ML070730423
| ML070730423 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/13/2007 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Caldwell J Region 3 Administrator |
| References | |
| 1-1489 | |
| Download: ML070730423 (12) | |
Text
FENOC 550 1 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor Onto 43449 Mark B. Bezilla 4 19.321-7676
!Ace fresdent - Nuclea, Fax 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1- 1489 March 1 3 , 2007 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region I11 2443 Warrenville Road, Suite 2 10 Lisle, JL 60532-4352
Subject:
Submittal of the Operations Performance Independent Assessment Plan for the Davis-Besse Nuclear Power Station - Year 2007
Dear Mr. Caldwell:
The purpose of this letter is to submit the assessment plan and related information for the year 2007 independent assessment of the Davis-Besse Nuclear Power Station (DBNPS)
Operations Performance. The Nuclear Regulatory Commission (NRC) letter, dated March 8,2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order, (letter DBNPS Log Number 1-4524) requires submittal of the external assessment organization, including the qualifications of the assessors, and the scope and depth of the assessment plan, ninety (90) days prior to the assessment.
In the DBNPS letter of August 23,2006, transmitting the results of the 2006 independent assessment (letter Serial Number 1-1470), DBNPS requested, in accordance with Section IV of the Confirmatory Order, that the NRC consider rescinding the requirement to continue the independent assessments of Operations Performance based on the positive results of the 2005 and 2006 assessments. For example, the 2006 assessment team noted that the plant is being operated safely, both in the control room and in the plant and the operations department assessments continue to improve in quality and depth. The DBNPS submitted a letter on January 17,2007, (letter Serial Number 1-1482) providing additional information to support the request to rescind the final two years of independent assessments.
With this letter, DBNPS respectfblly withdraws its prior request for the NRC to rescind the Order requirements to perform the remaining two years of Operations Performance
Docket Number 50-34e License Number NPF-3 Serial Number 1- 1489 Page 2 of 2 independent assessments. Although the DBNPS believes that sustained safe performance in the area of Operations is being demonstrated and that the organization continues to demonstrate the ability to effectively self-assess, identi@ and correct areas needing additional focus, the DBNPS and the FirstEnergy Nuclear Operating Company (FENOC) see value in the continuance of the independent assessments as the assessments provide external perspectives that will further assist the Station and the fleet in achieving top industry performance.
Therefore, in accordance with the Confirmatory Order, FENOC is submitting the Operations Performance Independent Assessment Plan, including the identification and qualifications of the assessors. Davis-Besse is securing an industry peer as an additional assessment team member. The DBNPS will submit a revised plan to include the identification and qualifications of the industry peer. The onsite portion of the assessment is scheduled to commence on June 1 1,2007, with this portion of the assessment lasting approximately two weeks. A final debrief marking the end of the assessment will be conducted with the DBNPS staff within 14 days of completion of the onsite assessment. The final assessment report and action plans, if required, will be submitted to the NRC within 45 days following the final debrief.
If you have any questions or require additional information, please contact Mr. Dale R. Wuokko, Acting Manager - Regulatory Compliance at (419) 32 1-7 120.
Sincerely yours, J
LJS - Commitment List - Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Plan - Year 2007 - Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Assessors and Qualifications - Year 2007 cc: USNRC Document Control Desk DB-1 NRC/NRR Project Manager DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 1-1489 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by FirstEnergy Nuclear Operating Companys (FENOC) Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory Commitments. Please notify the Acting Manager - Regulatory Compliance (419-321-7120) at the DBNPS of any questions regarding this document or associated regulatory commitments.
COMMITMENTS DUE DATE Submit a revision to the Operations Performance April 12,2007 Independent Assessment Plan for the DBNPS - Year 2007 to include the identification and qualifications of the industry peer.
