ML023260433

Senior Management Review of the Lessons Learned Report for Degradation of Davis-Besse Nuclear Power Station Reactor Pressure Vessel Head - Memo to Travers from Paperiello

ML023260433
Person / Time
Site:	Davis Besse
Issue date:	11/26/2002
From:	Paperiello C NRC/EDO
To:	Travers W NRC/EDO
Rosenberg S, 415-1733
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ML023260433	List: ML023260433
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Download: ML023260433 (26)

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November 26, 2002 MEMORANDUM TO: William D. Travers Executive Director for Operations FROM: Carl J. Paperiello /RA/

Deputy Executive Director for Materials, Research, and State Programs

SUBJECT:

SENIOR MANAGEMENT REVIEW OF THE LESSONS-LEARNED REPORT FOR THE DEGRADATION OF THE DAVIS-BESSE NUCLEAR POWER STATION REACTOR PRESSURE VESSEL HEAD

SUMMARY

The Senior Management Review Team (RT), established by your October 3, 2002 memorandum, has completed its review and evaluation of the Final Lessons-Learned Task Force (LLTF) Report for the Degradation of the Davis-Besse Nuclear Power Station Reactor Pressure Vessel Head. The RT generally agreed with the LLTF recommendations, with two exceptions, and integrated the agreed upon recommendations into four overarching categories.

Action plans and/or focused activities are being developed or proposed for each of these categories, which will address the LLTF recommendations. Proposed implementation time frames are provided for those activities determined to be the highest priority. The remaining lower priority activities should be integrated into the operational planning activities for the lead offices. The agencys Planning, Budgeting, and Performance Management (PBPM) process should be used to establish completion dates and to integrate the work into other agency priorities. If you decide to implement the proposed actions, the RT recommends that a semi-annual status review be performed to evaluate the progress of activities and determine whether periodic realignments are needed.

DISCUSSION The RT members acknowledge that the final report articulates the thorough, focused, and thoughtful efforts of the LLTF in accomplishing its chartered duties. The RT focused its efforts on reviewing and evaluating the LLTF report and integrating the individual recommendations into a consolidated matrix to effectively address the LLTF findings. Early in its review, the RT recognized that some of the specific recommendations would overlap in their implementation.

The RT viewed one of its tasks as individually reviewing each recommendation and discerning

Contact:

Stacey Rosenberg, EDO 301-415-1733

2 which of the recommendations could be combined to form a consolidated approach to implementation. Therefore, the RT grouped the recommendations into a matrix format with four overarching categories as discussed below. The matrix is provided as Attachment 1 and includes a prioritization of activities, time-frames for completion, and designation of the lead office responsible for coordinating the activities. The LLTF worked from 5 general operational and regulatory areas, which included a total of 18 detailed areas, to develop 51 specific recommendations to address matters related to the pressure vessel head degradation.

The RT evaluation centered on combining some of the LLTF recommendations that generally had the highest priority into a number of focused planned activities and action plans. The RT placed the highest priority on those recommendations that appeared to be more closely linked to the contributing causes that led to the Davis-Besse event, as well as actions needed to respond to the vessel head corrosion phenomenon. The remaining lower priority recommendations are expected to be integrated into the assigned office operational planning activities. The agencys PBPM process should be used to establish completion dates and to integrate the work into other agency priorities.

The RT recognized that several of the LLTF recommended actions are already underway or have previously been completed by the program offices. These items are identified as STATUS items in the RT Proposed Actions column of Attachment 1. The RT did not verify whether the current or completed actions fully satisfy the LLTF recommendations.

Consequently, the RT recommends that the lead program offices evaluate these actions against the LLTF recommendations to determine if those actions satisfy the recommendations.

In addition, the RT notes that NRR is coordinating the development of an action plan with a number of activities, particularly short-term activities, associated with those facilities affected with vessel head penetration nozzle cracking. This action plan is expected to incorporate the applicable recommendations from Attachment 1. Additional insights and recommendations may be forthcoming from other NRC reviews that are currently ongoing. These will be incorporated into the planned activities, as they become available.

The RT believes that the Attachment 1 planned activities can be grouped appropriately into one of four overarching categories, which encompass the LLTF Report recommendations. The specific activities contained in Attachment 1 were consolidated under each of these categories.

The proposed actions for addressing each of the LLTF recommendations have been prioritized, with the high priority items requiring focused attention and coordination, and the medium and low priority items relegated to the lead program offices for inclusion into their operational planning and PBPM activities.

1. Assessment of Stress Corrosion Cracking (eight LLTF recommendations)

The RT recommends that NRR lead the effort, with RES support, to develop an action plan to address the issue of nickel-based alloy nozzle susceptibility to stress corrosion cracking, including other susceptible components, and boric acid corrosion of carbon steel. This will implement LLTF recommendation 3.1.1(1).

The RT disagreed with LLTF 3.1.2(4) as noted in Attachment 1.

Five recommendations, LLTF 3.3.2(1), 3.2.2(1), 3.3.4(3), 3.3.4 (8), and 3.1.4(1) appear to be included in NRRs Vessel Head Penetration and Vessel Head Inspection Criteria Action Plan, currently under development. These recommendations should be managed within that plan.

