ML12269A690
| ML12269A690 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/11/2012 |
| From: | - No Known Affiliation |
| To: | Division of License Renewal |
| References | |
| Download: ML12269A690 (10) | |
Text
Davis-BesseNPEm Resource From: dorts@firstenergycorp.com Sent: Wednesday, July 11, 2012 3:35 PM To: Harris, Brian Cc: CuadradoDeJesus, Samuel; custerc@firstenergycorp.com
Subject:
FENOC Letter L-12-243 -- Response to Davis-Besse License Renewal RAI on Operating Experience Attachments: L-12-243 Amd 28 & RAI OE_Rev B.pdf Brian..... attached is a copy of FENOC Letter L-12-243 providing the response to the NRC request for additional information related to Operating Experience for Davis-Besse License Renewal, and Amendment 28 to the License Renewal Application.
Should you have questions regarding the attached letter, please contact Cliff Custer or me.
Thank you,
_____
Steve Dort Davis-Besse License Renewal
The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately, and delete the original message.
1
Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 3899 Mail Envelope Properties (OFB1817AA3.8E8226CE-ON85257A38.006B088A-85257A38.006B912B)
Subject:
FENOC Letter L-12-243 -- Response to Davis-Besse License Renewal RAI on Operating Experience Sent Date: 7/11/2012 3:34:55 PM Received Date: 7/11/2012 3:35:06 PM From: dorts@firstenergycorp.com Created By: dorts@firstenergycorp.com Recipients:
"CuadradoDeJesus, Samuel" <Samuel.CuadradoDeJesus@nrc.gov>
Tracking Status: None "custerc@firstenergycorp.com" <custerc@firstenergycorp.com>
Tracking Status: None "Harris, Brian" <Brian.Harris2@nrc.gov>
Tracking Status: None Post Office: FirstEnergyCorp.com Files Size Date & Time MESSAGE 989 7/11/2012 3:35:06 PM L-12-243 Amd 28 & RAI OE_Rev B.pdf 52006 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Davis-Besse Nuclear Power Station, Unit No. 1 L-12-243 Page 2
Attachment:
Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application, Section B.1.4
Enclosure:
Amendment No. 28 to the Davis-Besse License Renewal Application cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board
Attachment L-12-243 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),
License Renewal Application, Section B.1.4 Page 1 of 3 Section B.1.4 Question RAI B.1.4-4
Background:
In request for additional information (RAI) B.1.4-1, issued on May 19, 2011, the staff asked the applicant to describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and as necessary, enhance the aging management programs (AMPs) or develop new AMPs for license renewal. After reviewing the applicants response dated June 24, 2011, the staff issued follow-up RAI B.1.4-2, requesting specific details to the applicants Operating Experience Program (OEP). In its response dated March 9, 2012, the applicant provided further details about its program.
On March 16, 2012, the NRC issued LR-ISG-2011-05, Ongoing Review of Operating Experience to clarify the staffs position that license renewal AMPs should be informed, and enhanced when necessary, based on the ongoing review of both plant-specific and industry operating experience.
Issue:
In reviewing aspects of the applicants program against the guidance set forth in LR-ISG-2011-05, the staff needs further clarification regarding training.
Request:
Where the applicant states in the LRA Section A.1 that personnel responsible for screening, evaluating and submitting ... age-related operating experience items are qualified for the task, the staff is not clear what qualified for the task implies. In addition, the applicants response to RAI B.1.4-2(e) is not clear in establishing the stated goals of the needs analysis for personnel training as it relates to age-related operating experience and maintenance of AMPs. Please provide updates to LRA Section A.1 and further clarification to your description regarding training related to operating experience, consistent with the guidance in LR-ISG-2011-05.
Attachment L-12-243 Page 2 of 3 RESPONSE RAI B.1.4-4 The following information is derived from the training procedures and activities performed by FirstEnergy Nuclear Operating Company (FENOC) using the Systematic Approach to Training (SAT) processes published by the Institute of Nuclear Power Operations (INPO) National Academy for Nuclear Training.
Meaning of the term qualified for the task The term qualified for the task has a specific meaning at FirstEnergy Nuclear Operating Company (FENOC). Qualified is defined in company training procedures as:
The characteristics or abilities gained through education, experience, or training, as measured against established standards, that enable an individual to independently perform a required function. Qualification is synonymous with completion of a training activity or activities.
FENOC personnel are required to complete specific training activities in accordance with FENOC training procedures to achieve qualification for position-specific job functions at Davis-Besse. Upon completion of the requisite training activities, qualifications are posted in an electronic qualification matrix.
Goals of the needs analysis The Systematic Approach to Training process employed by FENOC includes the use of a needs analysis to determine training needs for a given position-specific job function.
