Presented by Dorian Conger General Manager Conger-Elsea, Inc Riveredge Parkway, Suite 740 Atlanta, GA Revised July 1, Human Performance, Root Cause, and Trending Conference Toronto, Canada Copyright 2014 Conger-Elsea, Inc. 1

Column 1 – Licensee Response (85) Column 2 – Regulatory Response (16) Column 3 – Degraded Cornerstone (2) Column 4 – Multiple/Repetitive Degraded Cornerstone (1) Column 5 – Unacceptable Performance Numbers as of Copyright 2014 Conger-Elsea, Inc. 2

Column 2 - $1 - $2 Million Column 3 - $10 - $20 Million Column 4 - $100 - $300 Million Copyright 2014 Conger-Elsea, Inc. 3

High Level of Effort in Cause Analysis CAP Low ? Col 1Col 2Col 3Col 4Col 5 * Problem Identification and Resolution Most frequently through a failed corrective action program (PI&R*) NRC expectation for a high quality, high performing CAP Copyright 2014 Conger-Elsea, Inc. 4

1.Extent of Condition 2.Extent of Cause 3.Safety Culture 4.Management System and Programmatic Considerations 5.Inadequate cause evaluations (depth and breadth ) Copyright 2014 Conger-Elsea, Inc. 5

Back to the drawing board – Redo the related event investigations  Establish new investigation teams for each of the events related to the  Train the investigation teams to meet the root cause analysis expectations defined in  Reinvestigate each of the events to the new expectations (with expert mentoring)  Prepare new root cause reports to the expected, elevated level of thoroughness required (with expert mentoring)  Train station managers to the elevated standards for root cause analysis and the proper behavioral expectations for Corrective Action Review Board members  CARB review and approve the upgraded root cause reports with related corrective actions (with expert mentoring)  Implement the corrective actions prior to the NRC inspection where possible  Develop a clear plan for implementing the remaining corrective actions, including provisions for funding and staffing (unresourced promises will not work) MAKE THE NECESSARY CHANGES TO THE CORRECTIVE ACTION PROGRAM TO MAKE THE UPGRADED PROCESS REPEATABLE. Copyright 2014 Conger-Elsea, Inc. 6

MOCK NRC Inspection – Establish a team of experts to perform a MOCK Inspection  NRC Executive experience  NRC Team Leader experience  NRC Inspector experience  Root Cause and Corrective Action Program expertise  Safety Culture expertise  Administrative support Copyright 2014 Conger-Elsea, Inc. 7

MOCK NRC Inspection – Perform the MOCK Inspection  Two weeks onsite  One week for report preparation  Deliver the report to the plant management  Provide advice and counsel to plant management regarding NRC expectations and the need to communicate importance to the entire plant staff Copyright 2014 Conger-Elsea, Inc. 8

Training – 1 week for elevated root cause team training 1 or 2 weeks for manager training Reinvestigate to the new standard and process – 6-9 weeks CARB review and comment integration – 1 week Implement corrective actions prior to the MOCK inspection – 4-5 weeks Conduct MOCK inspection and report – 3 weeks Implement corrective actions prior to the NRC inspection – 4-8 weeks Copyright 2014 Conger-Elsea, Inc. 9

1.Understanding the magnitude of the problem 2.Top management commitment and active participation 3.Resource commitment to properly perform the upgraded CAP process 4.Demonstrate commitment by implementing corrective actions 5.Demonstrate that the new CAP process can be repeated successfully 6.Demonstrate the upgraded processes and safety culture to the NRC inspection team Copyright 2014 Conger-Elsea, Inc. 10