shift 12 Managers putting together a Leadership Plan. Purpose of 13 the plan was to prepare operations for restart and ensure a 14 sustained high level after restart.

15 Next slide.

16 Vision plan is very important and underlines the 17 attributes necessary for an operations group. I want to go 18 through that rather slowly.

19 The Operations Department is recognized as the lead 20 organization at Davis-Besse. Very important item.

21 Continuous improvement is expected, demonstrated and 22 embraced by operations personnel.

23 Operations ownership of equipment deficiencies, 24 nuclear fuel performance and plant chemistry is strong.

25 Operation management communicates, demonstrates and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

113 1 reinforces desired performance standards.

2 Shift management consistently demonstrates 3 leadership.

4 And, Im losing my voice, so bear with me. Next 5 slide. A little bit about the plan.

6 MR. THOMAS: Mike, could I ask 7 a quick question. In your opinion, what is the status of 8 bullet one?

9 MR. ROSS: I didnt hear the 10 question.

11 MR. THOMAS: I said, in your 12 opinion, what is the status of bullet one?

13 MR. ROSS: I think there is 14 some -- the question, whats the status of bullet one. I 15 think there is some work to be done there. I think this 16 has been internalized in Operations and theyre trying to 17 step forward and were working on bringing the staff 18 together to ensure, or our agency step forward. Its not 19 done yet, working.

20 MR. THOMAS: Okay.

21 MR. GROBE: Along that same 22 line, is the Operations Organization Root Cause, Im not 23 sure exactly what the title is of that document; is that 24 completed?

25 MR. FAST: Its in review.

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114 1 The draft has been produced. Its in review. In fact, the 2 author is in the audience.

3 MR. GROBE: I received a copy 4 of the first version of that document, and then that was 5 pulled back, then you initiated a second effort. That 6 activity is curbed within the last eight weeks. Could you 7 give me your assessment of the first effort and what that 8 tells you about operations leadership and what changes have 9 occurred in the last eight weeks?

10 MR. FAST: The first, the 11 first report that was put out was focused more internally, 12 rather than looking at the organizational impact. The 13 human dynamics associated with operations leadership have 14 degraded over the years. And the quality of the root cause 15 we did was, I would say its superficial.

16 We dug deeper, weve gotten more feedback from 17 across the organization. It substantiates more direct 18 linkage to our 000891, thats the root cause of our 19 management performance for our head case.

20 So, we see direct linkage. So, this is, Ill say, a 21 full body stout report that focuses on the human dynamics 22 associated with the organization. Its a much improved 23 version and I believe it will be more successful in really 24 identifying what the root cause is and the actions that we 25 will be taking going forward.

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115 1 MR. GROBE: Randy, when do 2 you think were going to be seeing that?

3 MR. FAST: Soon. Let me 4 just, let me comment. One of the things that Lew did, is 5 Steve was the team lead from day one. We will take all the 6 time necessary to ensure we have a quality product. And 7 what we have in the review and comment cycle right now are 8 some individual facts that need to be either substantiated, 9 or they need to be withdrawn. And that was some of the 10 comment that we had for this past weekend. I read that 11 report in great detail.

12 And, we want to make sure that all of the facts that 13 are provided are substantiated. And so, thats a level of 14 effort thats going on right now. But, Im going to allow 15 that team all the time necessary to ensure we get a quality 16 product.

17 MR. GROBE: I appreciate 18 that. I wouldnt suggest that you do anything otherwise.

19 The case study, are all of the issues that are 20 captured in your draft report on Root Cause for Operations, 21 were they captured in the case study? Because it seemed 22 to be case study was already completed, you hadnt yet 23 completed this root cause report.

24 MR. FAST: I would say there 25 are some additional elements, more organizational elements, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

116 1 outside involvement, the focus on operational standards; 2 those will be addressed in more detail that really talk 3 about organizationally how do we provide support and 4 acknowledgement to the operations leadership role. That 5 will be evaluated more in depth.

6 And I believe as well there will be some corrective 7 actions that extend organizationally to ensure that we have 8 the right level support of the operations staff.

9 MR. MYERS: Okay, Mike.

10 MR. THOMAS: One more question 11 on that slide, please. This is open to anyone, whoever, 12 probably Randy or Lew, if you could answer this question.

13 Im real interested in bullet one. And Im curious what 14 your assessment is of the, the other organizations on site; 15 are they embracing that vision as well?

16 MR. FAST: Let me tell you.

17 You know, were not the lead right now. Whats happened 18 is, I will use the term that there has been a dilution over 19 time of operations having that leadership responsibility.

20 Its a two-fold responsibility. Organizationally, we need 21 to focus on that, but also we need to stand up and take 22 responsibility. That delusion dilution has occurred over many 23 years, just as the head degradation occurred over many 24 years.

25 So, the reality is, thats not a step chain. We can MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

117 1 not stand up and say Ops is now the leader of the site and 2 everybody will rally around. Operations has to demonstrate 3 their leadership and demand that, and the rest of the 4 organization has to respond to that. Will that happen 5 overnight? The answer is absolutely not. That will be our 6 focus.

7 MR. MYERS: We know of 8 several times, were, just sit down and try to take the 9 lead on something, its not had the proper response. So, 10 we have to have senior management support, and youll see 11 us doing that.

12 MR. THOMAS: Okay.

13 MR. GROBE: Your supervisor 14 observations and your manager observations, this seems like 15 an area that should be fairly easy to develop some 16 performance indicators, track progress, and I would be 17 interested in that.

