ML022380419

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Return to Service Update August 20, 2002
ML022380419
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 08/20/2002
From: Myers L
FirstEnergy Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation
References
Download: ML022380419 (93)


Text

1 Davis-Besse Davis-Besse Nuclear Power Station Nuclear Power Station Return to Service Plan Update Return to Service Plan Update Return to Service Plan Update August 20, 2002

2 Lew Myers FENOC Chief Operating Officer Introduction Introduction

3 Desired Outcomes Desired Outcomes

  • Demonstrate the Integrated Schedule of activities is underway
  • Introduce actions to achieve and ensure sustained Management and Human Performance Excellence
  • Provide indicators that demonstrate our progress
  • Demonstrate increased standards by the Quality Oversight organization
  • Provide status of several Building Blocks

4 Reactor Head Reactor Head Resolution Plan Resolution Plan Bob Schrauder Bob Schrauder Program Compliance Program Compliance Plan Plan Jim Powers Jim Powers Containment Health Containment Health Assurance Plan Assurance Plan Randy Fast Randy Fast Restart Test Plan Restart Test Plan Randy Fast Randy Fast Management and Management and Human Performance Human Performance Excellence Plan Excellence Plan Lew Myers Lew Myers System Health System Health Assurance Plan Assurance Plan Jim Powers Jim Powers Restart Action Plan Restart Action Plan Lew Myers Lew Myers Restart Overview Restart Overview Panel Panel Return to Service Plan Return to Service Plan Basic Building Blocks Basic Building Blocks

5 Raising Standards Raising Standards

  • Restart Overview Panel has provided over 80 recommendations

- Expand the scope of the Containment Health Assurance Building Block

- Develop procedures to institutionalize standards and quality

- Place independent oversight on internal review boards and committees

- Benchmark specific plants for management practices and standards

- Strengthen Safety Conscious Work Environment

- Extend Root Cause to consider fleet-wide implications Management Root Cause Management Root Cause Results Results

6 VICE PRESIDENT -

FENOC OVERSIGHT L. William Pearce DAVIS-BESSE SITE ORGANIZATION FENOC CHIEF OPERATING OFFICER Lew W. Myers EXECUTIVE VICE PRESIDENT - FENOC Gary R. Leidich MANAGER - OPERATIONS EFFECTIVENESS Michael J. Ross VICE PRESIDENT -

NUCLEAR Lew W. Myers PLANT MANAGER J. Randel Fast DIRECTOR -

MAINTENANCE Michael J. Stevens DIRECTOR -

SUPPORT SERVICES Robert W. Schrauder DIRECTOR - NUCLEAR ENGINEERING James J. Powers, III MANAGER - CHEMISTRY AND RADIATION PROTECTION Robert W. Pell MANAGER - PLANT OPERATIONS Michael J. Roder MANAGER - NUCLEAR TRAINING William A. Mugge MANAGER -

MAINTENANCE Michael J. Roder MANAGER - WORK CONTROL C. David Nelson MANAGER -

OUTAGE MANAGEMENT C. David Nelson (acting)

MANAGER -

REGULATORY AFFAIRS Patrick J. McCloskey MANAGER -

PLANT ENGINEERING Joseph W. Rogers MANAGER - LEARNING ORGANIZATION David T. Gudger MANAGER -

QUALITY SERVICES Linda M. Dohrmann MANAGER - SECURITY Gary A. Skeel MANAGER -

HUMAN RESOURCES Deanna L. Haskins MANAGER -

DESIGN BASIS ENGINEERING John J. Grabnar SUPERVISOR - NUCLEAR ENGINEERING (SUPERVISOR - DESIGN JOINT ENGINEERING TEAM Glenn R. McIntyre Executive Assistant Leolla Mitchell Executive Assistant Rebecca S. Harsanje Executive Assistant Jacqueline Gezo Executive Assistant Yvonne M. Leidorf Executive Assistant Susan K. Ihnat Process Advisor Linda K. Griffith Executive Assistant Nora L.Flood

7 Management Root Cause Management Root Cause Lew Myers Chief Operating Officer

8 Management Root Cause Management Root Cause Results Results Introduction Introduction

  • Earlier Root Cause investigation and the NRC Augmented Inspection Team report both concluded that management had ineffectively implemented processes, and thus failed to detect and address plant problems as opportunities arose
  • The Root Cause Analysis Team was chartered to understand WHY, over a period of time, Davis-Besse personnel failed to identify corrosion of the Reactor Pressure Vessel Head

