ML071030446
| ML071030446 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/12/2007 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Caldwell J NRC/RGN-III |
| References | |
| 1-1492 | |
| Download: ML071030446 (13) | |
Text
. FENOC - FirstEnergy Nuclear Operating Company 550 7 Norlh Sta!e Rode 2 Oak Harbor Ohlo 43339 Mark 6. 6ezrlla Vice Presdenl - Nuclear 3 79-32 7 - 7676 Fax 41.9-327-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1492 April 12, 2007 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission, Region I11 2443 Warrenville Road, Suite 21 0 Lisle, IL 60532-4352
Subject:
Submittal of Revision 1 - 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 Revision 1 to the assessment plan and related information for the 2007 independent assessment of the Davis-Besse Nuclear Power Station (DBNPS) Operations Performance.
The original 2007 Operations Performance Independent Assessment Plan was submitted on March 13,2007, via DBNPS letter Serial Number 1-1489.
In accordance with 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," (DBNPS letter Log Number 1-4524) the FirstEnergy Nuclear Operating Company (FENOC) is submitting Kevision 1 to the Operations Performance Independent Assessment Plan, including the identification and qualifications of the assessors for the DBNPS. This Operations Performance Independent Assessment Plan, Revision 1 is being submitted to identify and provide the qualifications for an independent industry peer as an additional team member, as committed in DBNPS letter Serial Number 1-1489.
The onsite portion of the assessment remains 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. RECEIVF'~
APR 1 3 2007 Docket Number 50-346 License Number NPF-3 Serial Number 1-1492 Page 2 of 2 Changes to the Operations Performance Independent Assessment Plan (Enclosure 1 ) and the assessors' biographies (Enclosure
- 2) are identified with a revision bar in the right hand margin.
This revision of the Operations Performance Independent Assessment Plan and the attached biographies supercedes the original submittal in its entirety.
If you have any questions or require fbrther information, please contact Mr. Dale R.
Wuokko, Acting Manager - Regulatory Compliance, at (41 9) 32 1-7 120. LJS J Attachment 1 - Commitment List Enclosure 1 - Enclosure 2 - Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Plan, Revision 1 Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Assessors and Qualifications, Revision 1 cc: USNRC Document Control Desk DB-1 NRC/NRR Project Manager DB- 1 Senior Resident Inspector Utility Radiological Safety Board Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1492 Attachment 1 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company's (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 (41 9-32 1 - 7 120) at the DBNPS of any questions regarding this document or associated regulatory commitments.
COMMITMENTS DUE DATE None NIA Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1492 Enclosure 1 Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Plan, Revision 1 (5 pages to follow)
OPERATIONS PERFORMANCE INDEPENDENT ASSESSMENT PLAN FOR Revision 1 THE DAVIS-BESSE NUCLEAR POWER STATION - 2007 NUMBER: COIA-OP s -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 Modifjmg 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 year's Operations Performance with that observed during the 2006 assessment.
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 a 0 0 e e e e e e e e 0 e e Shift turnover; Control manipulations; Communications, including management's expectations in accordance with the Conduct of Operations Procedure; Interdepartmental interfaces; Procedural use; Operations Procedure revision backlog; Awareness of plant and equipment status and workarounds; Pre-job/activity briefings; Non-shift Operations management interface and oversight; On-shift personnel manning and scheduling, including implementation of the Davis-Besse Nuclear Power Station Operations Long Range Staffing Plan, dated July 2006; Shift management command and control; Shift management's evaluation, prioritization, and disposition of maintenance activities and em ergen t issues
- Operations behaviors in the areas of questioning attitude and safety; Shift handling of off-normal operations; Observation of operator simulator training to compare crew performance, demeanor, and communication skills with actual control room operations.
Page 1 of 5 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-Besse's implementation of reactivity management during plant evolutions.
The Assessment Team will also evaluate the effectiveness of the Davis-Besse Nuclear Power Station's 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 0 0 Larry E, Briggs, Independent Consultant to Silver Fox Synergies, LLC, Team Leader Paul H. Bissett, Independent Consultant to Silver Fox Synergies, LLC William B. Carsky, Director-Operations, Three Mile Island -Independent Industry Peer Biographies attached.
Page 2 of 5 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.
April 12,2007: Submit revised assessment plan identifjmg independent industry peer. I 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) backshifis, 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.
Page 3 of5 ASSESSMENT METHODS (cont.): 5. Observation of simulator training during routine and abnormal operating conditions using NUREG- 102 1 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-Besse's Operations' department implementation of reactivity management during plant evolutions.
