ML031110333
| ML031110333 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/03/2002 |
| 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: ML031110333 (9) | |
Text
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To:
Koshy, Thomas; Date:
Subject:
Joseph Donoghue I c DQ Bywater, Russ; Castleman, Patrick; Haag, Robert, Hackett, Edwin; Howell, Art, Lloyd, Ron; Raphael, Elaine; Starefos, Joelle 9/3/02 8:37AM APP A UPDATE Recommendations table updated based on new 3 2 from Bob.
i Joelle Starefos - Armendix.wrpd Page 1, 9 JoelieStarefs ADend~x~~d Paa 1
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I 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 including 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 bonc acid corrosion.
4 Consider performing a study to analyze bonc acid corrosion of different materials under 3 1 1 NRC varying temperatures and conditions 5
Consider the need for long-term analysis of operational experience 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 periodic 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 expenence 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 3 1.2 NRC 12 Update the international expenence database onginally kept by AEOD 3 1.2 NRC 13 Assess whether or not lessons learned have been teamed or not 3 1.2 NRC 14 Consider the need to venfy that corrective actions have been implemented to address 3 1 3 NRC past significant generic communications and generic issues 15 Consider establishing a process for verification of licensee and agency actions to address 3 1.3 NRC genenc communications Consider also the need to verify the effectiveness of licensee and agency corrective actions to address generic communication 16 Assess the overall scope and process for reviewing operational expenence 3 1.3 NRC 17 Consider the need to consolidate the genenc communication program (LIC-503) and the 3 1.3 NRC genenc Issues program (MD 6 4) 18 Consider establishing cntena for accepting 'industry" resolutions for genenc 3 1.3 NRC communications and generic Issues
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i Joelle Starefos - Appendix.wmd Paae2I 19 Establish a central operating experience screening group to Identify issues for Genenc 3 1.4 NRC Issues Program based on US and foreign experience 20 Evaluatelrevise guidance for proposed genenc communications 3 1.4 NRC
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21 Determine If screening criteria for candidate genenc issues are acceptable 3 1 4 NRC 22 Assess consolidation of generic communications process and the Generic Issue Program 3 1 4 NRC (GIP) 23 Ensure that genenc requirements or guidance are not eliminated or undermined when 3 1 4 NRC making changes to regulatory processes (e g, deleting inspection procedures).
l 24 Update MD 8.5, MD 6 4, and NRR Office Instruction LIC 503, 'Generic Communications 3.1 4 NRC Affecting Nuclear Reactor Licensees "
25 Enhance cntena for Bonc Acid Corrosion Control (BACC) programs.
3 1 4 NRC 26 Reassess the issue of requiring Installation of an enhanced leakage monitonng system 3.2 1 NRC and requirements for the discrimination between RCS unidentified leakage and RCPB leakage and identify expected licensee actions to venfy no RCPB boundary leakage exists.
27 Develop and implement inspection requirements for RCS leakage monitoring systems 3.2 1 NRC 28 Review alarm response procedure requirements for RCS leakage monitonng systems 3.2 1 IND and provide additional requirements for the identification of RCPB leakage 29 Develop and implement inspection requirements for bonc acid corrosion control program 3 2 2 NRC implementation 30 Assess adequacy of bonc acid corrosion control programs to determine their acceptability 3 2 2 IND for the identification of RCPB leakage and ensure that adequate inspections and evaluations are performed for any RCS leak, including considerations for insulation removal 31 Ensure that personnel performing bonc acid corrosion control inspections are adequately 3 2 2 IND trained 32 Assess the practice of resolving safety issues via communications with industry owners 3 2 3 NRC groups to determine If this practice is appropnate rather than direct communications with Individual licensees 33 Review the legal status of owners group communications with the NRC to determine if 3 2 3 NRC actions or commitments Identified by the owners groups on behalf of their member utdies are enforceable upon individual licensees 34 Perform a review of NRC safety evaluations of owners group submitals to identify what 3 2 3 NRC actions were assumed by the staff to be implemented by individual licensees to support the NRC staffs conclusions
IJoelle Starefos - Appendix.wpd Pagqe 31 Joelle Starefos - Apendix.wDd Paae 3
35 Develop a process for the communication of NRC safety evaluations of owners group 3.2 3 NRC submitals to the affected licensees and the NRC regional offices.
