ML073380226
| ML073380226 | |
| 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: ML073380226 (25) | |
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- Act, 27,e2.0 MIA-7-&o
Joe Hagan FENOC President & Chief Nuclear Officer
Introduction & Agenda
- Joe Hagan Opening Remarks
- Gary Leidich FirstEnergy Senior Vice President - Operations FirstEnergy Perspective
" Greg Hainon Director - Fleet Regulatory Affairs
. Insurance Claim Timeline & Process
" Dan Pace Senior Vice President - Fleet Engineering Exponent & Mattson Report Analysis
- Joe Hagan Commitments & Concluding Remarks
FENOC is Committed to Safety
- Lessons learned from the Davis-Besse event will not be forgotten a
- Strongly committed to operating all, nuclear facilities safely, and responsibly f.. 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 improvement
Plant Operations Reflect Safety Commitment
" Conservative operations lead to strong operating performance
, Equipment improvements ensure continued safe, reliable operations
.,, Industry recognizes performance improvements
FENOC Response Addresses Key Issues
- FENOC acceptsfull responsibility for the Davis-Besse event m Root causes and corrective actions remain valid
- Expert reports do reliable operation nuclear plants not impact safe and of Davis-Besse or other
, Lessons learned are:
Formal Reviews
.. Early Communications
FN0 F-st--ergy-ersp-eS-c-~~e Gary Leidich FirstEnergy Senior Vice President - Operations C
Corporate Commitment to Nuclear Safety is Strong
- Nuclear safety is at the forefront
- Corporate confidence in FENOC with full authority to operate facilities safely and reliably
- Interfaces across corporate organizations need to improve U
(7' Emphasis on safety is the highest priority at all levels of FirstEnergy
FENOCInsuanceClai e------e&Po e
Greg Halnon Director, Fleet Regulatory Affairs
FENOC. Receives Reports
FENOC Considers Exponent Report LCommercial and nuclear processes did not sufficiently interface
- Determined no safety or inspection concern existed Lacked sensitivity to regulatory interest
. Improved process being developed
' a FENOC Addresses May 2
Response
.. Response was:
Narrowly focused or crack and cavity develo;pment Fa I - Not an endorsement of the entire Exponent K*Report a
70' Response did not sufficien*v.
U Uý consider:
- Exponent's overall conclusions and assumptions OPperational data.,
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Repor Anli Dan Pace Senior Vice President, Fleet Engineering
FENOC Standsby Root Cause Reports Analyses of root causes:
Provided comprehensive review of the Davis-Besse event Identified programmatic failures Not implementing boric acid corrosion control program properly caused head degradation, Leakage detectable prior to 12RFO (2000)
Generated comprehensive and appropriate corrective actions
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 Provided expert testimon on boric acid control program ri¸
FENOC Performed Analysis of Exponent Report
- Key root-cause team members participated in review m Exponent Report statements evaluated against technical/
managerial root cause reports Impact on other. root cause reports assessed Key differences highlighted Discussed findings with Exponent Team Corrective actions reaffirmed c41
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
- Exponent results do not fully explain observed operational data
Differences in Exponent Report and-Root Cause Reports Noted m Rnnt rn",.P, rp-nnrtq cnncl HidP.
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(ii if detectable I 2000 m r to
- Exponent analysis indicated degradation not detectable i
- FENOC stands by analyses of root causes
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Mattson Report is Expert Testimony m Contains expert testimony about the industry and-its boric acid control programs m 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 /7 Proposed Imposition of Civil Penalties 954
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
, FENOC agrees damage to the reactor head was not deliberate
Aw
-C-o-m-m-it-m-e-nts-FENO C Joe Hagan FENOC President & Chief Nuclear Officer
FENOC Commits to Actions m 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
Mi-S SM Joe Hagan FENOC President & Chief Nuclear Officer
t BV-L-07-082 DB-Serial Number 3350 PY-CEI/NRR-3044L Page 1 of 1 Coffirnitment List The following table identifies those actions committed to by FENOC. Any other statements in this letter are provided for information purposes and are not considered regulatory commitments. Please notify Mr. Gregory H. Halnon, Director, Fleet Regulatory Affairs, at (330) 384-5638, of any questions regarding this document or associated regulatory commitments.
Commitment Due Date FENOC will develop a formal process to review technical reports 12/14/2007 prepared as a part of a commercial matter. The process will provide criteria for FENOC to utilize to determine if the report has the potential for regulatory implications or impact on nuclear safety both at our sites and within the nuclear industry. This process will provide for the timely and critical evaluation of this type of report and will complement our existing formal nuclear process for obtaining technical reports from our agents and contractors.
FENOC will also provide an OE document to the nuclear industry 8/10/2007 through the established OE process. This OE document will discuss the issues surrounding this DFI, including the review of technical reports prepared as part of a commercial matter.
Process changes will be made to the NRC Correspondence procedure 12/14/2007 to ensure specific questions are asked during the process relative to the experience gained from the efforts to respond to this DFI.
FENOC's policy on Regulatory Communications will be assessed for 11/30/2007 potential enhancements through CAP.
The May 2, 2007 response to the April 2, 2007 NRC Request for 11/30/2007 Information was narrow in scope and resulted in unintended conclusions relative to FENOC's regulatory position. 'TEls will be addressed through the Corrective Action Program.J