See Beaver Valley responses below in Red

Anthony (A.R.) Burger
Supervisor, Reactor Engineering
FENOC - Beaver Valley Power Station
Phone: (724) 682-4108
Cell: (724) 601-3224
FAX: (724) 682-4250
Email: aburger@firstenergycorp.com

From: "Kelliher, Andrew P" <Andrew.Kelliher@cengllc.com>
To: "pwrrm@retaqs.com" <pwrrm@retaqs.com>
Cc: "Knowles, Justin W" <Justin.Knowles@cengllc.com>, "Brown, Kenneth" <Kenneth.Brown@cengllc.com>, "Hellems, Ryan T" <Ryan.Hellems@cengllc.com>
Date: 01/16/2012 07:49 AM
Subject: [Pwrrm] Foreign Material Exclusion (FME) in the Spent Fuel Pool (SFP)
Sent by: pwrrm@retaqs.com

R.E. Ginna is working to improve our practices related to FME around the SFP. We have developed the following questions:

What FME controls are in place for work around the SFP? Is there a project plan or FME plan in place?
Response - The SFP is considered a High Risk FME Area (FMEA) per INPO 07-008,Guidelines for Achieving Excellence in FME. For large projects such as Refueling, Fuel Inspections, or our current Rerack there is a specific FME Plan in place. For normal maintenance activities, personnel would follow the guidance provided in the site FME procedure for a FMEA.

Does your SFP have legacy foreign material (FM) in it?
Response - Yes

If you have legacy FM, do you have a plan established to recover it long term?
Response - Yes. As an example, a year ago a lens gap from a plastic weir gate pressure gage fell into the SFP. We know its approximate location and during the current Rerack we will attempt to retrieve when we move those assemblies.

How do you document and track FM in the SFP?
Response - A few years ago we started a Non-SNM tracking program and we include FM in that system. This log is maintained by Reactor Engineering.

If you discover FM during the performance of other work, do you stop all work to recover FM, or proceed as long as you will not impact that location?
Response - It would depend on the FME Plan. If the item is immediately retrievable then it could be retrieved. If not immediately retrievable then work would be stopped and an FME Recovery Plan developed.

When recovering foreign material FM, do you have station personnel or contractors perform the work?
Response - In most instances it has been the fuel vendor.

What tools/methods do you use to recover FM in the SFP?
Response - Air-operated vise grips, LUVS (Light Underwater Vacuum System), or regulare tri-nuke vacuum with suction hose.

Your response to any of the questions above will be much appreciated. Also, if you have a good procedure, project plan or FME plan that controls work around the spent fuel pool please forward it to me.

Thank you,
Andy

Andrew Kelliher
Reactor Engineer
R.E. Ginna Nuclear Power Plant
Phone: (585) 771-3457

"I'm just sayin', I don't like fun." - Karl Pilkington

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