36 Develop an inspection procedure for regional office inspector venfication of 3 2 3 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 37 Perform an audit of implementation of past owners group commitments for individual 3 2 3 NRC licensees to ensure the bases of the NRC's safety evaluation conclusions remain valid 38 Implement periodic inspections of licensee operating experience programs 3 2 3 NRC 39 Audit owners group submitals made to the NRC on their behalf to ensure commitments, 3 2 3 Ind explicit or implied, are incorporated Into the commitment tracking system Ensure that required actions have been implemented 40 Ensure that feedback mechanisms exist and are implemented to perform adequate 3 2 3 Ind review of owners group reports to ensure that site-specific actions are taken as required 41 Review the range of NRC baseline inspections and assessment capabilities to determine 3.2 4 NRC if sufficient activities are inplace to detects the types of problems expenenced at DBNPS or if addition oversight activities are needed 42 Each commercial nuclear power plant should perform indepth case study review of the 3 2 4 Ind Davis-Besse head degradation event to ensure they do not have similar problems and weaknesses 43 Re-emphasize questioning attitude among NRC staff/management Consider this 3 3 1 NRC attribute in Individual and organizational performance measures 44 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 45 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 46 Review Inspection procedure Attachment 71111. 20, Refueling and Outage 3 3 1 NRC Activities, to deterrnine if adequate Instructions and expectations for outage reviews are specffied. MAYBE MOVE 47 Emphasize to inspectors the need remain aware of their surroundings when inspecting in 3 3 1 NRC a particular area, such as radiation protection, and the need to pass on observations to applicable personnel 48 Assess the overall PI&R guidance such that issues similar to those experienced at 3 3 2 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
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I Joelle SiareTOS -JRDpendIX.Wpa P~qinA I4 I
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~tae~os ADenlxw-49 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 IFIs be allowed that would direct future Inspections in areas of concern 50 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 51 Assess the need for inspection of licensees bonc acid corrosion programs, similar to the 3 3.2 NRC actions directed by IP62001 52 Consider vanous method to independently assess plant performance, then compare and 3 3.2 NRC contrast the results with existing plant performance assessment performed by the region 53 Determine If additional guidance is needed to pursue issues and problems identified 3 3 3 NRC dunng plant status reviews and if other Improvement to plant status guidance is needed.
Of particular important is managements engagement! recognition of issues and the guidance that is given to the inspection staff 54 Re-emphasze questioning attitude among NRC staff/management Consider this 3.3 3 NRC attribute in individual and organizational performance measures 55 Review ROP assessment process to determine If changes are needed to identify plants 3 3 3 NRC that may have similar problems as Davis-Besse, however, the Inspections results has only Green findings and Green Pis 56 Determine if other plants, which were only assessed by PPRs for a similar length of time 3 3 3 NRC as Davis-Besse, have problems that need to be addressed 57 Improvement to the Barrier Pis should be considered 3 3 3 NRC 58 Management Directive 8 3 should be reviewed for possible over-reliance on nsk 3 3 3 NRC determination that have too much uncertainty 59 Develop and implement guidance for conduct and content of daily plant status calls 3 3 4 NRC between the resident inspector office staff, NRR project manager, and regional office supervisor 60 Review and Implement guidance for NRR project managers to maintain cognizance of 3 3 4 NRC plant operational Issues and provide feedback to regional office staff of licensing issues that have licensee performance Insights.
61 Revise regional procedures for conduct and content of daily staff meetings. Guidance 3.3 4 NRC should include provision for senior manager acknowledgment of issues presented and assignment of action Items as necessary
Joelle Starefos - Appendix.wpid Paqe 5d 62 Develop uniform guidance for inspection debriefings with regional management 3 3 4 NRC Guidance should indude provision for discussion of plant performance observations that may be indicative of licensee problem identification and resolubon deficiencies and declining plant performance 63 Review guidance for the conduct of counterpart meetings between NRC headquarters 3 3 4 NRC and regional office staff to determine If additional forums for communication are required of plant performance issues 64 Enhancements to the NRC inspectortraining should include 1) provide training on bonc 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 learned 65 Re-enforce expectation of IMC 0102 regarding regional management visits to reactor 33 5 NRC sites 66 Conduct an assessment of staff needs In the matenals area 3 3 5 NRC 67 Establish measurements for resident inspector staffing and consider establishing 3 3 5 NRC nationwide expectations to satisfy minimum staffing 68 Consider 0350 impact on regional branch assignment of facilities and the need for 3 3 5 NRC program guidance on distnbution of oversight function for branch with 0350 plants 69 Assessment of maximum turnover rate for NRR project managers (i e 3 3 5 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 70 Reassess policy for selecting uncertified staff for resident positions 3 3 5 NRC 71 The NRC should take steps (i e, establish processes and provide resources) to venfy 33 6 NRC Information provided by licensees in response to safety-significant generic communications and in support of other safety-related information submitted by licensees 72 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.