9 Root Causes Root Causes

  • Less than adequate nuclear safety focus

- Focus on production, combined with minimum actions to meet regulatory requirements, resulted in the acceptance of degraded conditions

  • Inadequate implementation of the Corrective Action Program
  • Failure to integrate and apply key industry information and site knowledge/experience; and to compare new information to baseline knowledge
  • Some steps in the Boric Acid Corrosion Control procedure were not followed Management Root Cause Management Root Cause Results Results

10 Contributing Causes Contributing Causes

  • Some decisions were made without considering the need for safety analysis
  • Corrective Action Program was not state-of-the-art Management Root Cause Management Root Cause Contributing Causes Contributing Causes

11 Extent of Condition Extent of Condition

  • Building Blocks designed to find and fix problems

- System Health Assurance Plan provides for rigorous system reviews

- Program Compliance Plan ensures programs meet industry high standards of performance

- Management and Human Performance Excellence Plan will ensure a strong and sustained safety focus Management Root Cause Management Root Cause Corrective Actions Corrective Actions

12

  • New FENOC Executive Team with high standards in place
  • New Senior Management Team with high standards in place at Davis-Besse
  • New Management Observation Program
  • Scheduled observations of plant activities
  • Case study training and re-baselining of standards
  • Reinforce Safety Conscious Work Environment Management Root Cause Management Root Cause Nuclear Safety Focus Corrective Actions Nuclear Safety Focus Corrective Actions

13

  • Staffed Organizational Effectiveness Experts
  • Four Cs Employee Meetings

- Compliments

- Communications

- Concerns

- Changes

  • Ownership for Excellence Review of all Managers and Directors
  • Competency Assessment of all Key Supervisors Management Root Cause Management Root Cause Nuclear Safety Focus Nuclear Safety Focus Corrective Actions Corrective Actions

14

  • Latent Issues Review by outside expert in progress
  • Criteria for categorizations is now effectively implemented
  • Existing, long-standing conditions are being reviewed as SCAQs
  • Corrective Action Review Board has been strengthened Management Root Cause Management Root Cause Corrective Action Program Corrective Actions Corrective Action Program Corrective Actions

15 Routinely perform assessments of categorization Repeat conditions are to be evaluated as SCAQ Require the use of formal cause determination techniques for root and basic cause evaluations to ensure analytical rigor is applied Define and implement training for cause evaluations Improve guidance on reviews of the effectiveness of corrective actions Implement an effective site-wide equipment trending program Management Root Cause Management Root Cause Corrective Action Program Corrective Actions Corrective Action Program Corrective Actions

16

  • Established FENOC hierarchy of documents for consistent standards for analysis of safety issues
  • Established Engineering Assessment Board to reinforce standards
  • Established a periodic system walkdown program
  • Established a periodic Engineering Program Review process
  • Re-baseline standards and expectations in each FENOC group Management Root Cause Management Root Cause Technical Rigor Corrective Actions Technical Rigor Corrective Actions

17

  • Established training to applicable Boric Acid inspectors
  • Reinforce standards and expectations for procedure compliance and the need for work-practice rigor Management Root Cause Management Root Cause Procedure Compliance Corrective Actions Procedure Compliance Corrective Actions

18

  • Implement Management Observation Program with weekly schedules (used at Beaver Valley and Perry)
  • Perform independent assessments of procedure compliance
  • Discuss procedure compliance regularly at morning meeting Management Root Cause Management Root Cause Procedure Compliance Corrective Actions Procedure Compliance Corrective Actions

19

  • Establish the FENOC decision-making process at Davis-Besse, including hazard analysis
  • Perform corrective action procedure benchmarking Management Root Cause Management Root Cause Contributing Causes Corrective Actions Contributing Causes Corrective Actions

20 Other Relevant Improvements Other Relevant Improvements

  • Realign Incentive Program to increase Focus on Safety
  • Establish policies to support safety

- Operations involvement

- Management presence in the field Management Root Cause Management Root Cause Corrective Actions Corrective Actions

21 FirstEnergys CEO has set the standard of returning Davis-Besse to service in a safe and reliable manner, and doing the job right the first time.

