1. Presented by Dorian Conger Conger-Elsea, Inc. 2000 Riveredge Parkway, Suite 740 Atlanta, GA 30328 800-875-8709 phone 770-926-8305 fax www.conger-elsea.com dorian.conger@conger-elsea.com 2009 Human Performance, Root Cause, and Trending Conference Del Ray Beach, FL Copyright 2014 Conger-Elsea, Inc. 1

2. PI&R is the most important program at the plant from a regulatory standpoint. A PI&R Substantive Crosscutting Area results from a failed Problem Identification and Resolution (PI&R) process; most frequently a failing or seriously flawed corrective action program. Copyright 2014 Conger-Elsea, Inc. 2

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

4. Column 1 – Licensee Response (86) Column 2 – Regulatory Response (15) - 95001 Column 3 – Degraded Cornerstone (2) - 95002 Column 4 – Multiple/Repetitive Degraded Cornerstone (1) - 95003 Column 5 – Unacceptable Performance Copyright 2014 Conger-Elsea, Inc. 4

5. Column 2 - $1 - $2 Million Column 3 - $10 - $20 Million Column 4 - $100 - $300 Million Copyright 2014 Conger-Elsea, Inc. 5

6. Back to the drawing board – Restructure the Corrective Action Program (CAP) MAKE THE NECESSARY CHANGES TO THE CORRECTIVE ACTION PROGRAM TO MAKE THE UPGRADED PROCESS REPEATABLE AND SUSTAINABLE.  Detailed evaluation of the existing program  Rewrite the governing procedures (near state-of-the-art; final changes to follow)  Train the plant staff, as appropriate:  Root Cause Analysts (Team Leaders)  Apparent Cause Analysts  Management Alignment training – Executives and Managers; Supervisors  Familiarize remaining plant staff  Conduct root cause evaluations using the new procedures with expert mentoring (two rounds recommended; may also include team leader skills training)  Train station executives and managers to the elevated standards for root cause analysis and the proper behavioral expectations for Corrective Action Review Board (CARB) members  CARB review and approve the upgraded root cause reports with related corrective actions (CARB observed and mentored/coached as needed)  Implement the new PI&R process with 2-4 months of run time Copyright 2014 Conger-Elsea, Inc. 6

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

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

9.  Evaluate current program –  2 weeks involving two or three senior consultants/principals  Rewrite CAP procedures –  4-6 weeks for the drafting and editing  2 weeks for the reviews and approvals  Training –  1 week - Root Cause Analysts (Team Leaders) - fully mentored; 5-day class  1 week - Apparent Cause Analysts – two 2-day class sessions  2 week - Management Alignment training – Executives and Managers (two 2-day sessions; Supervisors (two 4-hours sessions; plus video)  1 week - Familiarize remaining plant staff (all hands meetings as needed)  Conduct Cause Evaluations per the new standard and procedures –  8-12 weeks for conducting mentored cause evaluations to assure competence and readiness of the personnel to sustain the process  CARB review and approval of reports –  As completed  Implement the new process prior to the MOCK PI&R inspection –  Allow 2-4 months run time  Conduct MOCK inspection and report –  2 weeks for performing the on-site inspect ion and writing the report with recommendations Copyright 2014 Conger-Elsea, Inc. 9

10. 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 sustained without intervention 6.Ultimately, demonstrate the upgraded processes to an NRC inspection team to clear the PI&R Substantive Crosscutting Area Copyright 2014 Conger-Elsea, Inc. 10