The needs analysis includes an evaluation of each job task to identify the training necessary to ensure individuals in a given position have the required knowledge and skills for independent performance of the job tasks. The needs analysis is used with applicable job and task analysis as part of the Systematic Approach to Training process to determine the topics, content and frequency of training necessary to train personnel and document that an individual is qualified for the task.
With respect to age-related operating experience and maintenance of aging management programs, the needs analysis will result in new training materials or modifications to existing training materials for those positions responsible for screening, evaluating, and submitting age-related operating experience items, and implementing changes to aging management programs.
Attachment L-12-243 Page 3 of 3 LRA Section A.1, Summary Descriptions of Aging Management Programs and Activities, Operating Experience subsection, is revised to include clarification in the description regarding training related to operating experience, and to better align the FENOC Operating Experience Program summary with License Renewal Interim Staff Guidance LR-ISG-2011-05, Ongoing Review of Operating Experience.
See the Enclosure to this letter for the revision to the Davis-Besse LRA.
Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)
Letter L-12-243 Amendment No. 28 to the Davis-Besse License Renewal Application Page 1 of 3 License Renewal Application Section Affected Section A.1 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected LRA Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text lined-out and added text underlined.
Enclosure L-12-243 Page 2 of 3 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1 Page A-9 3rd paragraph, and 1st bullet In response to RAI B.1.4-4, the third paragraph and the first bulleted item of LRA Section A.1, Summary Descriptions of Aging Management Programs and Activities, previously added by FENOC letter dated March 9, 2012 (ML12094A383), are revised to read as follows:
Operating Experience The intent of evaluating and incorporating operating experience lessons-learned, including aging-related lessons-learned, is prevention. The lessons-learned are used to improve plant operation, equipment material condition, and aging management to minimize equipment degradation and prevent loss of equipment intended functions. Operating experience from plant-specific and industry sources is captured and systematically reviewed on an ongoing basis in accordance with the quality assurance program, which meets the requirements of 10 CFR Part 50, Appendix B, and the operating experience program, which meets the requirements of NUREG-0737, Clarification of TMI Action Plan Requirements, Item I.C.5, Procedures for Feedback of Operating Experience to Plant Staff. The operating experience program interfaces with and relies on active participation in the Institute of Nuclear Power Operations operating experience program, as endorsed by the NRC. The FENOC Operating Experience Program processes and procedures for the ongoing review of operating experience include the following attributes:
x Personnel responsible for screening, evaluating and submitting (to the industry) aging-related operating experience items are qualified for the task. Training on age-related degradation and aging management is provided to those personnel responsible for implementing aging management programs and who may submit, screen, assign, evaluate, or otherwise process plant-specific and industry operating experience to ensure they are qualified for the task. This training is to occur on the frequency determined by FENOC training procedures and processes, and includes provisions to accommodate the turnover of plant personnel.
x While the programs and procedures may specify reviews of certain sources of information, such as NRC generic communications and Institute of Nuclear Power Operations reports, they allow for any potential source of relevant plant-specific or industry operating experience information.
Enclosure L-12-243 Page 3 of 3 x The processes are adequate so as to not preclude the consideration of operating experience related to aging management. The processes allow for appropriately gathering information on structures and passive components within the scope of license renewal, their materials, environments, aging effects, and aging mechanisms, and the aging management programs credited for managing the effects of aging, including the activities under these programs (e.g., inspection methods, preventive actions or evaluation techniques).
x Plant-specific operating experience, including aging-related operating experience, is documented in condition reports and processed using the FENOC Corrective Action Program. Condition reports for adverse conditions and related documents captured in the Corrective Action Program database are quality records and are auditable and retrievable.
x Industry operating experience, including aging-related operating experience, is entered into the Operating Experience Program database and screened for applicability to FENOC. Documents captured in the Operating Experience Program database are retrievable.
x Evaluations of internal and external aging-related operating experience issues associated with structures and passive components include consideration of the affected structure or component, material, environment, aging effect, aging mechanism, and aging management program, with feedback to the affected aging management program owner for consideration of the impact to aging management program effectiveness.
x Aging management program owners review data collected by program activities, use the Corrective Action Program to document adverse conditions to ensure they will be addressed and corrected, maintain required records for the program, maintain the program current, and implement revisions as needed based on program results and internal or external operating experience evaluations. Revision of existing or development of new aging management programs based on operating experience evaluations is performed through corrective actions using the Corrective Action Program, or by action items identified in the Operating Experience Program database.
x Noteworthy plant-specific aging-related operating experience is shared with the other FENOC sites and the industry. The Operating Experience Program procedure provides guidance on sharing internal operating experience.