3 The RT considers LLTF Item 3.3.7(6) is low priority and should be incorporated into NRRs operational planning, through PBPM.

2. Assessment of Operating Experience, Integration of Operating Experience into Training, and Review of Program Effectiveness. (seventeen LLTF recommendations)

The RT views seven LLTF recommendations, 3.1.6(1), 3.1.6(2), 3.1.6(3), 3.2.4(1),

3.3.4(2), 3.3.1(1), and 3.3.5(1), as one high priority action item. The RT recommends that NRR lead the effort with RES, the TTC, and the Regions supporting to develop an action plan to address these recommendations. The RT considers this action plan an important contributor to enhancing staff ability to respond to off-normal conditions.

The RT disagreed with LLTF Item 3.3.7(4) as noted in Attachment 1. However, the RTs dismissal of the recommendation does not preclude the review of any piece of technical literature by the staff in the normal course of maintaining professional awareness.

Nine LLTF recommendations of medium and low priority 3.1.2(1), 3.1.2(2), 3.2.3(1),

3.2.3(2), 3.1.2(5), 3.1.3(2), 3.1.2(3), 3.1.3(1), and 3.3.4(7) should be incorporated into the lead program office operational planning through PBPM.

3. Evaluation of Inspection, Assessment, and Project Management Guidance (nineteen LLTF recommendations)

The RT considers LLTF recommendations 3.2.5(2), 3.3.5(4), and 3.3.7(2) to be of high priority with a short implementation schedule. These items should be completed in time to be addressed in the FY 2005 budget preparation cycle. The RT recommends that NRR assess whether its modifications of Inspection Procedure (IP) 71152 address the LLTF recommendation 3.2.5(2).

The RT reviewed the LLTF recommendation on Appendix F regarding past lessons-learned reviews. The RT agreed that the scope of review should be the assessment of issues identified in Table F-1 of the LLTF Report to determine whether the recommendations from previous lessons-learned reviews have been adequately implemented.

Fifteen recommendations 3.3.4(5), 3.2.5(1), 3.3.1(2), 3.3.1(1), 3.3.7(1), 3.3.4(1),

3.3.4(4), 3.3.2(2), 3.3.2(3), 3.3.2(4), 3.3.3(2), 3.3.4(6), 3.3.5(2), 3.3.5(3), and 3.3.7(5) should be incorporated into NRRs operational planning through PBPM.

4. Assessment of the Barrier Integrity Requirements (seven LLTF Recommendations)

The RT views six of the LLTF recommendations as one high priority activity. These items include 3.2.1(1), 3.1.5(1), 3.2.1(2), 3.3.3(3), 3.2.1(3), and 3.3.4(9). The RT recommends that RES, leading the effort with the support of NRR, develop an action plan to define the scope of the effort and the resources required to assess Barrier Integrity Requirement.

The RT notes that RES has an ongoing program that should include LLTF recommendation 3.3.7(3). This should be reviewed to ensure this recommendation is sufficiently encompassed by this program.

4 Progress for individual activities under each category should be managed through individual office operational planning activities, which are reviewed quarterly. No resource estimates have been made for implementing individual activities. These estimates should be projected as each of the operational planning activities are developed for the overarching categories.

Many of the issues identified in the LLTF report have implications affecting other NRC programs. Although NMSS was not explicitly tasked with activities from the LLTF recommendations, the Office developed an Assessment Plan for examining potential opportunities for improvement in program effectiveness. Attachment 2 provides the Assessment Plan developed by NMSS, which prioritizes the LLTF recommendations for completion of expected follow-on activities. NMSS is proposing to reprogram its resources for implementing the Assessment Plan and operational planning using PBPM.

Attachments:

1. RT Matrix

2. NMSS Assessment Plan

4 The RT notes that RES has an ongoing program that should include LLTF recommendation 3.3.7(3). This should be reviewed to ensure this recommendation is sufficiently encompassed by this program.

Progress for individual activities under each category should be managed through individual office operational planning activities, which are reviewed quarterly. No resource estimates have been made for implementing individual activities. These estimates should be projected as each of the operational planning activities are developed for the overarching categories.

Many of the issues identified in the LLTF report have implications affecting other NRC programs. Although NMSS was not explicitly tasked with activities from the LLTF recommendations, the Office developed an Assessment Plan for examining potential opportunities for improvement in program effectiveness. Attachment 2 provides the Assessment Plan developed by NMSS, which prioritizes the LLTF recommendations for completion of expected follow-on activities. NMSS is proposing to reprogram its resources for implementing the Assessment Plan and operational planning using PBPM.