18 MR. ROSS: Okay.

19 Next slide.

20 As to the content of the plan, Ill give you an idea 21 of the size. There are 67 items total, 42 for restart, 22 and benchmarking, training and other improvements.

23 Next slide.

24 One of the real important items within the plan was 25 benchmarking. We took benchmarking very serious and we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

118 1 benchmarked with teams. The teams were led either by the 2 Operations Manager or one of the Operating Superintendents; 3 and they had an SRO Shift Manager, Equipment Operator, a 4 Reactor Operator and Staff person on them.

5 We benchmarked three facilities. We purposely 6 picked three operators of multiple units, Excelon, Intergy 7 and Progress Energy. From that three, we compiled the 8 improvements we wanted to make, and as of now we have 9 written new standards, expectations and how they align with 10 the reactor.

11 Shift Manager has been moved out of the work control 12 center, so he be more visible and involved in other plant 13 activities and interact with the people more readily.

14 As to training thats in that plan, we did complete 15 a case study training. That was very well received in the 16 Operations. Conducted an INPO first line supervisors 17 course. That course was aimed at the sharpening the human 18 performance and prevention tools of the supervisor, and 19 sharpening his general skills.

20 Boric acid program requirements were completed and 21 made part of the core program for operations.

22 Safety Conscious Work Environment training for all 23 supervisory personnel is completed.

24 We did additional training on Operability 25 Determinations.

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119 1 Next slide.

2 One of the things the staff did do at Davis-Besse is 3 they kept the operator Requal Program intact. Presently 4 the Requal Program is at the stage where theyre taking 5 tests in simulator, taking written tests and taking job 6 performance tests. That will give us a good idea where we 7 are in skills and how well were prepared for restart.

8 As part of our planning for restart, included in our 9 Leadership Plan, there is additional training scheduled.

10 The standards and expectations that we just talked about 11 are brand new. There will be training going on with 12 written tests.

13 Decision-making training, restart test plan training 14 with a simulator evaluation of that training, plant 15 modifications, licensed operator responsibility training 16 and ombudsman responsibilities and procedures.

17 As to other activities, just looking a little bit 18 ahead, an additional INPO assist visit will be scheduled 19 for sometime in April. The thrust of that INPO assist 20 visit will be check and evaluation. I want to take the 21 word evaluation out there. Its an assist visit. Theyll 22 give us an assist visit of our simulator performance.

23 Additionally, theyll do a check in the field of our 24 standards and how well were going on.

25 That concludes what I was going to say about the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

120 1 Operations Leadership Plan.

2 MS. LIPA: Okay, thank you.

3 Do you have any closing remarks, Lew?

4 MR. MYERS: Well, we had some 5 Desired Outcomes today. That was to demonstrate that were 6 making progress.

7 I think that the reactor vessel head, were ready 8 for testing there. The containment sump, were done. We 9 removed the old covering and putting new bolts in now, and 10 have the sump being manufactured. I think the painting is 11 going well, and paint removal.

12 Decon efforts also are doing well in containment.

13 Weve taken one reactor coolant pump apart, already removed 14 the rotating assembly. Working on the second as we speak.

15 System readiness reviews are being completed.

16 We status on some of the actions that weve taken; 17 very timely, time consuming and timely; and Management 18 Human Performance Plan.

19 We are getting ready now to prepare for what we call 20 deep drain. Thats a place that a plant very seldom goes, 21 couple times in the lifetime of the plant. There is no 22 fuel in the vessel now. So, were going to drain it down 23 below the nozzles. And its tight; its 11 inches, or 24 something.

25 And, anyway, we would drain it down, we will go down MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

121 1 and take, work on like 76 valves, 79 valves. The first 2 valve on all Reactor Coolant System. So, it gives us an 3 opportunity to do some serious maintenance on those 4 valves.

5 It would have been easy for us not to do a lot of 6 the maintenance were doing, but we decided to go change 7 some things out. Were repacking the valves. We want to 8 bring the plant up to quality condition. So, were 9 preparing for that deep drain now.

10 After that, well be preparing for fuel load, 11 pressurization of the containment, pressurization of the 12 reactor to ensure we have good integrity.

13 Thats all I have. Thank you.

14 MS. LIPA: Okay, thanks, 15 Lew.

16 Ill check to see if there is anybody who has some 17 comments, but I want to thank you for the information that 18 you shared today, and we then look forward to the next 19 public meeting, which will be December 10th at Camp Perry.

20 We talked already today about a couple of things we 21 would like to hear about next time; performance indicators 22 on management observations, for one. And then, root class, 23 talk about root cause. Hopefully that will be ready, but 24 as Randy said, it will be done when its done properly.

25 But, were eager to see that document.

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122 1 And then, do you have any comments?

2 MR. GROBE: Any final 3 questions?

4 Yeah, I just wanted to summarize the meeting. It 5 was a long meeting, and I appreciate the candor and all the 6 information that was shared. Christine and Marty opened 7 the meeting summarizing the results of some recent 8 inspections. And several of those inspections have had 9 positive results; and, by and large, went a great distance 10 toward closure of some of those issues; reactor head, 11 containment restoration, the issues that Christine 12 discussed earlier and presented in our newsletter, Martys 13 inspection, and to a certain extent the resident 14 inspections identified some issues that require some 15 continuing work.

16 I think weve talked about most of the issues today 17 that I think are several of the key issues that youre 18 actively working on, but warrant a great deal of attention 19 on your part. One is the lower reactor pressurized 20 penetrations, resolving that issue; and were looking 21 forward to the meeting on the 26th to discuss that 22 further.

23 Second, is the design issues and getting assessment 24 of those, and as soon as youre ready to talk about that 25 were ready to meet.