We are committed to meeting this challenge.

Management Root Cause Management Root Cause Summary Summary

22 Restart Progress Restart Progress Clark Price Manager -- Business Services

23 Our focus is to ensure the plant and our people are meeting new high standards for restart and sustained, safe operations.

Restart Progress Restart Progress

24 Restart Progress Restart Progress Restart Action Milestones Restart Action Milestones

  • System Walkdowns complete
  • Containment Inspections near complete
  • Containment painting preparations underway
  • Containment Polar Crane modification complete this week
  • Containment Air Cooler Coil removal complete
  • Management Root Cause report complete

25 Restart Progress Restart Progress System System Walkdown Walkdown Overview Overview

  • Approximately 80 separate walkdowns conducted
  • 31 System Health Readiness Review Systems
  • 5 Latent Issue Review Systems
  • Configuration Verification walkdowns for selected systems will occur later
  • > 3,500 manhours were expended

- Members of all 36 System Readiness and Latent Issues Walkdown Teams

- Management Oversight participation

26 Reactor Coolant System Reactor Coolant System

27 Containment Air Cooler Containment Air Cooler

28 Management Oversight Participation Management Oversight Participation

29 Examples of Containment Debris Examples of Containment Debris

30 Safety Features Actuation System Safety Features Actuation System Cabinet Wiring Cabinet Wiring

31 125Volt DC Power Panel Connection 125Volt DC Power Panel Connection

32 Restart Progress Restart Progress System System Walkdowns Walkdowns - Generic Issues

- Generic Issues

  • Numerous small valve leaks
  • Need to improve cleanliness and proper housekeeping in less-accessed areas
  • Thread Engagement - packing followers, valve studs, etc.
  • Loose conduit and tubing
  • Crushed tubing/bent sensing lines

33 Restart Progress Restart Progress System System Walkdowns Walkdowns - Significant Findings

- Significant Findings

  • Substantial debris in Containment
  • Substantial dust in Control Room panels
  • Pressurizer manway stud thread engagement
  • Potential MOV lubrication degradation
  • SFAS Control Room cabinets contain multiple examples of poor workmanship that may challenge long-term functionality
  • Potential non-compliance with EQ requirements for MOVs (electrical terminations, t-drains, etc.)

34 Restart Progress Restart Progress System System Walkdowns Walkdowns - Significant Findings

- Significant Findings

  • EDG Exhaust Silencer Tornado Missile Shield structural attachment to roof parapet degraded
  • Over 200 CRs initiated to-date
  • More CRs are being written to complete the walkdown findings

35 Restart Progress Restart Progress System System Walkdowns Walkdowns - Cumulative Impact

- Cumulative Impact

  • Status of systems to support safe and reliable operation is being evaluated
  • Number of valve packing leaks may require substantial effort to fix prior to restart
  • Lack of proper thread engagement issue requires broader investigation
  • Investigation to Extent of Condition of potential EQ issues may lead to additional work

36 Measuring Measuring Progress Progress

  • Established Indicators to track:

- Progress on Building Block Plans

- Progress on NRC Inspection Manual Chapter 0350 Restart Checklist

- Progress towards meeting new standards for restart and sustained operational excellence Restart Progress Restart Progress

37 Restart Progress Restart Progress RESTART ACTIONS 0

100 200 300 400 500 600 700 800 900 Number of Remaining Actions Add Close Goal CAs 0

20 29 30 27 CRs 225 273 517 587 793 Close 10 18 19 25 16 Add 62 86 272 96 219 Goal 0

7/21 7/28 8/4 8/11 8/18 8/25 9/1 9/8 9/15 9/22 9/29 10/6 10/13 10/20 10/27 Goal = 0 Good CAs CRs

38 Restart Progress Restart Progress PROGRESS MEASURE TARGET START TARGET END CURRENT START CURRENT END ACTUAL

% COMPL 1

05/20/02 06/29/02 05/20/02 06/29/02 100%

2 08/01/02 08/04/02 07/17/02 07/18/02 100%

3 07/31/02 08/16/02 08/12/02 08/19/02 100%

4 07/09/02 08/25/02 06/27/02 08/24/02 95%

5 08/26/02 09/28/02 08/26/02 09/28/02 6

08/26/02 09/28/02 08/26/02 09/28/02 7

09/29/02 09/29/02 11/04/02 11/04/02 MILESTONE ACTIVITIES OLD DB REACTOR HEAD READY FOR REMOVAL REP LACEMENT HEAD INSTALLATION AT DB CONTAINMENT DESIGN RESTORATION AT DB MODE 5 (REACTOR HEAD ON THE VESSEL)

