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May 17, 2012 William J. Froehlich, Chair Nicholas G. Trikouros Dr

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May 17, 2012 William J. Froehlich, Chair Nicholas G. Trikouros Dr Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Tel. 202.739.3000 Fax: 202.739.3001 www.morganlewis.com Timothy P. Matthews Partner 202.739.5527 [email protected] May 17, 2012 William J. Froehlich, Chair Nicholas G. Trikouros Dr. William E. Kastenberg Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket: FirstEnergy Nuclear Operating Company, Davis-Besse Nuclear Power Station, Unit 1, Docket No. 50-346-LR Re: Notification of Filing Related to Proposed Shield Building Cracking Contention Dear Licensing Board Members: The purpose of this letter is to provide notification that FirstEnergy Nuclear Operating Company (FENOC), applicant in this proceeding, sent the enclosed letter to the Nuclear Regulatory Commission (NRC) on May 16, 2012, attached to which is FENOC’s Revision 1 of the Root Cause Analysis Report (Report) for the cracking first identified in the Davis-Besse Shield Building in October 2011. FENOC is notifying the Board of the enclosed letter because it is relevant to the proposed contention that was filed by Intervenors on January 10, 2012 in this proceeding. This document is a revision to the February 27, 2012 version of the Report, which FENOC provided to the Board in a February 29, 2012 notification. The revisions are identified and discussed in a Revision Summary on pages 5-7 of the Report and are identified by italics throughout the Report. The revisions include additional or clarifying information in response to observations made during a recent NRC inspection of the Report. The revisions do not invalidate the methodology, assessment and analysis, or conclusions of the Report. Atomic Safety and Licensing Board May 17, 2012 Page 2 Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d) Signed (electronically) by Timothy P. Matthews Timothy P. Matthews Counsel for FENOC Enclosure cc: Service List Table of Contents _____________________________________________________________________ Table of Contents ...................................................................................................................... 2 List of Acronyms ........................................................................................................................ 4 Revision Summary .................................................................................................................... 5 1 Abstract ................................................................................................................................. 8 2 Introduction.......................................................................................................................... 11 2.1 Problem Statement ................................................................................................ 11 2.2 Consequences ....................................................................................................... 11 2.3 Self-Identification Information................................................................................. 11 2.4 Root Cause Team Members.................................................................................. 11 3 Data Analysis....................................................................................................................... 13 3.1 Methodology .......................................................................................................... 13 3.2 Sequence of Events............................................................................................... 14 3.3 Discussion.............................................................................................................. 15 3.3.1 Initial Problem Solving ......................................................................................... 18 3.3.2 Impulse Response Testing and Core Bores......................................................... 19 3.3.3 Petrographic and Destructive Examination .......................................................... 24 3.3.4 Surface Examination............................................................................................ 29 3.3.5 Design.................................................................................................................. 32 3.3.6 Construction......................................................................................................... 37 3.3.7 Operational Phase ............................................................................................... 41 3.3.8 Shield Building Modeling and Analysis................................................................. 45 3.3.9 Failure Modes Analysis........................................................................................ 50 3.3.10 Hardware Disposition......................................................................................... 53 4 Safety Culture Evaluation ....................................................................................................54 5 Latent Organizational Weakness Evaluation ....................................................................... 55 6 Generic Implications ............................................................................................................ 56 6.1 Plant and Industry Experience ............................................................................... 56 6.2 Extent of Condition................................................................................................. 59 6.3 Extent of Cause ..................................................................................................... 60 Root Cause Analysis Report, CR 2011-03346 Table of Contents Page 2 6.4 Data Analysis Conclusions...................................................................................... 61 7 Root and Contributing Causes............................................................................................. 64 8 Corrective Action Plan ......................................................................................................... 66 9 Effectiveness Review Plan .................................................................................................. 72 10 References ......................................................................................................................... 73 10.1 Developmental References................................................................................... 73 10.2 Other References.................................................................................................. 75 11 Attachments........................................................................................................................ 77 Attachment 1, Shield Building Exterior Developed Elevation ........................................ 78 Attachment 2, Shield Building Impulse Response Average Mobility Values ................. 79 Attachment 3, Shield Building Core Bore Summary...................................................... 80 Attachment 4, Shield Building Concrete Material Properties......................................... 84 Attachment 5, Shield Building Surface Visual Inspection History.................................. 85 Attachment 6, Shield Building Milestones ..................................................................... 86 Attachment 7, Shield Building Slip-Form Construction Sequence................................. 89 Attachment 8, Shield Building Concrete Compression Test Results............................. 93 Attachment 9, Shield Building Concrete Mixes ............................................................. 94 Attachment 10, Shield Building Construction Deviations .............................................. 95 Attachment 11, Fault Tree ............................................................................................ 99 Attachment 12, Failure Modes Analysis...................................................................... 100 Attachment 13, Change Analysis................................................................................ 119 Attachment 14, Barrier Analysis.................................................................................. 120 Attachment 15, Event and Causal Factors Chart........................................................ 121 Attachment 16, Generic Implications Matrix................................................................ 122 Attachment 17, Corrective Action Matrix..................................................................... 123 Root Cause Analysis Report, CR 2011-03346 Table of Contents Page 3 List of Acronyms _____________________________________________________________________ ACI American Concrete Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials CANDU Canadian deuterium uranium nuclear plants CARB Corrective Action Review Board CF Causal Factor CFD Computational Fluid Dynamics CR Condition Report CTE Coefficient of thermal expansion CTL Construction Technology Laboratory DCM Design Criteria Manual DBNPS Davis-Besse Nuclear Power Station ECP Engineering Change Package EDG Emergency Diesel Generator EPRI Electric Power Research Institute F Fahrenheit FEA Finite Element Analysis FENOC FirstEnergy Nuclear Operating Company FM Failure Mode FMA Failure Modes Analysis IAEA International Atomic Energy Agency INPO Institute of Nuclear Power Operations IR Impulse Response NRC Nuclear Regulatory Commission PCAQ Potential Condition Adverse to Quality report PII Performance Improvement 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