ML072250023
| ML072250023 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/02/2007 |
| From: | Halnon G FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC MC6465, TAC MC6466 | |
| Download: ML072250023 (13) | |
Text
BEAVER VALLEY POWER STATION License Renewal Application BVPS License Renewal Project Presentation to NRC Aug. 2, 2007 FENOC Introduction Greg Halnon, Director Fleet Regulatory Affairs FENOC I
AGENDA
" Introduction - Greg Halnon
- 2005 project review - Cliff Custer
" Current project overview - Cliff Custer
" Oversight - Greg Halnon
" Review Process - Cliff Custer
" Submittal items of interest - Cliff Custer
- Closing remarks - Pete Sena FENOC 3
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(~ea CP 2005 Project Review March 2005 NRC Letter:
- Information - overly general
- Inadequate QA of renewal application
- Insufficient explanation of information
- Lack of non-safety related structures &
components scoping
- Technically incorrect information
- LRA inconsistencies
2
2005 Project Review 2005 Project: Root Causes:
" Less than adequate participation in NRC & Industry Working Groups
- Inadequate regulatory interface
- Inadequate sponsorship & station ownership FENOC 2005 Project Review Major Lessons Learned:
- FENOC must manage the project to remain current with industry and NRC standards
- Station personnel must own the results and be prepared to implement renewed licenses 0 Improved management engagement and oversight are necessary.
- LRA and support documents should be subjected to rigorous reviews by owner, third party and peers FENOC 3
Current Project Overview What's different this time?
- Root Causes & Lessons Learned have been addressed
" Industry Participation to remain current with standards
- Site Participation & use of Site-Specific Operating Experience
" CLB items related to.License Renewal identified &
addressed
" Built-in Quality - Approval Structure, LRAB, Review Cycle (Internal/External Assessments)
FENOC 7
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ftMR Current Project Overview Current Licensing Basis Reconciliation JIFMI IMP IJTJIAiIlOINID['JIFIMIAIMIJIJIAI5IOINI JIFIM AIMiJ JAI131OINI0 JIFIMIAIMIJ At) 50 1N7JFIII I
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FENOC 4
Current Project Overview Site Participation:
0 Program evaluation documents & site operating experience
- Aging management review
" Specific TLAA updates & reviews
- Midland propane terminal evaluation FENOC 9
77-- %
Current Project Overview Industry Participation & NRC Interface S20O@
z20 06 2007 Working Group, Audits
& Inspections
- r,,~ronenti.
L olfCrek AMP NRC/ACRS Meetings NRC/NEI LRTF Meetin s & Conf. Calls NRC & BVPS Specific Meetings 5
FENOC 10 5
Industry Benchmarking Significance
- LR Task Force & Working Groups
- Improved content
- Adjustments to program documents
- Audits
- Detailed adjustments to support documents and the application
- Understanding of audit issues and logistics
- Monthly NRC phone-calls & meetings
- Verify project actions are current
- Current expectations for the Environmental Report FENOC Response to Industry Participation &
Lessons Learned (cont.)
-Environmental report enhanced to address NRC concerns regarding:
- Clean Water Act 316 (b) information
- Non-rad waste, waste minimization and the 1990 Pollution Prevention Act information
- 1966 National Historic Preservation Act information
- Endangered Species Act threatened and Endangered Species Review FENOC 12
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Oversight Summary:
- Increased scrutiny from peer groups:
NEI Working Group Reviews of Guidance Peer reviews in self-assessments 3 rd Party sufficiency review
" License Renewal Assessment Board
" Nuclear oversight - performance based assessments
- Management Review of progress and quality indicators
" Final Licensing and site reviews FENOC 13F Oversight LR Assessment Board Charter:
" Diverse membership:
- FENOC corporate, BV Senior Leadership Team, plant experts, peers, industry experts, and legal advisor
- Scope of review - Focused assessments and board meeting:
- Assessment results and recommendations Project guidelines - current
- Technical issues - consistent with Current Licensing Basis
- Deviations from GALL or other standards LRA acceptable (NRC/Industry Standards)
" Timing for reviews:
5 Reviews at key milestone events
" Board reports to BVPS site VP FENOC 14
.71-7-1.
7
Oversight LRAB
Conclusions:
" Industry involvement & use of lessons learned was effective
- Procedures are aligned with current industry expectations
" Appropriate level of interaction with BVPS program owners
" Historical RAI evaluation is adequate
- Document structure supports LRA & NRC inspection &
audits
" The review process through Phase 1 has been effective
" LRA adequate for submittal - pending resolution of open items FENOC 15 Review - Phase I FENOC 16 8
Review - Phase III FENOC 181 77-177-9
Review - Comments Status 0 Received 0 Closed Team Peer Mgmt.
Suff.
LRAB 5 V&V PORC CNRB Total FENOC 19 Submittal Items of Interest o RT(PTS) evaluation Metal Fatigue DBD
- Midland Propane Terminal
, SAMA correction - regarding SECPOP errors
- TLAA approach
- GALL conformance
- Environmental Report revision -
refurbishment FENOC 20 10
Submittal Items of Interest 42 Total Aging Management Programs 16 New 26 Existing 2 Plant-12 GALL 2 Future 2 Plant-24 GALL Specific Specific FENOC 21 Submittal Items of Interest Plant-Specific Programs - evaluated 4 programs:
" B.2.10: Electrical Cable Connections - not subject to 10 CFR 50.49 environmental qualification requirements one-time inspection
" B.2.13: Electrical Wooden Poles/Structures inspection (Unit 2 Only)
" B.2.35: Reactor Vessel Integrity
" B.2.37: Settlement Monitoring (Unit 2 Only)
FENOC II
Submittal Items of Interest Variances & Exceptions:
7 Programs take exception to NUREG-1801
- 4 ASME code programs: code edition
- Fire protection: testing frequency of halon and CO 2 systems
- Fuel Oil Chemistry: ASTM standards, additives, and periodic testing for microbiological activity
- Selective Leaching: Brinell hardness testing 23 FENOC 23
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PC,. CQC,,f Submittal Items of Interest Action Items:
- Midland Propane Terminal
- PTS analysis docketing per 10CFR50.61
- Planned PRA peer evaluation
- (Reg. Guide 1.200)
12
Closing Remarks Pete Sena, BVPS Site VP FENOC 25 1-,
0-111.0Cc 13