Docket Number 50-346 License Number NPF-3 Serial Number 1- 1489 Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Plan - Year 2007 (5 pages to follow)
NUMBER:
COIA-OPS-2007 ASSESSMENT AREA:
Operations Performance PURPOSE:
The purpose of this assessment is to provide an independent and comprehensive assessment of Operations Performance at the Davis-Besse Nuclear Power Station. The assessment will be performed in accordance with the requirements of the March 8,2004, Confirmatory Order Modifying License No. NPF-3, and Davis-Besse Business Practice, DBBP-VP-0009, Management Plan for Confirmatory Order Independent Assessments. The assessment will be used to identify areas for improvement that require corrective actions with action plans and areas in need of attention for other improvement opportunities. The assessment will also be used to assess the rigor, criticality, and overall quality of available Davis-Besse internal self-assessment activities in the Operations performance area. The final assessment report will provide a conclusion of the effectiveness of the assessed areas, using the rating categories contained in Business Practice DBBP-VP-0009. In addition, the assessment will compare this years Operations Performance with that observed during the 2006 assessment.
SCOPE:
The Independent Assessment Team will evaluate the following Operations activities occurring during the assessment period using current industry standards and applicable Davis-Besse procedures:
e Shift turnover; e Control manipulations; e Communications, including managements expectations in accordance with the Conduct of Operations Procedure; e Interdepartmental interfaces; e Procedural use; e Operations Procedure revision backlog; 0 Awareness of plant and equipment status and workarounds; e Pre-job/activit y briefings; e Non-shift Operations management interface and oversight; a On-shift personnel manning and scheduling, including implementation of the Davis-Besse Nuclear Power Station Operations Long Range Staffing Plan, dated July 2006; e Shift management command and control; e Shift managements evaluation, prioritization, and disposition of maintenance activities and emergent issues; e Operations behaviors in the areas of questioning attitude and safety; e Shift handling of off-normal operations; e Observation of operator simulator training to compare crew performance, demeanor, and communication skills with actual control room operations.
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SCOPE (cont.):
The Assessment Team will review selected Condition Reports related to Operations Section performance initiated since the 2006 Independent Assessment of Operations Performance and independently assess the corrective actions taken.
The Assessment Team will review the Condition Reports initiated to address the Areas in Need of Attention that were identified during the 2006 Operations Performance Assessment.
The Assessment Team will review Davis-Besses implementation of reactivity management during plant evolutions.
The Assessment Team will also evaluate the effectiveness of the Davis-Besse Nuclear Power Stations self-assessment activities associated with Operations Performance since the 2006 Independent Assessment of Operations Performance, as follows:
- a. Review the results of Davis-Besse Fleet Oversight Quarterly Audits that evaluated Operations Performance. Determine if the assessments were comprehensive and if effective actions were taken to correct problems or weaknesses identified.
- b. Evaluate the effectiveness of self-assessment capability by reviewing corrective actions associated with self-assessment reports, audits (including audits of both onsite and offsite safety committee activities), and evaluations conducted of Operations Performance.
Evaluate the significance of a sample of other self-assessment findings to determine the effectiveness of the self-assessment effort.
- c. Determine if the Davis-Besse Operations staff is aggressive in correcting self-assessment findings and determine whether the corrective actions are adequate, timely, properly prioritized, and that effectiveness reviews are ensuring the desired results.
INDEPENDENT ASSESSMENT TEAM:
0 Larry E. Briggs, Independent Consultant to Silver Fox Synergies, LLC, Team Leader 0 Paul H. Bissett, Independent Consultant to Silver Fox Synergies, LLC Industry Peer to be Determined Biographies attached.
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SCHEDULE:
March 13,2007: Submit assessment plan to NRC.
May 9, 2007: Send selected documentation to team members to begin off-site preparations.
June 10,2007: Assessment Team will assemble near the plant for final assessment preparations.
June 11 through June 22,2007: Conduct onsite assessment and provide Davis-Besse with preliminary results prior to leaving site.
The Assessment Team will provide a draft assessment report to and conduct a Final Debrief with Davis-Besse within 14 days (July 6 ) after the completion of the assessment execution week(s). The Final Debrief will conclude the assessment.
The final assessment report will be provided to Davis-Besse within seven (7) days (July 13) following completion of the Final Debrief.
The final Davis-Besse assessment report and action plans (if required by findings) will be submitted to the NRC by Davis-Besse within 45 days (August 20) of the completion of the assessment.
ASSESSMENT METHODS:
The independent assessment team will use the listed references as guidance to evaluate performance of the Operations section. The assessment methodology will include, but is not limited to the following:
- 1. Observe Control Room, Non-Licensed and Operations Management personnel in the performance of their assignments. Assessment team member shift assignments will overlap shift turnovers to compare consistency of crew operations.