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123 1 The third is Safety Conscious Work Environment, and 2 Human Performance. In this area, our inspection on 3 Management/Human Performance is currently suspended. Were 4 evaluating how to proceed on that. You have initiated a 5 significant amount of activity in that area, but there is 6 still activity that is yet to be completed; and thats an 7 area that were particularly focusing on.

8 And then, of course, the final one we didnt talk 9 about today is just getting work done, what I refer to as 10 bulk work. But I think the outcome is that there is 11 progress. Our inspections are confirming in several areas 12 the accuracy of work thats been done. In some areas, we 13 still have work to do. Okay. Thanks a lot.

14 Why dont we take a very short break?

15 MR. MYERS: Could I give you 16 one other thing?

17 MR. GROBE: Sure.

18 MR. MYERS: We had a question 19 earlier about Management/Human Performance. To ensure that 20 were moving foward and making progress that we wanted to, 21 Ive got three of our RRP members coming in during the next 22 month at different times; and what theyre doing is getting 23 out and meeting with our employees. We have a lot of 24 confidence that theyre independent and then giving us 25 feedback.

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124 1 MR. GROBE: Okay, good.

2 MR. MYERS: Thank you.

3 MR. GROBE: Thank you.

4 Lets take a very short break and reconvene in three 5 minutes. So, stand up and then sit down. Dont walk out.

6 (Off the record.)

7 MS. LIPA: Well, this is 8 the, we finished the formal meeting with FirstEnergy.

9 Before we adjourn the rest of the meeting, we want to offer 10 an opportunity for members of the public or anybody who has 11 a comment to come up and talk to us. And what we would 12 like to do is start with local members of the public first 13 and then speaking clearly into the microphone for the 14 transcription, and then give us your comment or question 15 and try to take three to five minutes.

16 MR. GROBE: Let me comment.

17 Before we get started, we have a very special person here 18 today, Sam Collins. Sam is a Director of the Office of 19 Nuclear Reactor Regulation in Headquarters. He has overall 20 responsibility for the safety of nuclear power plants in 21 the United States. And I think Sam wants to make, did I 22 make that too big?

23 MR. COLLINS: You made it too 24 big.

25 MR. GROBE: Sam wants to make MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

125 1 a couple of comments, and then we can take public 2 comments.

3 MR. COLLINS: Im not that 4 special, but I am here. My name is Sam Collins. Im the 5 Director of the Office of Nuclear Reactor Regulation. And, 6 before we get started, I wanted to acknowledge that people 7 in Oak Harbor and Catawba Island had an occasion over the 8 weekend to, of course, be affected by tornados. So, we 9 know this probably isnt on the top of your mind as far as 10 this meeting is concerned for many of those local 11 individuals. So, we want to acknowledge that.

12 Having said that, we are available. Im here 13 particularly to address the decision-making and the 14 processes that went on in regards to the reactor vessel 15 head and the degradation of the head, and the continuation 16 of the operation of the unit beyond December 31st.

17 So, to the best of my ability, and recognizing I 18 dont have my technical staff with me that usually keeps me 19 out of trouble when we get into those type of details, I 20 can acknowledge the processes that we use and the 21 decision-making process, so I will be available for that.

22 Thank you, Jack.

23 MR. GROBE: Were now open 24 for any questions. As Christine indicated, we prefer to 25 limit it to 3 to 5 minutes. And we would like to start MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

126 1 with any local, public representatives or members of the 2 local community.

3 HOWARD WHITCOMB: My name is Howard 4 Whitcomb.

5 Welcome, Mr. Collins.

6 I think there is a young gentleman, I dont see him 7 here, or this afternoon; I think might want to ask some 8 questions. I hope youre here for the evening session.

9 MR. GROBE: Howard, pull the 10 microphone down a little bit. There you go.

11 HOWARD WHITCOMB: In keeping with 12 the spirit of being short, I have a very, well, I have a 13 comment, quick comment. Mr. Ross, I think youre right on 14 target with your vision statements. I think you have a 15 magnificent challenge ahead of you to get Engineering to 16 subscribe to the notion that Operations is the boss.

17 Thats been a problem at Davis-Besse for as long as I know 18 Davis-Besse people, and I think thats, its going to be a 19 big hurdle to overcome.

20 In looking at the FirstEnergy, I guess it was the 21 handout on July 16th, in looking at the Restart Overview 22 Panel, which was specifically page 5 of that handout, I had 23 a question. There is a Mr. Jack Martin, who is identified 24 as the Company Nuclear Review Board Representative. I 25 guess hes on the Restart Overview Panel.

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127 1 My question is, is this the same Jack Martin who was 2 the Regional Administrator in Region III of the Nuclear 3 Regulatory Commission in the mid 90s?

4 MR. GROBE: I think I can 5 answer that question. That is correct. Jack retired from 6 the Nuclear Regulatory Commission a number of years ago, 7 and is providing services to the industry. There is also 8 other former members of the Nuclear Regulatory Commission; 9 Mr. Joe Callan, the former Executive Director for 10 Operations. I guess thats it, Jack and Joe are the only 11 two former NRC executives.

12 HOWARD WHITCOMB: Okay. Thats all 13 I needed to know. Thank you, Jack.

14 MR. GROBE: Thanks.

15 Other questions or comments from the local 16 community?

17 Okay. I would like to open it up to the floor 18 then. Any questions or comments from anyone else?

19 AMY RYDER: Amy Ryder. Like 20 the truck.

21 I have just a couple of quick questions. My first 22 is regarding the testing of the reactor looking for the 23 leakage at the bottom. It raises a little bit of a red 24 flag that they want to put fuel in the reactor. They want 25 to put fuel in the reactor when they test it. And it seems MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

128 1 like there is an alternative way to do it.

