ML031110330
| ML031110330 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/29/2002 |
| From: | Joseph Donoghue NRC/EDO |
| To: | Russ Bywater, Castleman P, Haag R, Hackett E, Howell A, Thomas Koshy, Lloyd R, Elaine Raphael, Starefos J NRC/RGN-IV/DRP |
| References | |
| FOIA/PA-2003-0018 | |
| Download: ML031110330 (9) | |
Text
Joelle Starefos - APPENDIX A Page 1 From: Joseph Donoghue ,cop To: Bywater, Russ; Castleman, Patrick; Haag, Robert; Hackett, Edwin; Howell, Art; Koshy, Thomas; Lloyd, Ron; Raphael, Elaine; Starefos, Joelle Date: 8/29/02 4:25PM
Subject:
APPENDIX A This is the table of recommendations based on today's draft of the report. It is on the shared drive.
There are only 97 items Ill We have OBVIOUSLY FALLEN SHORTI (Art, we'll work all weekend to come up with 3 morelIll)
I'll revise it as needed so we'll have an up to date version for the meetings next week.
I i Joelle Starefos - APPEND14.WPD Page Paae 1 I1 Joelle Starefos APPENDI4.WPD Appendix A: Consolidated Recommendations No. Recommendation Report Action Reference Org.
(Section) _
1 Consider providing an integrated listing of studies or major documents containing 3.1 1 NRC significant operating expenence to ensure that this body of knowledge and expenence isn't lost 2 Consider providing an integrated listing and assessment of issued genenc 3.1 1 NRC communications induding an assessment of their effectiveness 3 Consider studying the unique vulnerabilities of B&W plants with respect to nozzle 3.1.1 NRC cracking and bone acid corrosion 4 Consider performing a study to analyze boric acid corrosion of different materials under 3.1.1 NRC varying temperatures and conditions.
5 Consider the need for long-term analysis of operational expenence by a single group. 3 1.1 NRC 6 Consider the need for the NRC to review industry guidance documents 3 1.2 NRC 7 Consider a penodic review of the status of genenc communications 3 1.2 NRC 8 Consider changes to MD 6.4. MD 8 5, and LIC-503 to coordinate office functions and 3 1.2 NRC provide appropriate training 9 Consider providing training on significant operational experience. 3 1.2 NRC 10 Assess the need to enhance the use of foreign operating expenence. 3 1.2 NRC 11 Enhance the dissemination of foreign expenence 31.2 NRC 12 Update the international expenence database onginally kept by AEOD 3.1 2 NRC 13 Assess whether or not lessons learned have been learned or not 3 12 NRC 14 Consider the need to venfy that corrective actions have been implemented to address 313 NRC past significant generic communications and generic issues 15 Consider establishing a process for venfication of licensee and agency actions to address 3 1.3 NRC genenc communications. Consider also the need to venfy the effectiveness of licensee and agency corrective actions to address genenc communication 16 Assess the overall scope and process for reviewing operational expenence 3 13 NRC 17 Consider the need to consolidate the genenc communication program (LIC-503) and the 3.1 3 NRC generic issues program (MD 6 4) 18 Consider establishing critena for accepting industry resolutions for genenc 3.1 3 NRC communications and genenc issues _
- - Starefos II Joelle - APPEND14.WPD Paa1e 2 0 I Jolle tarfos APPNDI.WPDP~ri 21 19 Establish a central operating expenence screening group to identify issues for Generic 3 1.4 NRC Issues Program based on US and foreign experience 20 Evaluate/revise guidance for proposed genenc communications 31 4 NRC 21 Determine if screening cntena for candidate generic issues are acceptable 3 1.4 NRC 22 Assess consolidation of genenc communications process and the Generic Issue Program 3.1.4 NRC
__ (GIP) 23 Ensure that generic requirements or guidance are not eliminated or undermined when 3 1.A NRC making changes to regulatory processes (e g , deleting inspection procedures) 24 Update MD 8 5, MD 6 4. and NRR Office Instruction LIC 503. "Generic Communications 3.1.4 NRC
- AffectingNuclear Reactor Licensees" 25 Enhance cntena for Bonc Acid Corrosion Control (BACC) programs 3.1 4 NRC xx 3.21 xx 322 26 Assess the practice of resolving safety issues via communications with Industry owners 3.2.3 NRC groups to determine if this practice is appropriate rather than direct communications with individual licensees 27 Review the legal status of owners group communications with the NRC to determine if 323 NRC actions or commitments Identified by the owners groups on behalf of their member
_ utilities are enforceable upon individual licensees 28 Perform a review of NRC safety evaluations of owners group submitals to identify what 323 NRC actions were assumed by the staff to be implemented by individual licensees to support the NRC staffts conclusions 29 Develop a process for the communication of NRC safety evaluations of owners group 323 NRC
_ submitals to the affected licensees and the NRC regional offices.
