ML030590142
| ML030590142 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/27/2003 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Moroney B, NRR/DLPM, 415-3974 | |
| Shared Package | |
| ml030660105 | List: |
| References | |
| TAC MB7280, TAC MB7347, Y020030008 | |
| Download: ML030590142 (8) | |
Text
ATTACHMENT 2 ACTION PLAN FOR ADDRESSING DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS REGARDING OPERATING EXPERIENCE PROGRAM EFFECTIVENESS Last Update: Initial Update (2/27/03)
Lead Division: DRIP Supporting Divisions: DE, DSSA, DIPM, DLPM Supporting Office: RES, Regions TAC No.
Description MB7280 Develop Operating Experience Action Plan MB7347 Overall Assessment of Agencys Operating Experience Program Milestone Date (T=Target)
(C=Complete)
Lead Support Part I - Operating Experience Program: Objective Phase 1.
Form Task Force with Steering Committee and develop Charter 03/03 (T)
NRR/RES 2.
Identify desirable agency operating experience program objectives and attributes, and 2.a Provide documented staff proposals of operating experience program objectives and attributes 2.b Obtain executive management endorsement 04/03 (T) 04/03 (T) 05/03 (T)
Task Force
- DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions Part II - Operating Experience Program: Assessment Phase
- 1.
Define functional needs/areas and processes to meet objectives and attributes 9/03 (T)
Task Force
- DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions
Milestone Date (T=Target)
(C=Complete)
Lead Support 2.
Review and evaluate current processes
[LLTF 3.1.6(1)]
9/03(T)
Task Force
- DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions 3.
Identify areas for improvements
[LLTF 3.2.4(1)]
9/03(T)
Task Force
- DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions 4.
Task Force issues draft report 9/03(T)
Task Force 5.
Task Force provides final report to Steering Committee documenting its specific program improvement proposals 11/03 (T)
Task Force 6.
Steering Committee makes recommendations to office management on improvements to be made 6.a Responsible organizations achieve consensus on proposals to implement 12/03 (T) 12/03 (T)
Steering Committee NRR/RES Regions Part III - Operating Experience Program: Implementation Phase
- 1.
Develop implementation plan based on 6.a in Part II 1.a Implement specific improvements per implementation plan (1/04-12/04)
[LLTF 3.1.6(2)]
[LLTF 3.1.6(3)]
[LLTF 3.3.4(2)]
1/04 (T) 12/04 (T)
NRR/RES Regions
Milestone Date (T=Target)
(C=Complete)
Lead Support 2.
Establish processes to monitor effectiveness 6/04(T)
NRR/RES Regions Part IV - Inspection Program Enhancements
- 1.
Provide training and reinforce expectations to NRC managers and staff members to address the following areas: (1) maintaining a questioning attitude in the conduct of inspection activities; (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 [LLTF 3.3.1(1)]
12/03 (T)
DIPM DE,
- DSSA, DET/RES, Regions 2.
Implement actions to maintain NRC expertise by ensuring that NRC inspector training includes: (1) boric acid corrosion effects and control; and (2) PWSCC of nickel based alloy nozzles [LLTF 3.3.5(1)]
12/03(T)
DIPM DE,
- DSSA, DET/RES, Regions
==
Description:==
Initiatives to assess and improve the agencys reactor operating experience program has been initiated and ongoing for some time. Also, the report of the Davis-Besse Lessons Learned Task Force (LLTF), issued on September 30, 2002, contains a number of recommendations on operating experience program improvements. It is important to note that opportunities to improve access and use of operating experience information will continue in parallel with the systematic assessment of the agencys operating experience program described in this action plan.
Historical
Background:
Up until 1999, the Office of Analysis and Evaluation of Operational Data (AEOD) performed various activities pertinent to systematically collecting and evaluating operating experience, and communicating the lessons learned to the NRC staff and the regulated industry. With the abolishment of AEOD per SECY 98-228, Proposed Streamlining and Consolidation of AEOD Functions and Responsibilities, October 1, 1998, the roles and responsibilities of AEOD associated with the operating experience program were transferred to the Offices of Nuclear Regulatory Research (RES) and Nuclear Reactor Regulation (NRR).
NRR was generally assigned the short-term operating experience reviews and RES long-term operating experience activities.
Since this time, both NRR and RES have recognized the need to make operating experience more efficiently available to users. RES has made substantial advances in making existing databases available through the internal web. These databases include licensee event reports (LERs), INPOs EPIX database, and monthly operating reports. RES uses these data to provide initiating event frequencies, safety system reliabilities, component failure probabilities, and common-cause failure parameter estimates, as well as related insights. The RES internal web page, for which significant further advances are already planned, will allow NRC staff easier and more timely access these estimates, related trends, and insights in a more timely manner. In addition, the RES internal web site will provide a new expanded LER search tool for use by NRC staff. It is planned that in April 2003, the accident sequence precursor (ASP) database will be accessible through the RES internal web site to the NRC staff. In September 2003, this will be followed by an expanded web site that will further integrate presently contained in separate databases and NUREG and NUREG/CR reports. NRR has similarly improved communications of its short term operating experience program outputs through web technology and is currently replatforming its events and assessment database.