2 Does the NRC have the authority to tell them, no, 3 you cant put fuel in the reactor?

4 MR. GROBE: What alternative 5 were you thinking of?

6 AMY RYDER: Well --

7 MR. COLLINS: Without fuel.

8 AMY RYDER: Without fuel.

9 MR. GROBE: Thanks, Sam. You 10 clarified that.

11 There is two issues that precipitate the need to 12 have the fuel in the reactor. The way, the way you heat 13 up, if youre not using the fuel, which youre not going to 14 use the fuel, the power from the fuel to heat up, is with 15 pump heat, and you have to run the pumps; and that 16 circulates a huge amount of water through the reactor; on 17 the order of probably half a million pounds, something of 18 that order. A lot of water.

19 That causes two concerns. One is that if youre 20 not, if you dont have the equipment inside the reactor 21 vessel itself appropriately supported, it can move around 22 and damage itself. And, the fuel provides some of that 23 structural support for the equipment inside the reactor.

24 The second issue, I think that this issue was 25 discussed by FirstEnergy a little bit, but just to make MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

129 1 sure youre clear. The pumps would damage themselves if 2 theyre not pushing against enough force. Theyre going to 3 be circulating water. And theyre designed to circulate 4 that water with the fuel in there. And that fuel 5 represents a significant burden to push water through.

6 So, if the fuel isnt there, the pumps would go into 7 whats called runout. What that means is, they run too 8 fast and they can damage themselves. So, FirstEnergy has 9 concluded that they need to have the fuel in the vessel to 10 do the test.

11 Now, that precipitates a number of different 12 things. If youre going to heat up the reactor to normal 13 operating temperature and pressure with the fuel in the 14 reactor vessel itself, you are entering one of the modes in 15 the technical specifications that require a variety of 16 systems, safety systems to be in service.

17 So, there is a large number of work activities that 18 have to occur to put all those safety systems, including 19 the containment structure itself back in service and other 20 emergency systems, including the sump; the sump has to be 21 operable; various emergency systems have to be operably in 22 service, containment has to be in place.

23 So, there is a lot of work that has to occur to make 24 sure that doing the test in that configuration is in 25 accordance with our requirements and done safely.

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130 1 In addition to that, there is a rule, thats 2 10-CR-50.65A4. And what that specifically talks about is 3 whenever you do something unusual, maintenance activities, 4 testing activities, that you assess the risk of that work, 5 and then if it is risky work, take compensatory actions.

6 And that is also something that the company would need to 7 consider, whether this is an unusually risk significant 8 activity and what type of compensatory actions.

9 So, we would be looking at all of these various 10 valuations that they would have to do, as well as we would 11 be thoroughly inspecting the Return to Service and 12 Containment Integrated Leak Test would have to be completed 13 before that would occur.

14 AMY RYDER: When you asked the 15 question this afternoon, why do you want to put the fuel in 16 the reactor when you heat it up. And their response, 17 simplified, was that certain equipment doesnt exist 18 anymore, so we have to put the fuel in versus equipment 19 that is no longer produced.

20 MR. GROBE: Yeah. They 21 referred to hot functional testing. Back when plants were 22 being built in the United States, one of the first, excuse 23 me, one of the final tests thats done before a plant is 24 put into operation is whats referred to as hot functional 25 testing. As you construct equipment, you test it as you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

131 1 build it, and then final tests are integrated tests that 2 are done at normal temperature and pressure.

3 There was a special piece of equipment, for lack of 4 a better term, an orifice that provided that back 5 pressure. And that equipment just doesnt exist anymore.

6 So that the pumps would not damage themselves.

7 AMY RYDER: Cant they just 8 make them?

9 MR. GROBE: There is two 10 issues. You can probably manufacture a piece of equipment, 11 but installing it is not, as an operating reactor, reactor 12 vessel would react from the neutrons from the fuel. So, 13 its not the kind of thing that is reasonable to do. And, 14 Im not sure its unreasonable to put fuel to run this 15 test. I think its something that insistent with test tech 16 specification, the operating license, and we would provide 17 appropriate oversight inspection.

18 AMY RYDER: Id probably never 19 put the fuel back in.

20 MR. GROBE: I understand.

21 AMY RYDER: But lets skip 22 that.

23 My next question is for Sam Collins. What was the 24 reasoning behind you not issuing, allowing to operate until 25 February 16th without allowing the shutdown to take place?

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132 1 MR. COLLINS: Thanks for the 2 question. Im going to start a little bit in time, if I 3 may, and kind of march through the process.

4 AMY RYDER: Okay.

5 MR. COLLINS: The NRC issued a 6 bulletin back in 2001, its Bulletin 2001-01. And what we 7 did with that bulletin was alert licensees to the 8 phenomenon of the cracking of the reactor vessel head. It 9 had been observed for a period of time, particularly in the 10 French plants. They were the first plants to discover it.

11 They replaced their heads.

12 And, subsequent to the initial type of cracking, 13 which we recall axial, which is straight up and down, there 14 was a secondary type of cracking, which is circumferential, 15 which goes around. And the circumferential cracking was of 16 more concern, because it was not initially well understood 17 for crack rules rates and how and when it happened.

18 We knew plants had been inspecting for cracks since 19 the 90s, quite awhile, including Davis-Besse. And what we 20 challenged the plants with in the Bulletin 01-01 was to 21 indicate to the NRC why those inspections had been 22 satisfactory. And, if the inspections had not been 23 satisfactory, we wanted them to shut down before December 24 31st in order to perform what we determined would be an 25 appropriate type of inspection.