REFERENCES:
DB-OP-00000, "Conduct of Operations DB-OP-00004, "Operator Aids Control" DB-OP-00006, "Night Orders and Standing Order Log" DB-OP-00016, "Temporary Configuration Control" DB-OP-000 1 8, "Inoperable Equipment Tracking Log" DB-OP-00200, "Shift Engineer" DB-OP-0 1002, "Component Operation and Verification" DB-OP-0 1003, "Operations Procedure Use Instructions" DB-OP-0 1200, "Reactor Coolant Leakage Management" NOP-WM-0001, "Work Management Process" NOP-OP-1009, "Immediate and Prompt Operability Determination" NOP-WM-2001, "Work Management Scheduling/Assessment/Seasonal Readiness Processes" NOP-LP-2001, "Corrective Action Program" NOP-OP- 1002, "Conduct of Operations" NOP-OP- 1004, "Reactivity Management" NOPL-OP-01002, "Reactivity Management" NOBP-LP-2604, "Effective Job Briefs" Work Process Guideline (WPG) - 2, "Operation's Equipment Issues" NRC Inspection Procedure (IP) 7 171 5, "Sustained Control Room and Plant Observation" NRC IP 7 1707, "Plant Operations" NRC IP 93802, "Operational Safety Team Inspection (OSTI)"
NRC IP 93 806, "Operations Readiness Assessment Team Inspections" DBNPS Operations Long Range Staffing Plan, July 2006 An index of Condition Reports, sorted for Operations Department involvement, June 24,2006 through May 1,2007 The "Work Week Schedule" for the on-site assessment weeks The licensed operator on-shift schedule for the on-site assessment weeks The licensed operator training schedule for the on-site assessment weeks Last three Quality Assurance quarterly assessments Applicable recent internal Operations self-assessments Applicable Company Nuclear Review Board minutes fkom last three CNRB intervals Page 4 of 5 ASSESSMENT PLAN APPROVALS:
Date: 4b0lOy Page 5 of5 Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1492 Enclosure 2 Davis-Besse Nuclear Power Station Operations Performance Independent Assessment Assessors and Qualifications, Revision 1 (3 pages to 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 Perry Nuclear Power Plant. 2001 - Onsite Inc.; Senior Consultant - Developed NRC written examination for the Oyster Creek Facility (May 2002 examination).
1977 - 200 1 : U. S. Nuclear Regulatory Commission (NRC); Held various positions with the NRC. Duties included: 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.
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.
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.
1960 - 1972: U. S. Navy; Leading CPO (USS Whale SSN 638) for Reactor Control Division.
Leading In-hull instructor/Reactor Control Division Officer on D1 G Prototype. Engineering Office of the Watch (EOOW) qualified on DIG Prototype.
Qualified on S3G Prototype, S2Wa, and S5W Navy power plants.
0 0 0 0 0 Page 1 of 1 Paul Bissett Independent Consultant Silver Fox Synergies, LLC 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.
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.
2004 - Performance, Safety
& Health Associates, Inc.; Independent Consultant - Assisted in the conduct of Licensed Operator audit examinations at the St. Lucie Nuclear Power Plant.
1989-2003:
U. S. Nuclear Regulatory Commission (NRC); Senior Operations Engineer (Chief License Examiner/Inspector) - Certified Chief Examiner on Babcock and Wilcox (1 990), Westinghouse (1 988) and General Electric (1 999) 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. 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 licensee's 10 year In-service Test program submittal. Responsible for the review of licensee QA plan submittals and subsequent inspection of licensee QNQC programs.
1977-1 982: 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.
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.
0 0 0 Page 1 of 1 William B. Carsky Operations Director Three Mile Island Unit 1 2006 to Present: Exelon, Three Mile Island Unit I 1998 - 2006: Exelon, Clinton Power Station o June 2006 - present: Operations Director o May 2004 - June 2006: Shift Operations Superintendent. Supervised the Station Shift Managers.
o 2003 - 2004: Shift Manager on shift. o 2002 - 2004: Control Room Supervisor on shift, provided direction to plant operators in response to normal, abnormal, and emergency conditions. Acted to ensure compliance with licensing requirements and ensure to ensure the safe operation of the unit or equipment to protect the health and safety of the public and the environment.
1998 - 2001: Manager (Various), recruited for an eight member team to restart Clinton Power Station. Implemented organizational, programmatic, and plant improvements necessary for the May 1999 restart of the plant. During this time, executed key management positions including Design Engineering Director, Plant Engineering Director, and Instrument Maintenance Director. During these assignments, drew on peers and experts in implementing the following initiatives:
o . Implemented workforce training program improvements including an Integrated Plant Operations Course to improve support staff responsiveness to Operations and redesigned Engineering Continuing Training to foster a self-critical, continuous learning culture. Implemented incentivized backlog reduction programs.
Implemented plant material condition management tools. . 1996 - 1997: Exelon, Corporate Headquarters o MechanicalKivil Engineering Branch Manager.
Led a large highly technical engineering team in support of PECO Nuclear power plants.
Led the team to high levels of emergent issue esolution through close communication with plant staffs, regulators, and experts. Delegated project responsibilities including equipment upgrades and component management programs. . . . Recruited industry technical experts to complete the team. Implemented new training/qualification programs for Technical Experts. Implemented an outage support team of technical experts. Developed strategies to manage generation threats from such issues as containment penetration over-pressurization, inadequate Emergency Core Cooling System (ECCS) pump Net Positive Suction Head (NPSH), strainer clogging, and steam line resonance.
Closed the regulatory driven Motor Operated Valve (MOV) Program. . 1987 - 1996: Exelon, Peach Bottom Atomic Power Station. o Staff Engineer in Maintenance, Work Control, and Engineering. . Implemented margin improvement strategies for all valve types. . Implemented an integrated scheduling process. Implemented maintenance efficiency strategies. . Implemented and Asbestos Management program. 1987: Graduated from Rensselaer Polytechnic Institute with a Bachelor of Science Mechanical Engineering Page 1 of 1