Observe portions of at least three (3) day shifts, two (2) backshifts, and two (2) weekend shifts.
Observe portions of at least two (2) shifts of non-licensed activities.
- 2. Interview selected Control Room, Non-Licensed, and Operations Management personnel.
Minimum of five (5) licensed, five (5) non-licensed, and two (2) management.
- 3. Review selected Condition Reports (CR) and corrective actions to evaluate safety perspective, appropriate cause determination, and corrective action effectiveness. An index of Operations-related CRs will be provided for review during the off-site preparation weeks.
Minimum of five (5) Condition Reports.
- 4. Review Corrective Actions initiated to address the Areas in Need of Attention that were identified during the 2006 Operations Assessment to evaluate the scope and effectiveness of the corrective actions implemented.
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ASSESSMENT METHODS (cont.1:
- 5. Observation of simulator training during routine and abnormal operating conditions using NUREG-1021 as guidance and as a comparison with actual Control Room observations. The team will observe and evaluate licensed and non-licensed operator continuing training classroom instruction, including resolution of feedback concerning student comments.
- 6. Review Davis-Besses Operations department implementation of reactivity management during plant evolutions.
REFERENCES:
e DB-OP-00000, Conduct of Operations e DB-OP-00004, Operator Aids Control e DB-OP-00006, Night Orders and Standing Order Log e DB-OP-00016, Temporary Configuration Control e DB-OP-00018, Inoperable Equipment Tracking Log e DB-OP-00200, Shift Engineer e DB-OP-0 1002, Component Operation and Verification e DB-OP-01003, Operations Procedure Use Instructions e DB-OP-01200, Reactor Coolant Leakage Management e NOP-WM-0001, Work Management Process e NOP-OP- 1009, Immediate and Prompt Operability Determination e NOP-WM-2001, Work Management Scheduling/Assessment/SeasonalReadiness Processes e NOP-LP-2001, Corrective Action Program e NOP-OP-1002, Conduct of Operations e NOP-OP- 1004, Reactivity Management e NOPL-OP-01002, Reactivity Management e NOBP-LP-2604, Effective Job Briefs e Work Process Guideline (WPG) - 2, Operations Equipment Issues e NRC Inspection Procedure (IP) 71715, Sustained Control Room and Plant Observation e NRC IP 71707, Plant Operations e NRC IP 93802, Operational Safety Team Inspection (OSTI) e NRC IP 93806, Operations Readiness Assessment Team Inspections e DBNPS Operations Long Range Staffing Plan, July 2006 e An index of Condition Reports, sorted for Operations Department involvement, June 24,2006 through May 1,2007 e The Work Week Schedule for the on-site assessment weeks e The licensed operator on-shift schedule for the on-site assessment weeks e The licensed operator training schedule for the on-site assessment weeks e Last three Quality Assurance quarterly assessments e Applicable recent internal Operations self-assessments e Applicable Company Nuclear Review Board minutes from last three CNRB intervals Page 4 o f 5
ASSESSMENT PLAN APPROVALS:
Prepared by: Date:
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1489 Davis-Besse Nuclear Power Station Operations Performance Independent Assessment - Year 2007 Assessors and Qualifications (2 pages follow)
Larry E. Briggs Independent Consultant Silver Fox Synergies, LLC 0 2005 and 2006 - Silver Fox Synergies, LLC; Team Lead, Davis-Besse Nuclear Power Station (DBNPS) Operations performance area independent assessment to identify areas for improvement and other improvement opportunities as required by the DBNPS Restart Confirmatory Order.
0 2004 - Silver Fox Synergies, LLC; Team Lead, Davis-Besse Nuclear Power Station (DBNPS)
Operations performance area independent assessment to identify areas for improvement and other improvement opportunities as required by the DBNPS Restart Confirmatory Order. A similar Operations performance assessment was conducted at the Ferry Nuclear Power Plant.
0 2001 - Unsite Inc.; Senior Consultant - Developed NRC written examination for the Oyster Creek Facility (May 2002 examination).
