L-09-037, Action Required by Confirmatory Orderea 07-199
| ML090850053 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse, Perry |
| Issue date: | 03/13/2009 |
| From: | Hagan J FirstEnergy Nuclear Operating Co |
| To: | Carpenter C NRC/OE |
| References | |
| EA-07-199, L-09-037 | |
| Download: ML090850053 (5) | |
Text
FENOCF76 South Main Street FirstEnergy Nuclear Operating Company Akron, Ohio 44308 Joseph J. Hagan 330-761-7895 President and Chief Nuclear Officer Fax: 330-384-5669 March 13, 2009 L-09-037 10 CFR 2.202 ATTN: Ms. Cynthia A. Carpenter Director, Office of Enforcement United States Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 Docket Nos. 50-334 and 50-412, License Nos. DPR-66 and NPF-73 Davis-Besse Nuclear Power Station, Docket No. 50-346, License No.!NPF-3 PerryNuclear Power Plant-':.
Docket No., 50-440,. License -No. NPF-58 Action Required by Confirmatory OrderEA 07-199 By letter dated August 15,: 2007, the NUclear Regulatory Commission (NRC) issued a Confirmatory Order (Order) to'the FirstEnergy Nuclear*OperatingCompany (FENOC) to formalize commitments made by FENOC following the NRC issuance of a Demand for Information (DFI) on May 14, 2007. In addition to the commitments made by FENOC in response to the DFI in letters dated June 13, 2007 and July 16, 2007, the Order contains requirements to provide letters to the Director, NRC Office of Enforcement, prior to implementation and following completion of selected commitments.
Item 2 of Section IV of the Order required a follow-up effectiveness review in January 2009 to determine if an appropriate level of regulatory sensitivity is evident among FirstEnergy employees. The follow-up effectiveness review was completed on January 22, 2009 and the final report was issued on February 25, 2009. In accordance with the Order, FENOC is required to providethe Director, NRC Office of Enforcement, with a summary of the,results of the, effectiveness review and a description of any actions taken orplanned in response.to the results.
The attachment to this letter contains a summary of the results of the follow-up effectiveness review, which was provided by team lead Mr. John M. Griffin, President of
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-09-037 Page 2 The Kestrel Group, Inc. The attachment also contains a description of the actions taken or planned in response to the results of the assessment.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Gregory H. Halnon, Director - Fleet Regulatory Affairs at 330-384-5638.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March f__, 2009.
Sincerely, Joseph J. Hagan
Attachment:
Summary of 2009 Follow-up Effectiveness Review of FirstEnergy/FENOC Regulatory Sensitivity Training cc: Document Control Desk Assistant General Counsel for Materials Litigation and Enforcement NRC Region I Administrator NRC Region Ill Administrator NRC Resident Inspector - Beaver Valley NRC Resident Inspector - Davis-Besse NRC Resident Inspector - Perry NRC Project Manager - Beaver Valley NRC Project Manager - Davis-Besse NRC Project Manager - Perry Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board
Attachment L-09-037 Summary of 2009 Follow-up Effectiveness Review of FirstEnergy/FENOC Regulatory Sensitivity Training Page 1 of 2 Summary of the Results of the Follow-up Effectiveness Review On August 15, 2007 the Nuclear Regulatory Commission (NRC) issued Confirmatory Order EA 07-199 to FirstEnergy Nuclear Operating Company (FENOC). The Confirmatory Order required FENOC to conduct regulatory sensitivity training and to have effectiveness reviews of the training performed by an external consultant during January 2008 and January 2009.
The regulatory sensitivity training was conducted in several training sessions in 2007.
The Team Leader and the Project Manager observed one of the training sessions in 2007. The effectiveness review for 2008 was held January 10-18, 2008 and the follow-up effectiveness review was held January 19-22, 2009.
The effectiveness review was performed by an external consultant with support from two industry peers and a FENOC project manager.
The effectiveness review team reviewed documentation pertaining to the regulatory sensitivity training conducted in October and November 2007, refresher training that was conducted in 2008, and regulatory sensitivity training that was conducted for employees who were new to their positions in 2008. The team also reviewed documentation of the eleven (11) issues that had been evaluated for regulatory impact using a FENOC Business Practice entitled "Regulatory Impact Assessment Process."
The team conducted sixty (60) structured interviews with FirstEnergy employees to evaluate their retention and understanding of the material provided in the regulatory sensitivity training.
The 2009 effectiveness review team concluded that the FENOC and non-FENOC FirstEnergy employees interviewed generally had a sensitivity to issues with a potential for regulatory interest, understood their responsibility to identify the issues for regulatory evaluation and described avenues available to them to ensure these issues were properly evaluated. The team identified to FENOC senior management five employees who would benefit from additional regulatory sensitivity training.
Several positive noteworthy items were identified by the team. The most relevant of these are:
The cooperation of FirstEnergy employees shown to the effectiveness review team, both when scheduling the interviews in advance of the review and during the structured interviews, was outstanding.
Attachment L-09-037 Page 2 of 2 The Noteworthy Items from the 2008 Effectiveness Review Report were appropriately addressed by FENOC.
The follow-up effectiveness review team was impressed with the overwhelming positive reaction to the regulatory sensitivity training. Not a single employee interviewed had a negative comment about the training.
Actions Taken or Planned In addition to the above noteworthy items, the effectiveness review team identified several other items, for which the following actions have been taken or are planned:
" The team suggested that FENOC evaluate the need for additional regulatory sensitivity training for five individuals identified during the evaluation who the team felt would benefit from this training. FENOC Regulatory Affairs will evaluate the extent of training needed on a case by case basis and provide it to these individuals.
- The team noted that FENOC had performed a review to determine which employees new to their position should receive regulatory sensitivity training during 2008. However, not all of the employees identified had received the training; therefore the team encouraged that the training be completed for the identified employees..Training has been completed for all but one of the identified individuals. The remaining individual will be provided with regulatory sensitivity training after his outage assignment is complete.
The team suggested that FENOC consider including a discussion of regulatory sensitivity in new employee and new supervisor training (Leadership Academy).
FENOC Regulatory Affairs is evaluating the most effective method to include a discussion of regulatory sensitivity in new employee and new supervisor training.
TA FENOC 76 South Main Street Akron, Ohio 44308 FirstEnergy Nuclear Operating Company TEMP-RETURN g
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$ 00.346 03113i 209 Mailed From 44308 US POSTAGE Ms. Cynthia A. Carpenter Director, Office of Enforcement United States Nuclear Regulatory Commission Washington, DC 20555-0001 G0-925.2 AARW~i 0s1