30 Develop an inspection procedure for regional office inspector verification of 3 23 NRC implementation of owners group commitments made on behalf of their member utilities at the affected plants and provide inspection resources to implement this verification.
31 Perform an audit of implementation of past owners group commitments for individual 3 23 NRC licensees to ensure the bases of the NRC's safety evaluation conclusions remain valid 32 Implement periodic inspections of licensee operating experience programs 3 2.3 NRC 33 Audit owners group submitals made to the NRC on their behalf to ensure commitments, 3 23 Ind explicit or implied, are incorporated into the commitment tracking system. Ensure that required actions have been implemented 34 Ensure that feedback mechanisms exist and are implemented to perform adequate 3 23 Ind review of owners group reports to ensure that site-specific actions are taken as required
1.__.
jeti Starefos - APPE-ND14.WPD II joelle APIDI.P
-tar-os PDnm D-n-
'Z 35 Review the range of NRC baseline inspections and assessment capabilities to determine 324 NRC if sufficient activities are inplace to detects the types of problems experienced at DBNPS or If addition oversight activities are needed 36 Each commercial nuclear power plant should perform indepth case study review of the 324 Ind Davis-Besse head degradation event to ensure they do not have similar problems and weaknesses 37 Re-emphasize questioning attitude among NRC staff/management. Consider this 3 3.1 NRC attnbute in individual and organizational performance measures 38 In refresher training discuss the Davis-Besse head degradation event and highlight 3 3.1 NRC symptoms that were available to the NRC staff dunng Inspection activities 39 Establish structure and expectations for management interaction with staff to followup on 3.3 1 NRC the types of problems that occurred at Davis-Besse 40 Review Inspection procedure Attachment 71111. 20, Refueling and Outage 33 1 NRC Activities, to determine If adequate Instructions and expectations for outage reviews are specified. MAYBE MOVE 41 Emphasize to inspectors the need remain aware of their surroundings when Inspecting in 33 1 NRC a particular area, such as radiation protection, and the need to pass on observations to applicable personnel 42 Assess the overall PI&R guidance such that issues similar to those experienced at 332 NRC Davis-Besse are reviews (possible emphasis on the 3 -6 Issues /years PI&R inspections and the biannual Inspections) Determine if guidance is needed on the format of issues that are screened when to determining which specific problems will be reviewed 43 Review ROP guidance to determine if changes are needed to allow longer term followup 3 3.2 NRC on issues that haven't progressed to a finding Should IFls be allowed that would direct future Inspections In areas of concern 44 Emphasize through a case study' training that inspection must probe into issues or 3.3 2 NRC potential problems verses reviewing licensee action and providing a status of these action In an Inspection report 45 Assess the need for inspection of licensees bonc acid corrosion programs, similar to the 3.3 2 NRC actions directed by IP62001.
46 Consider vanous method to independently assess plant performance, then compare and 33 2 NRC contrast the results with existinq plant performance assessment performed by the region
Joelle Starefos - APPEND14.WPD Pagqe 4 47 Determine if additional guidance Is needed to pursue issues and problems identified 3.3 3 NRC during plant status reviews and if other improvement to plant status guidance is needed.
Of particular Important is management's engagement recognition of issues and the guidance that is given to the Inspection staff 48 Re-emphasize questioning attitude among NRC staff/management Consider this 333 NRC attribute in individual and organizational performance measures.