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133 1 So, we were receiving information from all 60 some 2 odd pressurized water reactors in the United States, but 3 there was a group of plants that were what we call high 4 susceptibility plants, particularly the B and W type of 5 reactors of which Davis-Besse is one, that we were more 6 sensitive to the information and had them on an accelerated 7 schedule, if you will.

8 The information that Davis-Besse submitted to us in 9 December, the initial response to the bulletin, we 10 determined was unsatisfactory. It did not contain enough 11 information for us to make a determination that the 12 inspections that had been performed prior to that time were 13 satisfactory, given the new circumferential cracking 14 phenomenon.

15 So, we had a series of meetings with them. I 16 believe there were, if I have this right, five letters back 17 and forth; there were perhaps four public meetings that 18 went on with the Licensee to glean information and to try 19 to have a better understanding of the plant.

20 The plant was originally to run until the end of 21 March. That was when the next outage would be for them.

22 The normal shutdown, if you will, for them to do the 23 inspection.

24 AMY RYDER: Right.

25 MR. COLLINS: Some plants did MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

134 1 shut down to do the inspection. Some plants provided us 2 enough information to provide them to run until the next 3 cycle. Davis-Besse was kind of in between.

4 On, if I get my dates right, on November 28th or so, 5 the final meeting with the Licensee, where they provided us 6 information to substantiate their inspection scope, 7 including compensatory measures that they would take in the 8 event that they did have a problem, that had leaks or 9 catastrophic failure. I can go into those, but those are 10 probably detail at this point.

11 The staff then made two types of determinations.

12 Made one of, do we believe that the past inspections are 13 adequate. And based on the information that was provided 14 to us, we did. We did not know about the erosion on the 15 head. Had we known of the erosion on the head, clearly we 16 would have made a different decision.

17 Did we have opportunities to do, to review the head 18 and to discover the erosion? The answer to that is yes.

19 We missed opportunities to do that. But at that point, we 20 made the decision, we did not know.

21 AMY RYDER: I think the 22 confusion is, the decision that you were ultimately 23 responsible for differed from what your staff had decided.

24 That your staff had decided that those inspections were not 25 adequate, that they needed to shut down by December 31st to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

135 1 look for those cracks. And, on the 28th, FirstEnergy made 2 their final plea, and it was ultimately your decision to 3 allow them to continue to reopen, and that differed from 4 the staff that had done all the investigative work.

5 MR. COLLINS: Yeah, I understand 6 why you say that, based on the information as provided from 7 the FOIA, of course, Freedom of Information Act, process of 8 information action, emails, letters, notes; and perhaps 9 what you may have read or may have heard. Let me try to 10 clarify that if I can.

11 The staff made a decision at the end of November, 12 and the staff consensus at that point was that it was 13 acceptable for Davis-Besse to operate halfway through their 14 normal cycle, as it extended beyond December 31st. So, 15 they ran to the middle of February.

16 The staff was specifically asked if they had any 17 reservations about that? And the answer was no. There 18 were two individuals who indicated that they would have 19 made a different decision, but that they would go along 20 with the consensus and they didnt believe there was an 21 immediate safety concern.

22 I asked the manager, who was at that meeting, if I 23 could talk to those two individuals. And I personally 24 talked to those two individuals to ensure that they in fact 25 did not have any safety concerns with the continuation of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

136 1 the operations of the Plant. And they expressed to me that 2 they did not.

3 They had different views, if you will, of some of 4 the technical information. They might have done 5 calculations differently, but they did not disagree with 6 the consensus of the staff.

7 So, in fact, what the emails depict is a process 8 thats building towards a resolution. And, we had, and I 9 tried to find out if we issued it today, I apologize I 10 dont have the answer. But there is a safety evaluation 11 that were issuing to Davis-Besse that will outline that 12 process and the basis of that process, and that information 13 will be contained in it. If its not issued today, it will 14 be issued by the end of the week.

15 AMY RYDER: Did Mr. Saunders 16 make a plea to you to postpone the shutdown order based on 17 public perception based on fuel and financial markets?

18 MR. COLLINS: To the extent that 19 you express it, no.

20 AMY RYDER: Okay.

21 MR. COLLINS: However, as in any 22 decision that has to be made, there are a number of 23 ramifications of those decisions, which Ive discussed.

24 The NRC makes decisions based on safety. They have four 25 performance goals; maintain safety, we want to do our work MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

137 1 efficiently and effectively, we want to reduce unnecessary 2 burden, when its appropriate, and we want to have public 3 confidence to the extent that its public confidence in a 4 strong credible regulator. Not nuclear power, but nuclear 5 regulator.

6 This was strictly a maintain safety decision. What 7 was discussed over lengths of time was when it is 8 appropriate for the plant to shut down for an outage, and 9 what are the ramifications of the different dates as they 10 were proposed. Clearly, I wont speak for the Licensee, 11 but clearly I think the Licensee, everything being equal, 12 would like to run to the end of their cycle. The NRC had a 13 question of, tell us why your inspections are adequate and 14 why they support operation beyond December 31st.

15 For this plant, the staff determined that it was 16 acceptable to run beyond December 31st. So, the question 17 comes, what is the most opportune time for the plant to 18 shut down, given that the end of the cycle, which is, 19 perhaps increases the probability of cracking, although 20 minuscule, youre talking 45 days of extra operation, but 21 if you could minimize that, you want to.