73 The DBNPS licensee should take steps to Improve Its intemal 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 written records include information consistent with actual system conditions, and that internal audits include steps to venfv information about system conditions
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L Joelle StareTOS - ADDend IX.WDa Paaem A I1 I Joelie tareos
- ADDfld IX.WOd Piri I 74 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 penodic NRR/Regional 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 75 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 venfication of information provided by licensees related to significant licensing decisions.
76 NRC should establish procedures to ensure that decisions to allow deviations from 3 3 7 NRC agency guidelines and recommendations issued in generic communications are adequately documented 77 NRC should assess the use of nsk methods and provide clearer guidance for integration 3.3 7 NRC of results into decision-making related to short-notice licensing actions Clearer guidance addressing such situations would help ensure that appropnate decisions are made and that the bases for the decisions are well documented 78 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 79 NRR should either fully implement LIC-900, "Commitment Management Process" or 3.3.7 NRC consider revising the guidance If i 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.
80 NRR should determine whether ISI summary reports should be submitted to the NRC, 3.3 7 NRC and revise the ASME submittal requirement, or staff guidance regarding disposition of the reports, as appropnate.
81 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 alternative, pursue changes to 1D CFR 50 55a
I I Joelle Staretos - Appendixmrpd Page 7 9 Joelle Staretos - Appendlx.wpd Paae 7 82 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 83 The NRC should establish a dear enforcement policy for RCS leakage and should not 3 4.1 NRC grant enforcement discretion for nozzle cracking 84 NRC should review the bases for the 1 gpm unidentified leakage limit to determine If this 3 4.1 NRC criterion is adequate to address low levels of leakage from the RCS pressure boundary 85 NRC should review, and revise as necessary, the Maintenance Rule requirements and 3.4.1 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.
86 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.
87 Review the significance determination process for limitations in evaluating degraded 3 4 2 NRC conditions and applying nsk assessments. Consideration should be given to the use of deterministic methods in assessment evaluations 88 Review the ROP inspection effort dunng refueling outages given the large of amount of 3 4 2 NRC licensee activities in the relatively short outage time frame, limit future opportunities dunng operating cycle, and a lack of previous Inspections for passive components; 89 Consideration should be given to proceduralizing 'good practices" such as containment 3 4 2 NRC building tours, Mode restraint reviews prior to startup, etc; 90 Evaluate performance Indicators in bamer integnty cornerstone to determine if 3 4 2 NRC Improvements are needed, 91 Evaluate the reactivation and implementation of inspection procedures 90700 and 62001 3 4 2 NRC or provide comparable level of guidance for operating expenence and boric acid corrosion program inspections; 92 Consider nsk of repetitive LCO entries or continuing problems, develop inspection 3 4 2 NRC guidance to focus on repetitive multiple tasks for significance (1 e CAC cleaning/ALARA),
93 Develop inspection guidance for resident inspector samples of licensing requests to 3 4 2 NRC understand the basis and provide necessary feedback to the project manager:
94 PI&R guidance should be strengthened In the area of utilizng 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;
t Joelle Star-efo-s - "Appendix.Wpd-
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-Ao-ndxw~dP~r 95 Develop NRC criteria 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 96 Assess the need for changes to the ROP to allow regional follow up on issues of potential 3 4 2 NRC safety significance 97 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 98 NRC should work with industry to develop guidance for voluntary initiatives such as 3 4 3 NRC testing to more fully understand bonc acid corrosion effects NRR should take steps to review guidelines in industry topical reports (see Recommendations in Section 3.37) A possible step would be to assign NRC technical project managers to evaluate industry tests and review the widely distributed guidelines for adequacy and suitability 99 Industry should review and revise existing guidance related to boric acid corrosion control 3 4 3 IND and RPV head penetration inspection and repair to better support licensee decision making involving these issues.
100 Industry should utilize plant condition Information gained by vendor organization 3 4.3 IND conducting inspection and repair activities at multiple plants.
101 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.
102 Industry groups should improve dissemination of Information to members and hold 3 4 3 IND members accountable for following guidancekrecommendabons 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 103 The industry should conduct further testing and analysis to develop a more reliable crack 3 4 3 IND model and should assess the susceptibility of other RCS components fabricated from Alloy 600 I
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Items numbered In order of appearance In report. Will be renumbered when recommendations are available for other sections.