REP LACEMENT HEAD TRANSP ORTED MIDLAND TO DB CONTAINMENT SHIELD BUILDING CONCRETE REMOVAL MOBILIZE 5/01 5/08 5/15 5/22 5/29 6/05 6/12 6/19 6/26 7/03 7/10 7/17 7/24 7/31 8/07 8/14 8/21 8/28 9/04 9/11 9/18 9/25 10/02 10/09 10/16 10/23 10/30 11/06 11/13 11/20 11/27 1

2 3

4 5

6 7

Milestone Activities Target Curent REACTOR VESSEL HEAD REPLACEMENT PROJECT

39 Restart Progress Restart Progress SYSTEM READINESS REVIEWS 0

5 10 15 20 25 30 35 Number of Outstanding Reviews Plan Actual Plan 31 31 31 31 31 30 26 17 17 17 10 0

0 Actual 31 31 31 31 31 7/21 7/28 8/4 8/11 8/18 8/25 9/1 9/8 9/15 9/22 9/29 10/6 10/13 Good REVIEW PHASE 18 9

0 0

5 10 15 20 25 30 35 Scope to EAB SRR Complete EAB Final Concurrance

40 Restart Progress Restart Progress TARGET START TARGET END CURRENT START CURRENT END ACTUAL

% COMPL 1

06/11/02 06/26/02 06/11/02 08/21/02 93%

2 06/17/02 08/02/02 06/17/02 09/03/02 74%

3 07/02/02 07/17/02 07/15/02 09/10/02 45%

4 07/16/02 08/21/02 08/20/02 10/14/02 5

08/05/02 09/12/02 08/20/02 10/07/02 6

05/17/02 10/03/02 05/17/02 10/03/02 58%

7 08/21/02 09/16/02 10/01/02 10/21/02 BORIC ACID CORROSION CONTROL P ROGRAM P SA P ROGRAM P HASE 2 (P ILOT)

OP ERATING EXP ERIENCE P ROGRAM REACTOR COOLING SYS UNIDENTIFIED LEAKAGE P ROGRAM PROGRESS MEASURE MILESTONE ACTIVITIES INSERVICE INSP ECTION (ISI) P ROGRAM ENGINEERING CHANGE/P LANT MODIFICATION P ROGRAM CORRECTIVE ACTION P ROGRAM 5/01 5/08 5/15 5/22 5/29 6/05 6/12 6/19 6/26 7/03 7/10 7/17 7/24 7/31 8/07 8/14 8/21 8/28 9/04 9/11 9/18 9/25 10/02 10/09 10/16 10/23 10/30 11/06 11/13 11/20 11/27 1

2 3

4 5

6 7

Milestone Activities Target Current PHASE 2 PROGRAM REVIEWS

41 Restart Progress Restart Progress ROOT CAUSE QUALITY 0%

20%

40%

60%

80%

100%

CARB Approval %

0 2

4 6

8 10 Items Processed Approved 0

0 5

0 3

2 Rew ork 3

0 0

4 0

2 Goal 90%

90%

90%

90%

90%

90%

90%

90%

90% 90%

90%

90%

90%

90%

90%

Cum Actual 13%

13%

46%

35%

42%

43%

7/7 7/14 7/21 7/28 8/11 8/18 8/25 9/1 9/8 9/15 9/22 9/29 10/13 10/20 10/27 Good

42 Restart Progress Restart Progress ENGINEERING QUALITY 0.0 0.5 1.0 1.5 2.0 2.5 3.0 Average Weekly Score 0

5 10 15 20 25 30 Engineering Items Reviewed Items Goal Actual Items 9

25 24 8

Goal 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 Actual 2.6 1.1 2.1 1.4 Pre-EAB 8/4 8/11 8/18 8/25 9/1 9/8 9/15 9/22 9/29 10/6 10/13 10/20 10/27 Good

43 Nuclear Quality Assessment Nuclear Quality Assessment Quality Standards Quality Standards Bill Pearce Vice President -- Oversight