Attachments:

1. RT Matrix

2. NMSS Assessment Plan

• See previous concurrence ML023260433 DOCUMENT NAME: g:\Davis-B1.wpd To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE ROPMS* ROPMS* OGC* NRR* NMSS*

NAME MLayton SRosenberg JMoore via e-mail SCollins via e-mail MVirgilio via e-mail DATE 11/19/02 11/22/02 11/21/02 11/21/02 11/ 21/02 OFFICE RES* RIV* DEDMRS NAME AThadani via e-mail EMerschoff via fax CPaperiello DATE 11/20/02 11/20/02 11/26/02 OFFICIAL RECORD COPY

Review Team (RT) Matrix for Addressing Recommendations from the Davis-Besse Lessons Learned Task Force (LLTF)

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions

1. Assessment of Stress Corrosion Cracking 3.1.1(1) The NRC should assemble foreign and Yes High Long NRR (DE) The RT agrees with this domestic information concerning Alloy 600 and RES recommendation. The RT recommends (and other nickel based alloys) nozzle that NRR with RES support develop an cracking and boric acid corrosion from action plan to address this item.

technical studies, previous related generic communications, industry guidance, and STATUS: This item is addressed in an operational events. Following an analysis of action plan currently being developed by nickel based alloy nozzle susceptibility to NRR.

stress corrosion cracking (SCC), including other susceptible components, and boric acid corrosion of carbon steel, the NRC should propose a course of action and an implementation schedule to address the results.

1 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.1.2(4) The NRC should review industry No N/A N/A N/A The RT disagrees with this approaches used by licensees to consider recommendation. NRCs role is to economic factors involved with VHP nozzle establish regulatory requirements. New inspection and repair. This might include requirements must meet the provisions of conducting representative cost/benefit §50.109, and consider cost/benefit in analyses of non-visual inspections of VHP cases where requirements are not nozzles that would consider factors involving needed to ensure adequate protection of dose, cost, and time involved. The NRC the public or to comply with existing should consider this information in the regulations. Options around how formulation of future positions regarding the licensees implement NRC requirements performance of non-visual inspections of are prescribed in NRC guidance VHP nozzles. documents. Licensees may either elect to follow NRC guidance or choose alternative approaches, based on economic or other factors, as long as they meet the underlying requirements.

3.3.2(1) The NRC should develop inspection Yes High Long NRR(IIPB, The RT agrees with recommendations guidance for the periodic inspection of PWR DE) 3.3.2(1) and 3.2.2(1), and considers that plant boric acid corrosion control programs. these recommendations should be combined into one action.

2 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.2.2(1) The NRC should inspect the adequacy of Yes NRR (IIPB, STATUS: This item is addressed in an PWR plant boric acid corrosion control DE) and action plan currently being developed by programs, including their implementation RES NRR. The implementation of these effectiveness, to determine their activities has already begun thru Bulletin acceptability for the identification of boric 2002-01. A TI was written in conjunction acid leakage, and their acceptability to with Bulletin 2002-02. Upon completion ensure that adequate evaluations are of TI 2515/150 a review will be conducted performed for identified boric acid leaks. to decide if periodic inspection guidance in this area is warranted. RES to work with ASME to address code improvements for boric acid corrosion.

3.3.4(3) The NRC should develop inspection Yes High Long NRR (IIPB, The RT agrees with this guidance or revise existing guidance, such DE) recommendation. ALARA should also be as IP 71111.08, to ensure that VHP nozzles considered when the guidance is revised.

and the RPV head area are periodically reviewed by the NRC during licensee ISI STATUS: This item is addressed in an activities. Such NRC inspections could be action plan currently being developed to accomplished by direct observation, remote address this overarching area. This effort video observation, or by the review of has already begun with a TI issued.

videotapes. General guidance pertaining to Following the completion of the TI a boric acid corrosion observations should be review will be conducted to decide included in IP 71111.08. whether periodic inspection guidance needs to be developed.

3 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.4(8) The NRC should encourage ASME Code Yes High Long RES and The RT agrees with this requirement changes for bare metal NRR(DE) recommendation.

inspections of nickel based alloy nozzles for which the code does not require the removal STATUS: This activity is currently being of insulation for inspections. The NRC performed. This item will be addressed in should also encourage ASME Code an action plan currently being developed.

requirement changes for the conduct of non-visual NDE inspections of VHP nozzles.

Alternatively, the NRC should revise 10 CFR 50.55a to address these areas.

3.1.4(1) The NRC should determine if it is Yes Medium PBPM RES and The RT agrees with this appropriate to continue using the existing NRR (DE) recommendation.

SCC models as a predictor of VHP nozzle PWSCC susceptibility given the apparent STATUS: This item is addressed in the large uncertainties associated with the action plan currently being developed.

models. The NRC should determine NRR should review the existing user whether additional analysis and testing are need to make sure it encompasses the needed to reduce uncertainties in these recommendation.

models relative to their continued application in regulatory decision making.

3.3.7(6) The NRC should determine whether ISI Yes Low PBPM NRR (DE, The RT agrees with this recommendation summary reports should be submitted to the DLPM) to perform an evaluation of the need to NRC, and revise the ASME submission submit ISI reports for review.

requirement and staff guidance regarding disposition of the reports, as appropriate.

