ML071790596
| ML071790596 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/27/2007 |
| From: | FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2007-0299 | |
| Download: ML071790596 (24) | |
Text
Jvul
Joe Hagan FENOC President & Chief Nuclear Officer
Introduction & Agenda
- Joe Hagan Opening Remarks
- Gary Leidich FirstEnergy Senior Vice President - Operations FirstEnergy Perspective
- Greg Halnon Director - Fleet Regulatory Affairs Insurance Claim Timeline & Process
- Dan Pace Senior Vice President - Fleet Engineering Exponent & Mattson Report Analysis
- Joe Hagan
- Commitments & Concluding Remarks 3
FENOC is Committed to Safety m Lessons learned from the Davis-Besse event will not be forgotten
- Strongly committed to operating all nuclear facilities safely and responsibly Annual Safety Culture and Safety Conscious Work Environment (SCWE) survey scores remain strong World class fleet industrial safety performance in 2006 Excellence Plans drive continued performance Safe Plant SaferPatins improvement Reliable Plant Operations 4
Plant Operations Reflect Safety Commitment
- Conservative operations lead to strong operating performance m Equipment improvements ensure continued safe, reliable operations
, Industry recognizes performance improvements Oprtonm Reliable Cost-Effective Plant Operations Plant Operations 5
FENOC Response Addresses Key Issues
- FENOC accepts full Davis-Besse event responsibility for the
- Root causes and corrective actions remain valid
- Expert reports do reliable operation nuclear plants not impact safe of Davis-Besse and or other
- Lessons learned are:
= Formal Reviews Early Communications Safe Plant Operations Reliable Plant Operations Gost-Effective Plant Operatioin 6
Gary Leidich FirstEnergy Senior Vice President - Operations
Corporate Commitment to Nuclear Safety is Strong
- Nuclear safety is at the forefront m Corporate confidence in FENOC with full authority to -operate facilities safely and reliably
- Interfaces across corporate organizations need to improve Emphasis on safety is the highest Sate Plant Saferatins priority at all levels of FirstEnergy Reliable Cost-Effective Plant Operations Plant Operations 8
Greg Halnon Director, Fleet Regulatory Affairs
FENOC Receives Reports Dec. 5-Exponent
& Mattson draft reports circulated Dec. 18-Exponent Report sent to NEIL Feb. 23-FENOC initiated CRto address NEIL safety concern; NRC notified Mar. 20-Exponent Report sent to NRC May 2 -
FENOC responded to NRC Request for Info Jun. 13 -
FENOC responded to NRC Demand for Info May 4-Mattson Report sent to NRC
FENOC Considers Exponent Report
- Commercial and nuclear processes did not sufficiently interface
" Determined no safety or inspection concern existed
- Lacked sensitivity to regulatory interest
, Improved process being developed Safe Plant Operations Reliable Plant Operations 11
FENOC Addresses May
Response
- Response was:
2
- Narrowly focused on development crack and cavity
= Not an endorsement of the entire Exponent, Report Response did not sufficiently consider:
- Exponent's overall conclusions and assumptions
- Operational data Safe Plant Operations Reliable Plant Operations Cost-Effective Plant Operations 12
Dan Pace Senior Vice President, Fleet Engineering
FENOC Stands by Root Cause Reports mAnalyses of root causes:
- Provided comprehensive review Davis-Besse event of the
- Identified programmatic failures
- Not implementing boric acid corrosion control program properly caused head degradation
- Leakage detectable prior to 12RFO (2000)
= Generated comprehensive and SafP
.appropriate corrective actions Reliable Plant Opecrationsa ant 14
Exponent & Mattson Reports Were Not Root Causes
- Reflect expert testimony obtained for insurance claim process
- Exponent Report Evaluated timing and evolution of wastage development based on recent data
= Assessed ability to detect leakage in 12RFO (2000)
" Mattson Report Safe Plan Operations Provided expert testimony on boric acid control program Reliable Cost Effective Plant Operations Plant Operations 15
FENOC Performed Analysis of Exponent Report
" Key root cause team members participated in review
, Exponent Report statements evaluated against technical/
managerial root cause reports
= Impact on other root cause reports assessed Key differences highlighted Safe P Discussed findings with Exponent Team pSaei
- Corrective actions reaffirmed Reliable Plant Operations 16
FENOC Assessed Report Conclusions
- Exponent provided complex analysis of cracking/wastage on head
- BWXT Head Report Argonne National Laboratories Report Recent Boric Acid Corrosion Data
- Root causes based on observed operational data Safe Plant Orperations
- Exponent results do not fully explain observed operational data Re liab e Cost-Effective Plant Operations Plant Operations 17
Differences in Exponent Report and Root Cause Reports Noted
" Root cause reports conclude detectable leakage started prior to 2000
- Exponent analysis indicated degradation not detectable in 2000 FENOC stands by analyses OSePatont of root causes Reliabl e Plan Operatns 18
Mattson Report is Expert Testimony
" Contains'expert testimony about the industry and its boric acid control programs
" Some of Mattson's conclusions can not be endorsed
" Agree with basic premise that damage to the reactor head was not deliberate
" Endorsed conclusions do not conflict with:
Root cause reports
- Licensee Event Report regarding the Reactor Pressure Vessel FENOC's response to Notice of Violation and Proposed Imposition of Civil Penalties 4
Reliatle Plant Operations 19
Report Conclusions Summarized
- FENOC stands by analyses of root causes
- Reports represent expert opinion
- Exponent Report provides detailed technical analysis
- FENOC disagrees with Exponent regarding when leakage was detectable N FENOC agrees damage to the reactor head was not deliberate OatiPnt 0*
Reliable Cost Effec Plant Operations Plant Operz 20
Joe Hagan FENOC President & Chief Nuclear Officer
FENOC Commits to Actions
- Develop process to review reports prepared for commercial matters
- Provide Operational Experience to industry
- Improve NRC correspondence procedure
- Assess Regulatory Communications policy
- Develop lessons learned from May 2 response Safe Plant Operations Reliable Co Plant Operations Plan 22
Joe Hagan FENOC President & Chief Nuclear Officer
FENOC 24