22 So, the discussion became, when is the new fuel 23 available? When will the modification packages for the 24 outage, as originally proposed for the end of March, be 25 finalized, so that they could be performed on a sooner MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

138 1 schedule?

2 What is the amount of mainline exposure, which is a 3 real maintained safety issue, because there are 4 individuals, many in this community, who work at the plant, 5 who have to be concerned about the limits of radiation 6 exposure; and if jobs unplanned, if equipment isnt ready, 7 if training isnt done, extra exposure can be increased.

8 And then there is the issue of the accelerated 9 inspection itself, which the determination being that the 10 plant did need to do different types of inspection. When 11 is the training of individuals available? When is the 12 equipment available? And what is the impact of all of 13 this?

14 Those are resources, is time, people and money. Is 15 that financial, yes? Does it deal with maintaining 16 safety, yes. So, the optimum date that was determined to 17 be, halfway between, if you will, December 3st, and the end 18 of the cycle. That was the earliest date by which we 19 determined the risk of doing an outage on a short term 20 basis is negated by the risk of continuing to operate.

21 And, FirstEnergy would be prepared to perform an efficient 22 and effective outage.

23 So, in a long-winded way, and I kind of excuse 24 myself for that, if you will.

25 AMY RYDER: Okay.

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139 1 MR. COLLINS: That kind of gives 2 you background of how the finances or how the schedule of 3 resources were discussed in the manner that it takes to 4 support accelerated outage.

5 AMY RYDER: I appreciate what 6 youre saying, but from somebody who lives in Ohio, and I 7 believe I could be -- I live in Cleveland -- I believe I 8 could be affected if there was an accident at this 9 facility. It does seem a little arbitrary. And I would 10 rather the NRC err much more on the side of caution, than 11 to base these decisions on a cost-benefit analysis, because 12 thats the decisions that FirstEnergy has been making for 13 quite sometime now and we see what happened when they do 14 that, so.

15 MR. COLLINS: And thats an 16 appropriate comment.

17 If I can, the cost-benefit analysis is only gone to 18 after the maintain safety question is answered. And we 19 have processes that provide for that.

20 You mentioned the order perhaps, in your first 21 question, if I could just answer that also, take the 22 opportunity.

23 We had prepared an order for Davis-Besse, like we 24 would with any plant that we felt it was necessary to shut 25 down in order to do the inspections on the maintain safety MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

140 1 basis. That order was predicated on establishing the 2 condition by which we felt like there was an undue hazard, 3 if you will, where a plant either did not meet the license 4 or we had conclusive evidence, thats kind of a legal term, 5 but conclusive evidence that there was a condition that 6 placed the public and environment in an undue hazard.

7 That order was, in fact, available to be issued if 8 it was necessary. And it went through me, went through the 9 Executive Director, it went to the Commission for 10 Information, the Commission of Technical Assistance were 11 briefed on it. I am the individual who would have signed 12 it out.

13 Based on discussions with FirstEnergy, if the NRC 14 had decided that the plant needed to shut down on December 15 31st, I had the commitment of Mr. Saunders that he would 16 shut the plant down. And we would not have to issue an 17 order, although we had it available; if we came to that 18 decision that it was necessary to maintain safety. We did 19 not come to that decision, based on the consensus of the 20 staff, so the order was not necessary to issue.

21 AMY RYDER: Wasnt there also 22 a press release written along with the order?

23 MR. COLLINS: Yes. Any time--

24 thats a good observation. Any time that we propose a 25 significant regulatory action, we have what we call a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

141 1 communication plan that goes with it. Thats not only a 2 press release, but its notification of elected officials, 3 notification of Congress; its all of those areas that help 4 us in the public confidence.

5 AMY RYDER: Thank you.

6 JAMES DOUGLAS: I have not met you 7 before, sir. Im one of the neighbors. I live down the 8 street from Davis-Besse. And Im also a retired chemical 9 engineer. Okay.

10 MS. FRESCH: Excuse me, sir.

11 Could you state your name, please?

12 JAMES DOUGLAS: My name is James 13 T. Douglas. I live on Duff-Washa Road. Im a retired 14 plant engineer and chemical engineer by trade. Ive got a 15 couple of questions.

16 How does Davis-Besse justify their gross negligence 17 of not inspecting the reactor and letting it get so far, as 18 paper thin stainless steel? Now, how do they justify 19 this?

20 This to me is absolutely, I could almost vomit. I 21 have run the biggest acid plant in the world. Now, let me 22 tell you, I cant get by that statement, that question. I 23 cant get by it.

24 MR. GROBE: I dont want to 25 speak for the company, but what I can share with you is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

142 1 they met with us on August 15th, and submitted what they 2 believed was their root cause, and there was no 3 justification or, I guess there was no justification of how 4 it would have been acceptable for this to have occurred.

5 There was a lot of reasons that it occurred. No 6 justification. And --

7 JAMES DOUGLAS: Okay.

8 MR. GROBE: And theyre in 9 the process of trying to address those reasons. We call 10 them root causes. And were in the process --

11 JAMES DOUGLAS: Well, they have a 12 horrible problem. They have the biggest plant problem I 13 could ever imagine. Theyre all brand new, the employees.

14 The other guys were kicked out by the Board of Directors.

15 They have the Board of Directors looking over their 16 shoulders at them, every single action that they take.

17 Their employees, and all of the hourly employees 18 that worked under them, when they take a look at the head 19 of the vessel head, how badly it was deteriorated, they 20 have a reason to sit down and almost hate the supervisors 21 that sent them in to almost get them killed. Nobody can 22 justify in my mind how paper thin stainless steel can 23 retain two thousand pounds of pressure.