49 Review ROP assessment process to determine if changes are needed to identify plants 333 NRC that may have similar problems as Davis-Besse, however, the inspections results has only Green findings and Green Pis 50 Determine If other plants, which were only assessed by PPRs for a similar length of time 333 NRC as Davis-Besse, have problems that need to be addressed 51 Improvement to the Barrer Pis should be considered 333 NRC 52 Management Directive 8.3 should be reviewed for possible over-reliance on nsk 33 3 NRC determination that have too much uncertainty 53 Develop and implement guidance for conduct and content of daily plant status calls 334 NRC between the resident inspector office staff, NRR project manager, and regional office supervisor 54 Review and Implement guidance for NRR project managers to maintain cognizance of 334 NRC plant operational Issues and provide feedback to regional office staff of licensing issues that have licensee performance insights 55 Revise regional procedures for conduct and content of daily staff meetings Guidance 334 NRC should include provision for senior manager acknowledgment of issues presented and assignment of action Items as necessary 56 Develop uniform guidance for inspection debnefings with regional management 334 NRC Guidance should Include provision for discussion of plant performance observations that may be Indicative of licensee problem Identification and resolution deficiencies and declining plant performance 57 Review guidance for the conduct of counterpart meetings between NRC headquarters 334 NRC and regional office staff to determine if additional forums for communication are required of plant performance issues 58 Enhancements to the NRC inspector training should include 1) provide training on boric 33 5 NRC acid corrosion; 2) Increasing knowledge level on selected industry operational experience, 3) utilized Davis-Besse reactor head degradation as a case study for Inspector initial certification and requalification, and 4) update training at TTC to include event lessons leamed
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IJoelle Starefos - APPEND14.WPD Page 51 Page Joelle Starefos APPENDI4.WPD 59 Re-enforce expectation of IMC 0102 regarding regional management visits to reactor 335 NRC sites I _
60 Conduct an assessment of staff needs in the matenals area 3 35 NRC 61 Establish measurements for resident inspector staffing and consider establishing 3 35 NRC nationwide expectations to satisfy minimum staffing 62 Consider 0350 impact on regional branch assignment of facilities and the need for 3 35 NRC program guidance on distribution of oversight function for branch with 0350 plants 63 Assessment of maximum turnover rate for NRR project managers (i e 3 35 NRC assignment/reassignment) and update the Project Manager Handbook to be consistent with current management expectation regarding project manager site visits and interaction with regional staff 64 Reassess policy for selecting uncertified staff for resident positions 33 5 NRC 65 The NRC should take steps (i e , establish processes and provide resources) to verify 336 NRC information provided by licensees In response to safety-significant generic communications and in support of other safety-related information submitted by licensees 66 The DBNPS event should be used as an example to strongly encourage licensees to 3.3 6 IND provide to the NRC complete and accurate information on plant operations and system conditions.
67 The DBNPS licensee should take steps to improve its internal communications to ensure 3.3 6 IND that accurate Information on plant operations and system conditions is available throughout the organization This should include processes to ensure that wntten records include information consistent with actual system conditions, and that internal audits include steps to venfy information about system conditions 68 Implement guidance In the PM handbook for project manager site visits and coordination 3.3.7 NRC between project managers and resident inspectors NRR should take steps to foster working relationships between project managers and site resident inspectors One step is for NRR to better manage project manager assignments to avoid the type of high turnover associated with DBNPS. NRR should consider holding periodic NRRIRegional Office counterpart meetings (including the resident inspectors) to maintain working relationships among staff and managers in the organizations and to allow exchanges on significant topics
i 1 oleStaeo A-iN:1.P Paae 6 "r yoelle itaretos -APl-NUl4.WPD Paae61 69 Licensing project managers and their supervisors should be encouraged to question 3.3 7 NRC information regarding plant operation and conditions NRR should consider strengthening the guidance related to the license amendment review process to emphasize the need to consider actual system conditions in the safety evaluation.
Further, further clear guidance is needed to ensure independent venficabon of information provided by licensees related to significant licensing decisions.
70 NRC should establish procedures to ensure that decisions to allow deviations from 33 7 NRC agency guidelines and recommendations issued in generic communications are adequately documented 71 NRC should assess the use of nsk methods and provide dearer guidance for integration 337 NRC of results into decision-making related to short-notice licensing actions. Clearer guidance addressing such situations would help ensure that appropriate decisions are made and that the bases for the decisions are well documented 72 NRC should revise the guidelines for review of industry topical reports to allow for staff 3 3.7 NRC review of safety-significant reports Independent of their formal submittal to the NRC NRC should also provide sufficient resources to support the reviews.