44

  • Evaluation performed by recognized outside team leader
  • Team also consisted of Perry and Beaver Valley employees
  • Independent root cause of missed opportunities
  • Corrective actions being implemented Nuclear Quality Assessment Nuclear Quality Assessment Root Cause Evaluation Root Cause Evaluation

45 Root Cause Root Cause

  • FENOC nuclear safety values, behaviors and expectations were inadequate to enable oversight to effect needed positive change in station operations Nuclear Quality Assessment Nuclear Quality Assessment Preliminary Conclusions Preliminary Conclusions

46 Contributing Causes Contributing Causes

  • Ineffective Training for previous event
  • Process for providing oversight of the oversight function was less than adequate
  • For a period of time, the management of the audit/evaluation process was not independent from the management of the corrective action process Nuclear Quality Assessment Nuclear Quality Assessment Preliminary Conclusions Preliminary Conclusions

47 Actions Actions

  • Elevate standards
  • Hold line organization accountable to higher standards
  • Increased intrusiveness
  • Raise tough issues
  • Escalate unresolved issues to higher management Nuclear Quality Assessment Nuclear Quality Assessment Preliminary Conclusions Preliminary Conclusions

48 Assessment of Key Activities Assessment of Key Activities

  • Review board meetings
  • In-depth technical review of engineering products
  • Field verification of actual conditions
  • Independent parallel reviews Nuclear Quality Assessment Nuclear Quality Assessment Quality Standards Quality Standards

49 0

5 10 15 20 25 30 35 40 JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL 12 Month Rolling Average 2001-2002 Condition Report Generation Rate Nuclear Quality Assessment Nuclear Quality Assessment Quality Standards Quality Standards

50 Increased Intrusiveness Increased Intrusiveness

  • Most recent assessment identified 77 issues
  • Real-time assessment of activities in process
  • Ensuring product quality upon activity completion Nuclear Quality Assessment Nuclear Quality Assessment Examples of Results Examples of Results

51 Real-Time Issues Identified Real-Time Issues Identified

  • Failure to recognize Containment painting as a design change Nuclear Quality Assessment Nuclear Quality Assessment Examples of Results Examples of Results

52 Ensuring Product Quality Ensuring Product Quality

  • Vendor errors with implementation of feedwater flow modification
  • Failure to comply with quality program requirements during overhaul of decay heat pump Nuclear Quality Assessment Nuclear Quality Assessment Examples of Results Examples of Results

53 Elevating Standards Elevating Standards

  • Posting and protection of Protected Train equipment
  • Documentation standards for unit log keeping
  • Potential corrosion of Containment Vessel
  • Untimely corrective actions for previously identified Corrective Action Program weaknesses Nuclear Quality Assessment Nuclear Quality Assessment Examples of Results Examples of Results

54 2nd Quarter Assessment Results 2nd Quarter Assessment Results

  • Marginal performance for 5 of 11 areas in second quarter
  • Two unacceptable performance issues Nuclear Quality Assessment Nuclear Quality Assessment Examples of Results Examples of Results

55 Conclusion Conclusion QA is already improving our standards. We are not yet where we need to be, but we have identified our weaknesses and are formulating an improvement plan.

Nuclear Quality Assessment Nuclear Quality Assessment

56 Reactor Head Resolution Plan Reactor Head Resolution Plan Bob Schrauder Director -- Support Services

57 Progress Progress

  • Replacement Head activities continue to support safe and reliable plant return to service during Fourth Quarter 2002.

Reactor Head Resolution Plan Reactor Head Resolution Plan

58 Replacement Head Activities Replacement Head Activities

  • New head arrived at Davis-Besse on July 18, 2002
  • All activities at Midland are complete
  • Code Data Package compiled
  • Design reconciliation compiled Reactor Head Resolution Plan Reactor Head Resolution Plan

59 New Head and Cover Placed on Trailer New Head and Cover Placed on Trailer

60 New Head Arrives at Davis-Besse New Head Arrives at Davis-Besse

61 Davis-Besse Activities Davis-Besse Activities

  • Reactor Head prepared for removal
  • Service Structure preparations complete
  • Shield Building opening complete Reactor Head Resolution Plan Reactor Head Resolution Plan