0 1977 - 2001 : U.S. Nuclear Regulatory Commission (NRC); Held various positions with the NRC. Dutiesincluded: Senior Operations Engineer (Chief License Examiner and Senior Inspector) - Certified Chief Examiner on General Electric (GE), Westinghouse, and Combustion Engineering plants. Responsible for review, oversight, and administration of licensed operator examinations. Scheduled and made personnel assignments for Region I licensed operator examinations and re-qualification inspections. Responsible for leading team inspections as assigned, such as maintenance rule and for cause re-qualification inspections. Also led numerous NRC routine operator licensing examination teams and re-qualification inspections. Participated in nuclear event response both in Region 1 and at the facility.
0 NRC Senior Resident Inspector - Responsible for NRC inspection program at assigned facility and maintained constant interface with utility and NRC concerning plant activities and status; Senior Engineer - Responsible for oversight of NRC pre-operational testing inspection program for Region I facilities; Project Engineer Responsible for general inspection of assigned NRC Region I facilities and coordinated NRC inspection activities at assigned facilities.
0 1972 - 1977: Burns and Roe Inc; Senior Startup Engineer - Responsible for development, implementation, and coordination of pre-operational test and startup procedures for assigned systems at Three Mile Island (TMI) Units 1 and 2. Also, provided on-site engineering resolution to Unit 2 problem reports during construction.
0 1960 - 1972: U. S. Navy; Leading CPO (USS Whale SSN 638) for Reactor Control Division.
Leading In-hull instructorReactor Control Division Officer on D1 G Prototype. Engineering Office of the Watch (EOOW) qualified on DIG Prototype. Qualified on S3G Prototype, S2Wa, and S5 W Navy power plants.
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Paul Bissett Independent Consultant Silver Fox Synergies, LLC 0 2005 and 2006 - Silver Fox Synergies, LLC; Team Member, Davis-Besse Nuclear Power Station (DBNPS) Operations performance area independent assessment to identify areas for improvement and other improvement opportunities as required by the DBNPS Restart Confirmatory Order.
0 2004 - Silver Fox Synergies, LLC; Davis-Besse Nuclear Power Station (DBNPS) Operations performance area independent assessment to identify areas for improvement and other improvement opportunities as required by the DBNPS Restart Confirmatory Order. A similar Operations performance assessment was conducted at the Perry Nuclear Power Plant.
0 2004 - Performance, Safe@ & Health Associates, Inc.; Independent Consultant - Assisted in the conduct of Licensed Operator audit examinations at the St. Lucie Nuclear Power Plant.
0 1989-2003: U. S. Nuclear Regulatory Commission (NRC); Senior Operations Engineer (Chief License ExarninedInspector) - Certified Chief Examiner on Babcock and Wilcox (1 990),
Westinghouse (1988) and General Electric (1999) facilities. Effectively led and conducted licensing examinations, and requalification examinations / inspections at Region I facilities.
Assisted in the administration of operator licensing examinations in Region I1 (Surry) and Region I11 (Davis-Besse).
Responsible for leading team inspections, including, but not limited to, operator licensing requalification, maintenance rule, problem identification and resolution, Event-V, PRA, Emergency Operating Procedure (EOPs) and operational startup inspections.
Participated in numerous Region I plant restart inspections (TMI-1, IP-2, Salem 1/2, etc.),
primarily focusing on operational safety assessments.
0 1982-1989: U. S. Nuclear Regulatory Commission (NRC); Responsible for the conduct of reactor operations inspections, including the areas of maintenance, surveillance and calibration, and in-service testing of pumps and valves, including the review and approval of a licensees 10 year In-service Test program submittal. Responsible for the review of licensee QA plan submittals and subsequent inspection of licensee QNQC programs.
0 1977-1982: U. S. Nuclear Regulatory Commission (NRC); Responsible for the accountability and security of special nuclear materials at fuel fabricating facilities, including the decommissioning of one major nuclear facility, utilizing non-destructive assay techniques.
0 1970-1976: U. S. Navy; Four year assignment on the USS California (CGN-36) included the participation in the construction and testing of the engineering plant, nuclear core installation, pre-critical testing, initial criticality, power range testing and sea trials. As the Leading Machinery Watch (LMW), supervised aft engine room mechanical work activities.
Administered preventive maintenance program.
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