73 NRR should either fully implement LIC-900, "Commitment Management Process" or 3.3 7 NRC consider revising the guidance if it determines that the project manager audit of licensees programs is not required Further, the staff should consider the usefulness of the periodic report on commitment changes made by licensees, and if they are not to be reviewed, inform licensees that they do not need to be submitted 74 NRR should determine whether ISI summary reports should be submitted to the NRC, 3 37 NRC and revise the ASME submittal requirement, or staff guidance regarding disposition of the
_ reports, as appropriate 75 The NRC staff should continue to pursue ongoing efforts to encourage the ASME Code 3 4.1 NRC requirement changes for inspections of reactor vessel heads, including nozzle penetrations, strengthened (NRR), or as an altemative, pursue changes to 10 CFR 50 55a 76 The NRC should pursue revision of the ASME Code to reduce the ability for plants to 3 4.1 NRC start up with known leakage from RCS mechanical joints 77 The NRC should establish a clear enforcement policy for RCS leakage and should not 34 1 NRC grant enforcement discretion for nozzle cracking 78 NRC should review the bases for the 1 gpm unidentified leakage limit to determine If this 34 1 NRC critenon is adequate to address low levels of leakage from the RCS pressure boundary
lJoelle Starefos - A015END14WWPD1 WPa1ge J7 79 NRC should review, and revise as necessary, the Maintenance Rule requirements and 34 1 NRC guidance pertaining to RCS unidentified leakage The results of this review should address requirements to establish a normal level of unidentified leakage and methods for establishing action levels based on deviations from normal.
80 Industry should revise related ASME code requirements to address the shortcomings in 3 4.1 IND VHP inspections and reduce the ability for plants to start up with known leakage from RCS mechanical joints 81 Review the significance determination process for limitations in evaluating degraded 34 2 NRC conditions and applying nsk assessments Consideration should be given to the use of deterministic methods in assessment evaluations; 82 Review the ROP Inspection effort dunng refueling outages given the large of amount of 34 2 NRC licensee activities in the relatively short outage time frame, limit future opportunities during operating cycle, and a lack of previous Inspections for passive components; 83 Consideration should be given to proceduralizing 'good practices' such as containment 3.4 2 NRC building tours, Mode restraint reviews pnor to startup, etc; 84 Evaluate performance Indicators In bamer integnty cornerstone to determine if 34 2 NRC
___ improvements are needed, 85 Evaluate the reactivation and Implementation of Inspection procedures 90700 and 62001 34 2 NRC or provide comparable level of guidance for operating expenence and bonc acid corrosion program Inspections' 86 Consider nsk of repetitive LCO entnes or continuing problems, develop inspection 34 2 NRC guidance to focus on repetitive multiple tasks for significance (i.e CAC cleaning/ALARA),
87 Develop inspection guidance for resident inspector samples of licensing requests to 3 4.2 NRC
__ understand the basis and provide necessary feedback to the prolect manager; 88 PI&R guidance should be strengthened in the area of utilizing expenence from members 3.4 2 NRC of the staff to develop area of review, I e , handing off issues to the PI&R team, and screening corrective action issues when determining issues for follow up review, 89 Develop NRC crnteria for inspection of industry Initiatives. Provide Inspection guidance to 3.4 2 NRC address selected industry operational expenence Initiate GC-specific inspection procedures Incorporate GC references in inspection procedures 90 Assess the need for changes to the ROP to allow regional follow up on issues of potential 3.4 2 NRC
__ safety significance 91 Determine if the results from reviewing previous lessons-leamed task force efforts 3.4 2 NRC suggest a need for programmatic guidance in this area
I Joelle Starefos - A1it-tNUI4.VVtLU 4 sa-77,7
.nnc~ralsgenr Parie R 11 I
92 NRC should work with industry to develop guidance for voluntary initiatives such as 343 NRC testing to more fully understand bonc acd corrosion effects NRR should take steps to review guidelines in industry topical reports (see Recommendations in Section 3 3 7) A possible step would be to assign NRC technical project managers to evaluate industry tests and review the widely distnbuted guidelines for adequacy and suitability 93 Industry should review and revise existing guidance related to bonc acid corrosion control 3 4 3 IND and RPV head penetration inspection and repair to better support licensee decision making involving these issues.
94 Industry should utilize plant condition information gained by vendor organization 34 3 IND
_ conducting inspection and repair activities at multiple plants 95 Industry should review the approaches used by licensees to consider economic factors 3 4.3 IND involved with RPV head penetration Inspection and repair. This might include conducting representative cost/benefit analyses of RPV head inspections that would include factors for dose, cost, and time involved 96 Industry groups should Improve dissemination of information to members and hold 3 4.3 IND members accountable for following guidance/recommendations For example, one mechanism that would aid dissemination is for licensee staff to regularly attend Owner's Group meetings related to RPV degradation and inspection 97 The industry should conduct further testing and analysis to develop a more reliable crack 34 3 IND model and should assess the susceptibility of other RCS components fabncated from Alloy 600 I Items numbered In order of appearance in report. Will be renumbered when recommendations are available for other sections.