However, despite individual program improvements, the effectiveness of the agency wide program has been questioned. Many believed that the current program activities should be more proactive, risk-informed, and integrated. Many also indicated that the insights gained and lessons learned from operating experience reviews should be better communicated to the users. In addition, both NRR and RES recognized that the governing agency policy, i.e.,
Management Directive 8.5, Operational Safety Data Review, December 23, 1997, and various guidance documents clearly needed updates. In late 2001, NRR created the Operating Experience Section (OES) under the Division of Regulatory Improvement Programs (DRIP). In late 2002, OES spearheaded an effort to assess the agencys overall operating experience program by soliciting support from various organizations responsible for agencys program activities. As a result, the Operating Experience Working Group has since been formed to better coordinate the multi-office effort for assessing and improving the agencys overall operating experience program.
One of the NRC follow-up actions to the Davis-Besse event was formation of a LLTF. The LLTF conducted an independent evaluation of the NRCs regulatory processes pertinent to the event in order to identify and recommend areas of improvement applicable to the NRC and the industry. A report summarizing their findings and recommendations was published on September 30, 2002. The report contains several consolidated lists of recommendations. The LLTF report was reviewed by a Review Team (RT), consisting of several senior management personnel appointed by the EDO. The RT issued a report on November 26, 2002, endorsing all but two of the LLTF recommendations, and placing them into four overarching groups. On January 3, 2003, the EDO issued a memo to the Directors of NRR and RES, tasking them with developing action plans for accomplishing the High-Priority items in the four groups.
This Action Plan addresses the assessment and improvement of the agencys operating experience program. It also addresses the recommendations of the Davis-Besse LLTF regarding operating experience program effectiveness. All of the seven High-Priority recommendations in Assessment of Operating Experience, Integration of Operating Experience into Training, and Review of Program Effectiveness grouping are included in this Action Plan.
Proposed Actions:
This Action Plan describes the key high-level steps for the agencys operating experience overall program review, which goes beyond the scope of the Davis-Besse LLTF recommendations. This approach is expected to be more effective than addressing only the LLTF items separately from the overall operating experience program review. The High-Priority LLTF items are specifically designated in the milestones under appropriate Parts or steps to address the requirements prescribed in the January 3, 2003 Tasking Memorandum. The designated LLTF items represent only a subset of multiple activities for the corresponding milestone.
The milestones are grouped into Parts I, II, III and IV.
Part I is associated with defining the objectives and attributes of the agencys desirable operating experience program and receiving the endorsement from the agencys executive management. An interoffice Task Force will be formed to perform the activities in Parts I and II. An interoffice (NRR, RES, and Regions) executive Steering Committee will also be formed to guide the Task Force activities. A Charter describing the goals and responsibilities of the Task Force will be jointly developed by the offices. The purpose of this Task Force is to complete the milestones described in the objective and assessment Phases (Parts I and II of this Action Plan) by December 31, 2003.
Part II describes the milestones associated with the assessment phase of the agencys overall operating experience program review. These assessment activities will be performed and completed by the Task Force. The scope of the assessment phases will include, but is not necessarily limited to, those operating experience functions identified by SECY 98-228. The output of the assessment activities will be the development of specific proposals for improvement in functional areas to effectively achieve the objectives established in Part I. The Task Force will issue a draft report for review when its preliminary observations, conclusions, and proposals are identified. The Task Force will subsequently provide a final report to the Steering Committee documenting its specific program improvement proposals and the basis for those proposals. The Steering Committee will make recommendations to the offices on improvements to be made and office management will make appropriate assignments. The target date for the Part II milestones is December 31, 2003.
The Part III improvements would include a number of actions that could significantly improve the agencys overall operating experience program effectiveness. These actions will be taken by line organizations in accordance with a implementation plan in response to the recommendations by the Steering Committee. The implementation plan is expected to contain both short-term and long-term improvements. The short-term improvements are expected to be implemented starting in early 2004 and long-term improvements in mid-to late 2004. Actions are expected to require significant interoffice coordination and interaction. If the improvements require significant changes to the policy, resource, or organizational structure, interactions with the Commission would be necessary. Meetings and communications with both internal and external stakeholders, e.g., INPO, are also expected and encompassed within the scope of the milestones listed in Parts II and III. The target date for completing all the Part III milestones is December 31, 2004.
Part IV lists the two inspection-related High-Priority LLTF items that are focused on enhancing inspection activities.