24 MR. GROBE: I understand your 25 comment. And I think its a very appropriate comment.

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143 1 Sam, do you want --

2 JAMES DOUGLAS: I mean, theyve 3 got pressure from the top. Theyve got pressure from the 4 bottom. And all I hear is gobbledygook from the stage.

5 MR. COLLINS: Mr. Douglas, let 6 me tell you what we know about the inspection of the head, 7 if that would be helpful for you. I dont think its going 8 to answer all of your questions, but it can perhaps give 9 you a perspective of the information that we have and what 10 the ongoing reviews are. If thats okay.

11 In response to the bulletin I mentioned earlier in 12 response to the young ladys question, FirstEnergy came and 13 presented to us their inspection plans that they had been 14 conducting over a period of time in response to the concern 15 about cracking.

16 There was Boron that was found on the head. Its 17 not unlike other plants when you look at it on the surface, 18 because of the mechanical leakage, not because of the 19 pressure primary leakage, but because of mechanical 20 leakage.

21 FirstEnergy presented to us their inspection plans, 22 if I have the dates right, its 96, 98 and 2000. I think 23 I have that correct. And, indicated to us that those 24 inspections had been complete; that the head had been 25 inspected; the head was relatively clean. But there was a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

144 1 group of control rod drive mechanisms, if I remember the 2 numbers, four or so, on the top area of the head that had 3 not been inspected.

4 JAMES DOUGLAS: Can I interrupt 5 you here for a second?

6 MR. COLLINS: Sure.

7 JAMES DOUGLAS: How can they 8 inspect in behind that big steel false wall without cutting 9 holes in it; and they never did that to take a look. Now, 10 when they did, what did they see? Enough crap and 11 corrosion to make you sick to your stomach.

12 MR. COLLINS: I dont disagree 13 with that at all. In fact, the NRC was at the head also.

14 We had an opportunity to identify this. We had inspectors 15 at the head. We observed the cleaning of the head. We 16 observed the in-service inspection of the head. And we 17 ourselves did not recognize the phenomenon that was going 18 on with the Boron.

19 We knew there was Boron there, but we didnt 20 understand completely the phenomenon, as chemical 21 engineering probably do, but we did not jump to that. That 22 was a missed opportunity.

23 JAMES DOUGLAS: What are they 24 going to do to prevent this in the future? They have a 25 bunch of mouse holes. Okay?

MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

145 1 MR. COLLINS: Mouse holes.

2 JAMES DOUGLAS: They cut a whole 3 bunch of mouse holes, they said, and it showed them on the 4 picture on the paper, all the way around the head, so they 5 can at least get in there with some kind of cameras and 6 look.

7 MR. COLLINS: There is a number 8 of issues, I guess, in a different form perhaps FirstEnergy 9 could speak for themselves. But, as a regulator, what we 10 understand; one, theyre replacing the head, of course.

11 So, there is a new head. There are additional inspection 12 requirements on the head itself. There is new types of 13 insulation on the head, so that the insulation could be 14 readily removed to provide for more --

15 JAMES DOUGLAS: Engineering never 16 stands still, sir.

17 MR. COLLINS: There is a new 18 type of mouse holes and doghouse, as you refer to them, 19 called access ports, which other plants have done, other 20 ports have modified that access house, so they could 21 visually see what was going on. Thats been done.

22 Theyre proposing also in addition to the more 23 frequent inspections new types of leak detection systems, 24 which Im not sure if you were here on the presentation, 25 but that would be a first of a kind in this country. They MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

146 1 are used in some plants in Europe to monitor the upper head 2 and the lower head for leakage.

3 Other plants are doing these types of things too.

4 There are a number of plants that are replacing their 5 reactor vessel heads. Eventually all plants that want to 6 continue to operate under this condition, not because of 7 Boron degradation, but because of the stress corrosion 8 cracking of the Alloy 600 stainless steel.

9 JAMES DOUGLAS: Let me present one 10 scenario to you. Let us say in 2007, they do not get their 11 new head. Okay? It gets delayed. All right?

12 MR. COLLINS: They have it now.

13 JAMES DOUGLAS: No, no, no, they 14 have the new one from Michigan now. They have another one 15 on order to be delivered 2007. Am I correct in that?

16 MR. GROBE: I believe thats 17 correct. Yeah.

18 JAMES DOUGLAS: Okay. Now, I 19 dont care if its a year off, I dont give a rats-- okay.

20 Let us say that they do not get this new head in 21 2007, because everybody in the nuclear industry is 22 absolutely shook up. Theyre all going to order new heads.

23 And only those that are real bad are going to get them, 24 because you can only make them so fast. Theyre 25 fantastically complicated. Okay? All right.

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147 1 At least Davis-Besse is going to be told, youre not 2 going to get your head, your new head, youre going to have 3 to go with the Michigan head. Okay?

4 MR. GROBE: Lets just make 5 sure the premises are correct. Its my understanding the 6 company plans on replacing their steam generators in 2012.

7 Is that it? And --

8 JAMES DOUGLAS: The whole thing?

9 MR. GROBE: The steam 10 generators. Its a component inside containment.

11 JAMES DOUGLAS: Oh, okay. All 12 right.

13 MR. GROBE: And at the same 14 time, they would be installing the redesigned head. That 15 head is on order, and I know of no reason it wouldnt be 16 received. Each plant has to order their head if they 17 desire a new one. And again --

18 JAMES DOUGLAS: Okay. Let me 19 finish my scenario just for a second, because my point is a 20 little different than you think.