62 Davis-Besse Head Ready for Removal Davis-Besse Head Ready for Removal

63 Shield Building Marked for Cutting Shield Building Marked for Cutting

64 Protection for the Start-Up Transformer Protection for the Start-Up Transformer

65 Ready to Remove Concrete Ready to Remove Concrete

66 Backing Plate Backing Plate

67 First Layer of Rebar Exposed First Layer of Rebar Exposed

68 Shield Building Opening Shield Building Opening

69 Mock-Up for Containment Cutting Mock-Up for Containment Cutting

70 Containment Health Plan Containment Health Plan Randy Fast Plant Manager

71 Containment Health Plan Containment Health Plan Inspections Inspections

  • Containment Air Coolers

- Complete refurbishment

- Replace plenum and turning vanes with stainless steel

- Replace 2 motors; refurbish 1

72 Removing Containment Air Cooler Coils Removing Containment Air Cooler Coils

73 Containment Health Plan Containment Health Plan Inspections Inspections

  • Under Vessel Inspections

- Temporary modification for incores installed

- Seal plate removed

- Insulation removed

- Hot Leg/Cold Leg/Core Flood Tank Nozzle Completed

74 Containment Health Plan Containment Health Plan Inspections Inspections

  • Independent Inspections

- Training

- Inspection status

- Findings

75 Containment Health Plan Containment Health Plan

  • Decay Heat Valve Pit

- Evaluating options

76

  • Containment Pressure Vessel

- MIC

- Corrosion

  • Equipment Qualification

- Walkdowns in progress Containment Health Plan Containment Health Plan

77

  • Containment Emergency Sump

- Improve margin Containment Health Plan Containment Health Plan

78 Containment Health Plan Containment Health Plan

- Dome coating in progress

79 Containment Dome Painting Containment Dome Painting

80 Containment Painting Containment Painting

81 Containment Painting Containment Painting

82 Program Compliance Plan Program Compliance Plan Jim Powers Director - Technical Services

83 Program Compliance Plan Program Compliance Plan Phase 1 Reviews Phase 1 Reviews

  • 14 programs reviewed

- 6 programs rated as satisfactory

  • Fire Protection Protection
  • Ventilation Filter Test Program
  • Corrosion and Erosion Analysis Program
  • Safety Tagging Program
  • Meteorological Monitoring

84 Program Compliance Plan Program Compliance Plan Phase 1 Reviews Phase 1 Reviews

- 8 programs require additional actions

  • Air Operated Valve Program
  • Software Control Program
  • Temporary Leak Seal Program
  • Severe Accident Management Program
  • Inservice Test Program
  • Appendix J Program

85 Program Compliance Plan Program Compliance Plan Phase 2 Reviews Phase 2 Reviews

- Walkdown Condition Reports to be effectively resolved

- Ownership

- Forward-Looking Program Linkages

- Management Involvement

- Organizational Interfaces

86 Program Review Board Program Review Board

87 Program Compliance Plan Program Compliance Plan Phase 2 -- Program Review Board Phase 2 -- Program Review Board

  • Corrective Action Program (August 29)
  • Inservice Inspection (September 6)
  • Probabilistic Safety Assessment (October 3)

88 System Health Assurance Plan System Health Assurance Plan Jim Powers Director -- Technical Services

89 System Readiness Reviews System Readiness Reviews

  • Discovery walkdowns on 31 systems completed
  • Team included representatives from:

- Maintenance

- Operations

- Engineering

- Management System Health Assurance Plan System Health Assurance Plan

90 Latent Issues Latent Issues

  • 5 teams scheduled to present scope definition to Engineering Assessment Board
  • Schedules and performance indicators developed
  • Discovery walkdowns completed
  • Teams relocated to Wellness Center System Health Assurance Plan System Health Assurance Plan

91 Latent Issues Latent Issues

  • Developing permanent plant procedures for walkdowns and Latent Issue Reviews to be used FENOC-wide
  • 120v DC to be included in Latent Issue Review going forward System Health Assurance Plan System Health Assurance Plan

92 Closing Remarks Closing Remarks Lew Myers FENOC Chief Operating Officer

93 We have confidence in our employees.

This plant is their livelihood. They are well educated, technically sound, hard working, and proud members of this community.

Our people continue to be committed to a comprehensive approach to ensure Davis-Besse is ready for safe and reliable operation and sustainable performance.

Conclusions Conclusions