4 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions

2. Assessment of Operating Experience, Integration of Operating Experience into Training, and Review of Program Effectiveness 3.1.6(1) The NRC should take the following steps to Yes High Long NRR The RT agrees with recommendations address the effectiveness of its programs (RORP) 3.1.6(1), 3.1.6(2), 3.1.6(3), 3.2.4(1),

involving the review of operating experience: lead with 3.3.4.(2), 3.3.1(1), and 3.3.5(1); and (1) evaluate the agencys capability to retain TTC, RES, considers that these recommendations operating experience information and to and should be combined into one activity.

perform longer-term operating experience REGIONS The RT recommends that NRR; with reviews; (2) evaluate thresholds, criteria, supporting RES, TTC, and the Regions supporting; and guidance for initiating generic develop an action plan to address these communications; (3) evaluate opportunities recommendations. This is a major effort for additional effectiveness and efficiency that will require an action plan to better gains stemming from changes in define the scope of this effort, coordinate organizational alignments (e.g., a responsibilities for the individual items centralized NRC operational experience and determine resource requirements.

clearing house); (4) evaluate the effectiveness of the Generic Issues Program; and (5) evaluate the effectiveness of the internal dissemination of operating experience to end users.

3.1.6(2) The NRC should update its operating Yes NRR experience guidance documents. (RORP) 3.1.6(3) The NRC should enhance the effectiveness Yes NRR of its processes for the collection, review, (RORP) assessment, storage, retrieval, and and RES dissemination of foreign operating experience.

5 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.2.4(1) The NRC should assess the scope and Yes NRR adequacy of its requirements governing (IQPB) licensee review of operating experience.

3.3.4(2) The NRC should strengthen its inspection Yes NRR (IIPB) guidance pertaining to the periodic review of operating experience. The level of effort should be changed, as appropriate, to be commensurate with the revised guidance.

3.3.1(1) The NRC should provide training and Yes NRR (IIPB) reinforce expectations to NRC managers lead with and staff members to address the following TTC and areas: (1) maintaining a questioning attitude REGIONS in the conduct of inspection activities; supporting (2) developing inspection insights stemming from the DBNPS event relative to symptoms and indications of RCS leakage; (3) communicating expectations regarding the inspection follow-up of the types of problems that occurred at DBNPS; and (4) maintaining an awareness of surroundings while conducting inspections.

Training requirements should be evaluated to include the appropriate mix of formal training and on-the-job training commensurate with experience.

Mechanisms should be established to perpetuate these training requirements.

6 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.5(1) The NRC should maintain its expertise in Yes NRR (IIPB) the subject areas by ensuring that NRC lead with inspector training includes: (1) boric acid TTC and corrosion effects and control; and (2) RES PWSCC of nickel based alloy nozzles. supporting 3.3.7(4) The NRC should revise the criteria for the No N/A N/A N/A The RT disagrees with this review of industry topical reports to allow for recommendation. NRC regulations NRC staff review of safety-significant reports included in Appendix B to 10 CFR Part 50 that have generic implications but have not and §50.59 prescribe processes for been formally submitted for NRC review in making changes to a nuclear power plant.

accordance with the existing criteria. These are designed, in part, to ensure changes that have more than a negligible impact on safety are reviewed by the NRC before they are implemented by the licensee. Topical Reports that are not submitted to the NRC in response to these requirements or other reporting requirements (e.g. Part 21, §50.73) are not formally reviewed today with the SER, nor can they be reviewed by the NRC in the future. It should be noted that review of industry research reports by RES may occur as part of its role of maintaining up-to-date understanding of technical issues and as part of planning and coordinating research activities.

7 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.1.2(1) The NRC should revise its processes to Yes Medium PBPM NRR The RT agrees with this require short-term and long-term follow-on (RORP recommendation.

verification of licensee actions to address and IIPB) significant generic communications (i.e.,

bulletins and GLs).

3.1.2(2) The NRC should establish review guidance Yes Medium PBPM NRR The RT agrees with recommendations for accepting owners group and industry (RPRP, 3.1.2(2), 3.2.3(1), and 3.2.3(2); and resolutions for generic communications and IIPB) considers that these recommendations generic issues. Such guidance should should be combined into one activity.

include provisions for verifying implementation of activities by individual owners groups and licensees.

3.2.3(1) The NRC should review a sample of NRC Yes NRR safety evaluations of owners group (DLPM, submissions to identify whether intended IIPB) actions that supported the bases of the NRCs conclusions were effectively implemented.

3.2.3(2) The NRC should develop general inspection Yes NRR guidance for the periodic verification of the (DLPM, implementation of owners groups IIPB) commitments made on behalf of their members.

8 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.1.2(5) The NRC should conduct follow-on Yes Medium PBPM NRR The RT agrees with recommendations verification of licensee actions associated (RORP, 3.1.2(5) and 3.1.3(2), but considers that with a sample of other significant generic IIPB) these activities should be combined.

communications, with emphasis on those Both 3.1.2(5) and 3.1.3(2) are involving generic communication actions retrospective.

that are primarily programmatic in nature.

3.1.3(2) The NRC should conduct follow-on Yes NRR verification of licensee actions pertaining to (DLPM, a sample of resolved GIs. IIPB) 3.1.2(3) The NRC should establish process guidance Yes Low PBPM NRR (IIPB) The RT agrees with this to ensure that generic requirements or recommendation.

guidance are not inappropriately affected when making unrelated changes to processes, guidance, etc. (e.g., deleting inspection procedures that were developed in response to a generic issue).

3.1.3(1) The NRC should evaluate, and revise as Yes Low PBPM RES The RT agrees with this recommendation necessary, the guidance for proposing for Management Directive 6.4.

candidate GIs.

STATUS: RES will undertake this as part of its overall assessment of the Management Directive.

9 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.4(7) The NRC should reassess the basis for the Yes Low PBPM NRR (IIPB) The RT agrees with this cancellation of the inspection procedures recommendation. The RT considers that that were deleted by Inspection Manual this activity should be performed in Chapter, Change Notice 01-017 to conjunction with the ROP self determine whether there are deleted assessment.

inspection procedures that have continuing applicability. Reactivate such procedures, as appropriate.

10 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions

3. Evaluation of Inspection, Assessment, and Project Management Guidance 3.2.5(2) The NRC should revise its inspection Yes High Short NRR (IIPB) The RT agrees with this guidance to provide assessments of: (1) the recommendation.

safety implications of long-standing, unresolved problems; (2) corrective actions STATUS: NRR has completed phased in over several years or refueling implementation of this recommendation outages; and (3) deferred modifications. by modifying IP 71152, PI&R.

3.3.5(4) The NRC should develop guidance to Yes High Short NRR (IIPB) The RT agrees with this address the impacts of IMC 0350 lead with recommendation.

implementation on the regional REGIONS organizational alignment and resource supporting allocation.

3.3.7(2) The NRC should establish guidance to Yes High Short NRR The RT agrees with this recommendation ensure that decisions to allow deviations (DLPM) with the following clarification The NRC from agency guidelines and should establish guidance to ensure the recommendations issued in generic staff evaluations of licensee responses to communications are adequately generic communications are documented documented. in sufficient detail to allow for public consideration of the bases for the staffs conclusions.

APP. F The NRC should conduct an effectiveness Yes Medium PBPM EDO The RT recommends that the issues review of the actions taken in response to identified in Table F-1 of the LLTF Report past lessons-learned reviews. be reviewed to determine whether the recommendations from previous Lessons-learned reviews have been adequately implemented.

11 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.4(5) The NRC should review the range of NRC Yes Medium PBPM NRR (IIPB) The RT agrees with this baseline inspections and plant assessment recommendation, with the following processes, as well as other NRC programs, clarification. The RT considers that the to determine whether sufficient programs fundamental difficulty associated with this and processes are in place to identify and event was the inability of the licensee and appropriately disposition the types of NRC to recognize the potential problem problems experienced at DBNPS. associated with various indicators, which Additionally, the NRC should provide more will be addressed in activities associated structured and focused inspections to with Recommendation 3.3.4(6). Also, the assess licensee employee concerns Commission has been provided a policy programs and safety conscious work options paper (SECY-02-0166) environment. addressing employee protection and safety conscious work environment.

3.2.5(1) The NRC should develop inspection Yes Medium PBPM NRR (IIPB) The RT agrees with this guidance to assess scheduler influences on recommendation. The RT considers that outage work scope. the regulatory basis should be confirmed before determining whether the guidance should be revised.

3.3.1(2) The NRC should develop inspection Yes Medium PBPM NRR (IIPB) The RT agrees with this guidance to assess repetitive or multiple TS recommendation. The RT considers that action statement entries, as well as, the this guidance should be linked back to radiation dose implications associated with the licensees corrective action program.

repetitive tasks. Specific guidance could be added to IP 71152 to highlight this concern.

12 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.3(1) As an additional level of assurance, the Yes Medium PBPM NRR (IIPB The RT agrees with this NRC should identify alternative mechanisms and EDO) recommendation. However, the RT to independently assess plant performance believes that this recommendation should as a means of self-assessing NRC focus on review of existing mechanisms processes. Once identified, the feasibility of to see if better use can be made of INPO, such mechanisms should be determined. OSART, etc., assessments.

3.3.7(1) The NRC should reinforce expectations for Yes Medium PBPM NRR The RT agrees with this the implementation of guidance in the PM (DLPM) recommendation. This should include handbook for PM site visits, coordination review of PM handbook and alignment of between PMs and resident inspectors, and expectations with practice.

PM assignment duration. The NRC should reinforce expectations provided to PMs and their supervisors regarding the questioning of information involving plant operation and conditions. Also, the NRC should strengthen the guidance related to the license amendment review process to emphasize the need to consider current system conditions, reliability, and performance data in SERs. In order to improve the licensing decision-making process, the NRC should strengthen its guidance regarding the verification of information provided by licensees.

13 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.4(1) The NRC should review its inspection Yes Medium PBPM NRR (IIPB) The RT agrees with this guidance pertaining to refueling outage recommendation. The RT considers that activities to determine whether the level of this activity should be expanded to inspection effort and guidance are sufficient consider establishing NRC guidance given the typically high level of licensee regarding scope and expectations for activity during relatively short outage inspection of containment systems and periods. The impact of extended operating material conditions.

cycles on the opportunity to inspect inside containment and the lack of inspection focus on passive components should be reviewed.

This review should also determine whether the guidance and level of effort are sufficient for inspecting other plant areas which are difficult to access or where access is routinely restricted.

3.3.4.(4) The NRC should revise IMC 0350 to permit Yes Medium PBPM NRR (IIPB) The RT agrees with this implementation of IMC 0350 without first recommendation. The RT believes the having established that a significant revision should include events and performance problem exists, as defined by conditions, in addition to performance the ROP. problems.

3.3.2(2) The NRC should revise the overall PI&R Yes Low PBPM NRR (IIPB) The RT agrees with this inspection approach such that issues similar recommendation.

to those experienced at DBNPS are reviewed and assessed. The NRC should enhance the guidance for these inspections to prescribe the format of information that is screened when determining which specific problems will be reviewed.

14 Attachment 1

Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.2(3) The NRC should provide enhanced Yes Low PBPM NRR (IIPB) The RT agrees with recommendations Inspection Manual Chapter guidance to 3.3.2(3) and 3.3.2(4), and believes that pursue issues and problems identified these recommendations should be during plant status reviews. combined. The RT recommends that NRR review IP 71152 to determine that the LLTF concerns were addressed.

3.3.2(4) The NRC should revise its inspection Yes STATUS: NRR believes these two guidance to provide for the longer-term recommendations are already addressed follow-up of issues that have not progressed by changes that were made in January to a finding. 2002 to IP 71152.

3.3.3(2) The NRC should perform a sample review of Yes Low PBPM NRR The RT agrees with this the plant assessments conducted under the (Regions recommendation. The RT believes PPR interim PPR assessment process (1998- and IIPB) letters from 1998 to 2000 should be 2000) to determine whether there are plant considered during annual assessments safety issues that have not been adequately as a way to examine long-term trends.

assessed.

3.3.4(6) The NRC should provide ROP refresher Yes Low PBPM NRR (IIPB) The RT agrees with this training to managers and staff members. lead with recommendation. The RT considers that TTC this activity should be focused on the supporting scope of the ROP, to reinforce a questioning attitude, and to receive feedback from the resident inspectors on any misconceptions of the ROP during the annual assessments.

3.3.5(2) The NRC should reinforce IMC 0102 Yes Low PBPM NRR (IIPB) The RT agrees with this expectations regarding regional manager recommendation. The RT considers this visits to reactor sites. activity should emphasize coaching and testing and knowledge sharing.

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Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.5(3) The NRC should establish measurements Yes Low PBPM NRR (IIPB) The RT agrees with this for resident inspector staffing, including the recommendation. The RT considers that establishment of program expectations to the inspector coverage and turnover at a satisfy minimum staffing levels. plant should also be included.

3.3.7(5) The NRC should fully implement Office Yes Low PBPM NRR The RT agrees with this Letter 900, Managing Commitments Made (DLPM) recommendation.

by Licensees to the NRC, or revise the guidance if it is determined that the audit of licensees programs is not required.

Further, the NRC should determine whether the periodic report on commitment changes submitted by licensees to the NRC should continue to be submitted and reviewed.

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Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions

4. Assessment of Barrier Integrity Requirements 3.2.1(1) The NRC should improve the requirements Yes High Long RES lead The RT agrees with recommendations pertaining to RCS unidentified leakage and supported 3.2.1(1), 3.1.5(1), 3.2.1(2), 3.2.1(3),

RCPB leakage to ensure that they are by NRR 3.3.3(3) and 3.3.4(9); and considers that sufficient to: (1) provide the ability to these recommendations should be discriminate between RCS unidentified combined into one activity. The RT leakage and RCPB leakage; and (2) provide recommends that RES develop an action reasonable assurance that plants are not plan to review requirements for RCS operated at power with RCPB leakage. leakage and determine if requirements should be revised.

This is a major effort that will require an action plan to better define the scope of this effort, coordinate responsibilities for the individual items, and determine resource requirements.

3.1.5(1) The NRC should determine whether PWR Yes plants should install on-line enhanced leakage detection systems on critical plant components, which would be capable of detecting leakage rates of significantly less than 1 gpm.

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Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.2.1(2) The NRC should develop inspection Yes guidance pertaining to RCS unidentified leakage that includes action levels to trigger increasing levels of NRC interaction with licensees in order to assess licensee actions in response to increasing levels of unidentified RCS leakage. The action level criteria should identify adverse trends in RCS unidentified leakage that could indicate RCPB degradation.

3.3.3(3) The NRC should continue ongoing efforts to Yes NRR (IIPB) review and improve the usefulness of the and barrier integrity PIs. These review efforts RES should evaluate the feasibility of establishing a PI which tracks the number, duration, and rate of primary system leaks that have been identified but not corrected.

3.2.1(3) The NRC should inspect plant alarm Yes NRR (IIPB) response procedure requirements for leakage monitoring systems to assess whether they provide adequate guidance for the identification of RCPB leakage.

3.3.4(9) The NRC should review PWR plant TS to Yes NRR identify plants that have non-standard RCPB (DRIP) leakage requirements and should pursue changes to those TS to make them consistent among all plants.

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Notes. Priority: Low; Medium; High Implementation Schedule: Short=6-12 mos.; Intermediate=12-24 mos.; Long=beyond 24 mos.; PBPM=Planning, Budgeting & Performance Management Response Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

LLTF RT Implement. Response RT No. LLTF Recommendation Accept Priority Schedule Org. Proposed Actions 3.3.7(3) The NRC should evaluate the adequacy of Yes Medium PBPM RES The RT agrees with this analysis methods involving the assessment recommendation.

of risk associated with passive component degradation, including the integration of the STATUS: RES will assess its ongoing results of such analyses into the regulatory programs related to component decision making process. degradation and evaluate methods to better incorporate passive system degradation in risk-informed decision making.

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Office of Nuclear Material Safety and Safeguards Areas for Assessment Davis-Besse Lessons Learned Task Force (DBLLTF) Recommendations Notes. Priority: L=Low; M=Medium; H=High Implementation Schedule: Short =6-12 months; Intermediate=12-24 months; Long=beyond 24 months Responsible Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

Implemt. Responsible DBLLTF Areas for Assessment Priority Schedule Org. Recommendations Integrated Assessment of Nuclear Material Safety Programs Inspection and licensee performance assessment could be a more MEDIUM SHORT NMSS 3.1.2(3); 3.2.1(2);

integrated process. Elements for further consideration may include 3.2.1(3); 3.2.5(1);

data analysis, evaluation of inspection results, and consideration of risk 3.2.5(2); 3.3.2(4);

insights. A plan for making the process more integrated is already in 3.3.3(1); 3.3.3(2);

progress, as provided in the draft Commission paper on the Agency 3.3.3(3); 3.3.4(5);

Action Review Meeting (AARM). The AARM should be reexamined 3.3.4(7); 3.3.7(3) periodically to test and confirm the quality and effectiveness of AARM processes.

Analysis and Use of Operating Experience Information The recommendations in the April 2001 Final Report of the Working MEDIUM SHORT NMSS 3.1.1(1); 3.1.6(1);

Group on Event Reporting should be reexamined, as appropriate, with 3.1.4(1); 3.1.5(1);

regard to the information collected, analyzed, and used by NRC and the 3.1.6(2); 3.1.6(3);

Agreement States. 3.2.4(1); 3.3.3(3);

3.3.4(2)

Operating experience information and the results of evaluations could MEDIUM INTER. NMSS be better communicated, particularly for foreign events. Emergent issues and trends are routinely discussed during regional counterpart meetings and are proposed for discussion at the AARM. Broader dissemination or discussion, with NRC Regions and Agreement States, of issues and evaluations should be considered.

1 Attachment 2

Notes. Priority: L=Low; M=Medium; H=High Implementation Schedule: Short =6-12 months; Intermediate=12-24 months; Long=beyond 24 months Responsible Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

Implemt. Responsible DBLLTF Areas for Assessment Priority Schedule Org. Recommendations Analysis and Use of Operating Experience Information (continued)

The Nuclear Materials Events Database (NMED) is the official NRC LOW LONG NMSS database for nuclear materials events. NMED contains the information on the occurrence, description, and resolution of material events in the U.S. reported in accordance with 10 CFR reporting requirements, or equivalent Agreement State reporting requirements, and other regulatory tools (e.g., NRC Bulletin 91-01, Reporting Loss of Criticality Controls). For NRC events, documentation of prompt telephonic reports to the NRC Operations Center, copies of licensee reports, reference to NRC inspection reports and enforcement actions, and other documents (ENs, PNs, etc.) are provided to the NMED contractor for entry into the database. NRC should examine methods for soliciting user feedback for improvements to NMED. Future improvements to NMED should derive from needs identified through the integrated assessment and operating experience programs.

Agreement State reporting is evaluated through the Integrated Materials MEDIUM LONG STP Performance Evaluation Program (IMPEP). NRC may want to better communicate the information reported by NRC and Agreement States and how it can be used to enhance the regulatory decision-making process. Periodic meetings with Agreement States should discuss significant events, emerging technologies, and possible generic issues.

2 Attachment 2

Notes. Priority: L=Low; M=Medium; H=High Implementation Schedule: Short =6-12 months; Intermediate=12-24 months; Long=beyond 24 months Responsible Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

Implemt. Responsible DBLLTF Areas for Assessment Priority Schedule Org. Recommendations Use of Risk Information in Regulatory Decisions It is possible for NMSS licensed activities and events to be improperly MEDIUM LONG NMSS 3.3.7(3) assumed to be of low safety significance without having a thorough investigation and/or risk analysis, with appropriate consideration of uncertainties. Likewise, it is possible for actions to tend toward risk-based decision-making rather than risk-informed, with appropriate balance of defense in depth. The appropriate use and potential misuse of risk information may warrant further discussion and reinforcement.

On an office-wide basis, NMSS should consider how risk has been MEDIUM LONG NMSS characterized in regulated activities (i.e., risk overlay). NRC should consider how consequences are used to characterize the significance of events, generic issues, and trends. NRC may want to consider evaluating a representative sample of generic issues and to consider how they were treated in terms of risk (i.e., gap analysis).

Program/activity selection should be based on the potential consequences of the licensed activity.

Verification of the Adequacy of Licensee and Regulatory Actions More could be done to verify short-term licensee actions in response to LOW LONG NMSS 3.1.1(1); 3.1.2(1);

generic communications. Few NRC Generic Letters and Bulletins are 3.1.2(2); 3.1.2(3);

used for NMSS licensed activities. Most are Information Notices that do 3.1.2(5); 3.1.3(1);

not require a response. The staff recently required confirmation of 3.1.3(2); 3.1.6(1);

licensee actions for Regulatory Issue Summaries related to the Orange 3.2.1(1); 3.2.2(1);

threat-level announcement. NRC and Agreement States may want to 3.2.3(2); 3.2.5(2);

examine a sample a recently issued generic communication to evaluate 3.3.4(2); 3.3.4(8);

the adequacy of licensee response to emergent safety issues and/or 3.3.4(9); 3.3.7(2);

trends.

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Notes. Priority: L=Low; M=Medium; H=High Implementation Schedule: Short =6-12 months; Intermediate=12-24 months; Long=beyond 24 months Responsible Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

Implemt. Responsible DBLLTF Areas for Assessment Priority Schedule Org. Recommendations Verification of the Adequacy of Licensee and Regulatory Actions (continued)

Management of aging, passive component degradation, and lack of LOW LONG NMSS engineering rigor are currently being addressed in applicable NMSS licensed activities (e.g., fuel cycle, waste management, etc.). However, NRC and Agreement States may want to examine a sample of older generic issues to verify the adequacy of actions by both NRC (e.g., via a Temporary Instruction) and licensees in achieving meaningful and lasting closure.

The Generic Safety Issue (GSI) process is sufficiently codified in NRC LOW LONG NMSS guidance. Management Directive 6.4 was recently revised to enhance guidance for processing of GSIs in NMSS-regulated activities but could be better communicated to the staff. NRC should reexamine MD 6.4 to consider DBLLTF recommendations applicable to NMSS and lessons learned, relative to the process implemented by NRR and RES for GSIs.

Implementation of Management Expectations Reinforcement of management expectations concerning the importance MEDIUM SHORT NMSS 3.2.5(1); 3.3.1(1);

of the NRC staff questioning licensee assumptions, analyses, and 3.3.2(1); 3.3.2(2);

conclusions is an ongoing process for both licensing and inspection. 3.3.2(4); 3.3.4(2);

Inspection procedures are designed to lead to predictable outcomes, 3.3.4(3); 3.3.4(4);

but should not constrain the expectation that inspectors are to 3.3.4(5); 3.3.5(2);

demonstrate questioning attitudes in observing licensee performance. 3.3.7(1); 3.3.7(5)

Inspection and licensing programs should take advantage of risk insights, importance to compliance, the staffs and management experience, wisdom, and instincts in looking at issues for potential problems.

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Notes. Priority: L=Low; M=Medium; H=High Implementation Schedule: Short =6-12 months; Intermediate=12-24 months; Long=beyond 24 months Responsible Org. is the NRC organization that will lead the implementation. Supporting organizations are noted.

Implemt. Responsible DBLLTF Areas for Assessment Priority Schedule Org. Recommendations NRC Staffing and Training NRC should consider the knowledge and skill of the generalist and MEDIUM INTER. NMSS 3.3.1(1); 3.3.1(2);

specialist in responding to performance-related information (e.g., 3.3.4(6); 3.3.5(1);

inspection findings, event reports, technical evaluations, etc.) and in 3.3.5(3); 3.3.5(4) deliberating Agency actions. NRC should examine and consider expanding career path opportunities for technical specialists. Success is predicated on the team concept whereby critical talent is brought to bear on issues of concern in a timely manner. NRC should examine the process of integrating generalist and specialist talent with appropriate management review and oversight. Only a limited number of NMSS licensees (FCSS) have resident inspectors.

The focus of staffing and training should be examined relative to the MEDIUM INTER. NMSS Strategic Workforce Planning (SWP) initiative. The need for selected skill sets (e.g., digital instrumentation and control systems, materials degradation, etc.) will change over time and need to be anticipated/identified for consideration in the SWP. Specialized skills may not be available within the NRC. Certain skills may be needed only for a limited time and could be satisfied through contractor support.

Licensee Self-Assessment and Corrective Action Programs Most NMSS licensees do not have extensive self-assessment, LOW LONG NMSS 3.1.6(1); 3.2.5(2);

corrective action, or employee-concerns programs, as relied on in the 3.3.7(3); 3.3.7(6);

reactor oversight process. The need for more additional effort in this App.F area should be considered based on risk and operating experience reviews.

5 Attachment 2