Originating Documents: Memorandum from Travers, W.D. to Collins, S. and Thadani, A. C.,
dated January 3, 2003, Actions Resulting From The Davis-Besse Lessons Learned Task Force Report Recommendations. (ML023640431)
Memorandum from Paperiello, C.J. to Travers, W.D., dated November 26, 2002, Senior Management Review of the Lessons-Learned Report of the Davis-Besse Nuclear Power Station Reactor Pressure Vessel Head. (ML023260433)
Memorandum from Howell, A.T. to Kane, W.F., dated September 30, 2002, Degradation of the Davis-Besse Nuclear Power Station Reactor Pressure Vessel Head Lessons-Learned Report.
Regulatory Assessment: The agency performs a broad range of activities that relate to collection, assessment, feedback, and dissemination of nuclear reactor operating experience.
The main purpose of these activities is to generate valuable insights and lessons learned from operating experience and provide feedback to the NRC regulatory programs and the industry.
The output of these activities should positively influence both the NRC regulatory programs and the nuclear industry performance. These operating experience program activities provide mechanisms for an independent assessment of the effectiveness of the current NRC regulatory programs and activities and generate long-term, historical, and objective perspectives on individual nuclear power plant and industry performance.
The LLTF recommended that the effectiveness of the current operating experience program be evaluated. As stated earlier, a systematic review of the overall operating experience program has been ongoing and would proceed according to this Action Plan.
Again, the regulatory basis for the agencys current operating experience functions generally stems from the roles and responsibilities defined in SECY 98-228. Any changes in the organizational and/or functional responsibilities defined in this SECY will require Commission consultation.
Current Status: This is the initial update for this Action Plan, which addresses the recommendations of the Davis-Besse LLTF regarding operating experience program. The milestones also include management oversight efforts and continuing interaction between the NRC, industry and other stakeholders.
Potential Problems: None.
Proposed Resolution of Potential Problems: N/A Schedule Changes Since Last Update: This is the Initial Update.
Resource Expenditure: As of February 22, 2003, 213.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (= 0.2 FTE) have been expended by NRR on the TACs listed for this Action Plan.
TAC No.
TAC Status HOURS MB7280 Open 165.0 MB7347 Open 48.5 An additional 18,104 Hours (12.4 FTEs) and $970K contract funding are anticipated to complete the tasks in the Action Plan.
NRR - 4.4 FTEs (1.5 FTEs for FY03, 2.3 FTEs for FY04, and 0.6 FTE for 1st quarter of FY05)
RES - 7.3 FTEs and $970K (2.6 FTEs and $125K for FY03, 3.5 FTEs and $535K for FY04, and 1.2 FTE and $310K for 1st quarter of FY05)
Regions - 0.7 FTE (0.2 FTE for FY03, 0.4 FTE for FY04, and 0.1 FTE for 1st quarter of FY05)
Priority: 2 Contacts:
Ian Jung, RORP, 415-1837 NRR Technical
Contact:
Terrence Reis, RORP, 415-3281 DSSA Lead
Contact:
Michael Johnson, SPSB, 415-3183 DIPM Lead
Contact:
Cynthia Carpenter, IIPB, 415-4006 DRIP Lead
Contact:
William Beckner, RORP, 415-3281 DLPM Lead
Contact:
Herbert Berkow, LPDII, 415-1485 DE Lead
Contact:
Goutam Bagchi, 415-3005 DET/RES Lead
Contact:
Nilesh Chokshi, 415-0190 DRAA/RES Lead Contact Patrick Baranowsky, OERAB, 415-7493 DSARE/RES Lead Contact John Flack, REAHFB, 415-8742 Regional Offices:
Charles Casto, Region II, 404-562-4600
References:
Management Directive 8.5, Operational Safety Data Review, December 23, 1997 SECY 98-228, Proposed Streamlining and Consolidation of AEOD Functions and Responsibilities, October 1, 1998 Table 1 LLTF Report Recommendations (High Priority)
RECOMMENDATION NUMBER RECOMMENDATION 3.1.6(1)
The NRC should take the following steps to address the effectiveness of its programs involving the review of operating experience: (1) evaluate the agencys capability to retain operating experience information and to perform longer-term operating experience reviews; (2) evaluate thresholds, criteria, and guidance for initiating generic communications; (3) evaluate opportunities for additional effectiveness and efficiency gains stemming from changes in organizational alignments (e.g., a centralized NRC operational experience 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 experience guidance documents.
3.1.6(3)
The NRC should enhance the effectiveness of its processes for the collection, review, assessment, storage, retrieval, and dissemination of foreign operating experience.
3.2.4(1)
The NRC should assess the scope and adequacy of its requirements governing licensee review of operating experience.
3.3.4(2)
The NRC should strengthen its inspection 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 reinforce expectations to NRC managers and staff members to address the following areas:
(1) maintaining a questioning attitude in the conduct of inspection activities; (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.
3.3.5(1)
The NRC should maintain its expertise in the subject areas by ensuring that NRC inspector training includes: (1) boric acid corrosion effects and control; and (2) PWSCC of nickel based alloy nozzles.