21 MR. GROBE: Okay.

22 JAMES DOUGLAS: Suppose they dont 23 get the head. It gets delayed. They have to wait ten more 24 years to get the head. They have to make this head last, 25 because it will only be seven years old then. They at MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

148 1 least got 25 years or so out of the first head, okay. So, 2 they are not in dire need of that new head. Whereas, some 3 other plants might and the government may just take it away 4 from them. Okay.

5 Now, what can they do?

6 MR. GROBE: We issued a 7 bulletin, recently, which described augmented testing for 8 reactor pressure vessel heads. And, that testing is, 9 increases in its comprehensiveness, based on the age of the 10 head, and the amount of degradation that might be present 11 in the parts of the head.

12 Given the fact that the head that Davis-Besse is 13 installing is not used, its not been exposed to service 14 conditions, there are very well little inspection 15 requirements, other than visual inspections. As this head 16 gets older, based on our current bulletin to all 17 pressurized water reactors, there would be augmented 18 inspections requiring required nondestructive examination 19 of the penetrations.

20 JAMES DOUGLAS: Okay, my point is 21 this. If you assume and think about that they are not 22 going to get the head, and they have to make the head go, 23 wouldnt it be a marvelous scenario if they had a whole 24 series, thousands of photographs of all of the square 25 inches of weld on that head that they have? This is what MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

149 1 it looked like before our last, right after our last annual 2 refeuling. And, there it is, a nice smooth bald 3 head, clean as can be.

4 Wouldnt that make them, the Board of Directors 5 happy? Wouldnt that make John Q. Public happy? Wouldnt 6 that make their employees happy?

7 MR. COLLINS: Mr. Douglas, I 8 think youre on to something.

9 JAMES DOUGLAS: Well, I wish to 10 hell they would listen.

11 MR. COLLINS: Let me clarify a 12 few things and then agree with you.

13 The government, meaning me, doesnt decide whether 14 FirstEnergy procures a new head for Davis-Besse or not.

15 They have one on order. They can decide to trade it, which 16 they might and I agree with that.

17 JAMES DOUGLAS: Mr. Bush might 18 disagree with you, I dont know. (laughing) 19 MR. COLLINS: Well, Ill take 20 that.

21 This head is Alloy 600, so it is the old type of 22 material.

23 JAMES DOUGLAS: Yes, it is.

24 MR. COLLINS: The new heads are 25 a different type of alloy that are perhaps less MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

150 1 susceptible. The amount of age on the head is really 2 effective full power years. Its not the age in dog years, 3 so to speak, its the age that the plant has been operating 4 at full power. So, that will be tracked.

5 This plant will remain a high susceptibility plant, 6 so it will have enhanced inspections. Were also going 7 back as a lessons learned at the NRC to the National Codes 8 and Standards, and working with the National Codes and 9 Standards Group to create generic as-need type of standards 10 for the inspection of the head. Those will continue at 11 this plant for this type of head and potentially even for 12 the new upgraded type of head.

13 In fact, the inspections youve been asking for, 14 theyve been done.

15 JAMES DOUGLAS: Okay. Im very 16 happy about it. Im talking about a photographic 17 preventative maintenance program. They keep the 18 photographs on file; and any, they can of course leave it 19 open to the public, but certainly any of your people that 20 want to look at them, and they can see they are in good 21 shape; and this is exactly what we need is a good strong 22 head to operate that bloody machine.

23 MR. COLLINS: In addition to 24 that, its also what you would know as nondestructive 25 examination of the head, which means that they have done a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

151 1 mapping of the head and metallurgy. The heads are forged.

2 So, there are welds in the area of the CRDN I believe on 3 the old style heads, and thats susceptibility area, but 4 the majority of the head is forged.

5 JAMES DOUGLAS: But I sure wish as 6 long as you guys stayed, I sure wish you would think about 7 a good photographic PM program and keep it on file.

8 MR. MYERS: That will do it.

9 JAMES DOUGLAS: Everybody. It 10 would make everybody in the whole damned place happy as can 11 be. And I would sleep much better at night, Ill tell 12 you.

13 MR. COLLINS: Im hearing there 14 is a videotape that exists of the head.

15 JAMES DOUGLAS: I thank you for 16 staying and listening. Okay.

17 MR. COLLINS: Thank you for your 18 comments.

19 MR. MYERS: Well show it to 20 you, if you want to see it.

21 JAMES DOUGLAS: I would love to 22 see it.

23 MR. MYERS: Well show it to 24 you.

25 MR. COLLINS: Maybe we can link MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO

152 1 you up with Mr. Myers here.

2 MR. GROBE: When theyre 3 showing you the videotape of the head, why dont you ask 4 them also to bring the case study, and they can share that 5 with you too.

6 JAMES DOUGLAS: Ill listen to 7 your advice, thank you.

8 MR. GROBE: Any other 9 questions?

10 Okay. I think thats it. Well be back here at 11 7:00. If any of you want to rejoin us, youre welcome.

12 Thank you very much.

13 (Off the record.)

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153 1 CERTIFICATE 2 I, Marie B. Fresch, Registered Merit Reporter and 3 Notary Public in and for the State of Ohio, duly 4 commissioned and qualified therein, do hereby certify that 5 the foregoing is a true and correct transcript of the 6 proceedings as taken by me and that I was present during 7 all of said proceedings.

8 IN WITNESS WHEREOF, I have hereunto set my hand and 9 affixed my seal of office at Norwalk, Ohio, on this 23rd 10 day of November, 2002.

11 12 13 14 Marie B. Fresch, RMR 15 NOTARY PUBLIC, STATE OF OHIO 16 My Commission Expires 10-9-03.

17 18 19 20 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO