ML032310220
| ML032310220 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/29/2003 |
| From: | Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research |
| To: | |
| Moroney B, NRR/DLPM, 415-3974 | |
| Shared Package | |
| ML032310212 | List: |
| References | |
| M030114B, Wits 200300006 (NRR) | |
| Download: ML032310220 (12) | |
Text
Status of Davis-Besse LLTF Recommendations LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status
- 1. Assessment of Stress Corrosion Cracking 3.1.1(1) Assemble foreign and domestic information High RES(DET) 10/04 Addressed in SCC Action Plan.
concerning Alloy 600 (and other nickel based alloys) Collection of information on cracking nozzle cracking and boric acid corrosion. Analyze is in progress and expected to nickel based alloy nozzle susceptibility to stress complete by 03/04 corrosion cracking (SCC), including other Collection of information on boric susceptible components, and boric acid corrosion of acid corrosion is targeted for carbon steel, and propose a course of action and an completion by 10/04 implementation schedule to address the results.
3.3.2(1) Develop inspection guidance for the periodic High NRR(IIPB) 03/04 Addressed in SCC Action Plan.
inspection of PWR plant boric acid corrosion control programs.
3.2.2(1) Inspect the adequacy of PWR plant boric acid NRR (IIPB) TBD Addressed in SCC Action Plan.
corrosion control programs. Inspection procedures to be developed by 03/04. Inspection schedule will be determined after procedures are developed.
3.3.4(3) Develop inspection guidance or revise existing High NRR (IIPB) 06/04 Addressed in SCC Action Plan.
guidance to ensure that VHP nozzles and the RPV head area are periodically reviewed by the NRC during licensee ISI activities.
ATTACHMENT 1
LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(8) Encourage ASME Code requirement changes for High NRR(DE) 06/04 Addressed in SCC Action Plan.
bare metal inspections of nickel based alloy nozzles Staff reviewing EPRI/MRP guidelines for which the code does not require the removal of (MRP-55 and MRP-75) which will be insulation for inspections. Also, encourage ASME used as basis for ASME code Code requirement changes for the conduct of non- changes.
visual NDE inspections of VHP nozzles. Staff participates in ASME Code Alternatively, revise 10 CFR 50.55a to address committees.
these areas.
3.1.4(1) Determine if it is appropriate to continue using the Medium RES 07/03 Addressed in SCC Action Plan.
existing SCC models as a predictor of VHP nozzle Target date was revised from 05/03 PWSCC susceptibility. to 07/03 to allow peer review of draft report.
Complete.
3.3.7(6) Determine whether ISI summary reports should be Low NRR (DE) 06/04 Addressed in SCC Action Plan.
submitted to the NRC, and revise the ASME submission requirement and staff guidance regarding disposition of the reports, as appropriate.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status
- 2. Assessment of Operating Experience, Integration of Operating Experience into Training, and Review of Program Effectiveness 3.1.6(1) Take the following steps to address the High NRR 12/04 Addressed in Operating Experience effectiveness of programs involving the review of (IROB) Action Plan.
operating experience: (1) evaluate the agencys and Operating Experience Task Force capability to retain operating experience information RES (OETF) completed development of and to perform longer-term operating experience program objectives and attributes reviews; (2) evaluate thresholds, criteria, and and received management guidance for initiating generic communications; (3) endorsement (05/03).
evaluate opportunities for additional effectiveness OETF to develop specific program and efficiency gains stemming from changes in improvement proposals and obtain organizational alignments (e.g., a centralized NRC management endorsement by 12/03.
operational experience clearing house); Offices to develop implementation (4) evaluate the effectiveness of the Generic Issues plan by 01/04.
Program; and (5) evaluate the effectiveness of the Revised program to be implemented internal dissemination of operating experience to by 12/04.
end users.
3.1.6(2) Update NRC operating experience guidance NRR 12/04 Addressed in Operating Experience documents. (IROB) Action Plan.
and RES 3.1.6(3) Enhance the effectiveness of NRC processes for the NRR 12/04 Addressed in Operating Experience collection, review, assessment, storage, retrieval, (IROB) Action Plan.
and dissemination of foreign operating experience. and RES 3.2.4(1) Assess the scope and adequacy of requirements NRR 09/03 Addressed in Operating Experience governing licensee review of operating experience. (IROB) Action Plan.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(2) Strengthen inspection guidance pertaining to the NRR 12/04 Addressed in Operating Experience periodic review of operating experience. (IROB, Action Plan.
IIPB) 3.3.1(1) Provide training and reinforce expectations to NRC NRR (IIPB) 12/03 Addressed in Operating Experience managers and staff members to address the Action Plan.
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) Maintain expertise in the subject areas by ensuring NRR (IIPB) 12/03 Addressed in Operating Experience that NRC inspector training includes: (1) boric acid Action Plan.
corrosion effects and control; and (2) PWSCC of nickel based alloy nozzles.
3.1.2(1) Revise NRC processes to require short-term and Medium NRR TBD Target date to be set upon long-term follow-on verification of licensee actions to (IROB) completion of generic communication address significant generic communications (i.e., review [3.1.2(5)].
bulletins and GLs).
3.1.2(2) Establish review guidance for accepting owners Medium NRR 12/03 group and industry resolutions for generic (DLPM, communications and generic issues. DE, DSSA) 4
LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.2.3(1) Review a sample of NRC safety evaluations of NRR 12/04 owners group submissions to identify whether (DLPM, intended actions that supported the bases of the IIPB)
NRCs conclusions were effectively implemented.
3.2.3(2) Develop general inspection guidance for the NRR 12/04 periodic verification of the implementation of owners (DLPM, groups commitments made on behalf of their IIPB) members.
3.1.2(5) Conduct follow-on verification of licensee actions Medium NRR 11/04 Polling of Regions, RES and NRR to associated with a sample of other significant generic (IROB, identify highest priority generic communications, with emphasis on those involving IIPB) communications is in progress.
generic communication actions that are primarily programmatic in nature.
3.1.3(2) Conduct follow-on verification of licensee actions NRR 12/04 pertaining to a sample of resolved GIs. (DLPM, IIPB) 3.1.2(3) Establish process guidance to ensure that generic Low NRR (IIPB) 12/03 requirements or 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) Evaluate, and revise as necessary, the guidance for Low RES 10/04 proposing candidate GIs.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(7) Reassess the basis for the cancellation of the Low NRR (IIPB) 12/03 inspection procedures that were deleted by Inspection Manual Chapter, Change Notice 01-017 to determine whether there are deleted inspection procedures that have continuing applicability.
Reactivate such procedures, as appropriate.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status
- 3. Evaluation of Inspection, Assessment, and Project Management Guidance 3.2.5(2) Revise inspection guidance to provide assessments High NRR (IIPB) 12/03 Addressed in Inspection Program of: (1) the safety implications of long-standing, Action Plan.
unresolved problems; (2) corrective actions phased in over several years or refueling outages; and (3) deferred modifications.
3.3.5(4) Develop guidance to address the impacts of IMC High NRR (IIPB) 12/03 Addressed in Inspection Program 0350 implementation on the regional organizational Action Plan.
alignment and resource allocation.
3.3.7(2) Establish guidance to ensure that decisions to allow High NRR 12/03 Addressed in Inspection Program deviations from agency guidelines and (DLPM) Action Plan.
recommendations issued in generic communications DLPM Handbook updated in 02/03.
are adequately documented. Training package distributed by EDO in 04/03.
Followup on training effectiveness targeted for 12/03.
APP. F Conduct an effectiveness review of the actions Medium NRR (IIPB) 02/04 taken in response to past lessons-learned reviews.
3.3.4(5) Review the range of NRC baseline inspections and Medium NRR (IIPB) 12/04 plant assessment processes, as well as other NRC programs, to determine whether sufficient programs and processes are in place to identify and appropriately disposition the types of problems experienced at DBNPS. Additionally, provide more structured and focused inspections to assess licensee employee concerns programs and safety conscious work environment.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.2.5(1) Develop inspection guidance to assess scheduler Medium NRR (IIPB) 12/03 influences on outage work scope.
3.3.1(2) Develop inspection guidance to assess repetitive or Medium NRR (IIPB) 12/03 multiple TS action statement entries, as well as, the radiation dose implications associated with repetitive tasks.
3.3.3(1) As an additional level of assurance, identify Medium NRR (IIPB) 12/04 alternative mechanisms to independently assess plant performance as a means of self-assessing NRC processes. Once identified, the feasibility of such mechanisms should be determined.
3.3.7(1) Reinforce expectations for the implementation of Medium NRR 12/03 guidance in the PM handbook for PM site visits, (DLPM) coordination between PMs and resident inspectors, and PM assignment duration.
Reinforce expectations provided to PMs and their supervisors regarding the questioning of information involving plant operation and conditions.
Also, 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.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(1) Review inspection guidance pertaining to refueling Medium NRR (IIPB) 12/03 outage activities to determine whether the level of inspection effort and guidance are sufficient given the typically high level of licensee activity during relatively short outage periods. The impact of extended operating 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) Revise IMC 0350 to permit implementation of IMC Medium NRR (IIPB) 10/03 0350 without first having established that a significant performance problem exists, as defined by the ROP.
3.3.2(2) Revise the overall PI&R inspection approach such Low NRR (IIPB) 12/03 Addressed in Inspection Program that issues similar to those experienced at DBNPS Action Plan.
are reviewed and assessed. Enhance the guidance for these inspections to prescribe the format of information that is screened when determining which specific problems will be reviewed.
3.3.2(3) Provide enhanced Inspection Manual Chapter Low NRR (IIPB) 12/03 Addressed in Inspection Program guidance to pursue issues and problems identified Action Plan.
during plant status reviews 3.3.2(4) Revise inspection guidance to provide for the 12/03 Addressed in Inspection Program longer-term follow-up of issues that have not Action Plan progressed to a finding.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.3(2) Perform a sample review of the plant assessments Low NRR (IIPB) 03/04 conducted under the interim PPR assessment process (1998-2000) to determine whether there are plant safety issues that have not been adequately assessed.
3.3.4(6) Provide ROP refresher training to managers and Low NRR (IIPB) 12/03 staff members.
3.3.5(2) Reinforce IMC 0102 expectations regarding regional Low NRR (IIPB) 12/03 manager visits to reactor sites.
3.3.5(3) Establish measurements for resident inspector Low NRR (IIPB) 12/03 staffing, including the establishment of program expectations to satisfy minimum staffing levels.
3.3.7(5) Fully implement Office Letter 900, Managing Low NRR 05/03 Complete. NRR Office Instruction Commitments Made by Licensees to the NRC, or (DLPM) LIC-105 implements OL 900 and revise the guidance if it is determined that the audit provides instructions for review of of licensees programs is not required. periodic reports.
Further, 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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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status
- 4. Assessment of Barrier Integrity Requirements 3.2.1(1) Improve the requirements pertaining to RCS High RES(DET) TBD Addressed in Barrier Integrity Action unidentified leakage and RCPB leakage to ensure Plan.
that they are sufficient to: (1) provide the ability to discriminate between RCS unidentified leakage and RCPB leakage; and (2) provide reasonable assurance that plants are not operated at power with RCPB leakage.
3.1.5(1) Determine whether PWR plants should install on- 03/05 Addressed in Barrier Integrity Action line enhanced leakage detection systems on critical Plan.
plant components, which would be capable of detecting leakage rates of significantly less than 1 gpm.
3.2.1(2) Develop inspection guidance pertaining to RCS 01/05 Addressed in Barrier Integrity Action unidentified leakage that includes action levels to Plan.
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) Continue ongoing efforts to review and improve the RES 12/05 Addressed in Barrier Integrity Action usefulness of the barrier integrity PIs. These review (DRAA) Plan.
efforts 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.
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LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.2.1(3) Inspect plant alarm response procedure NRR (IIPB) 03/04 Addressed in Barrier Integrity Action requirements for leakage monitoring systems to Plan.
assess whether they provide adequate guidance for the identification of RCPB leakage.
3.3.4(9) Review PWR plant TS to identify plants that have NRR 07/03 Addressed in Barrier Integrity Action non-standard RCPB leakage requirements and (IROB) Plan.
should pursue changes to those TS to make them Complete. ML031980077 consistent among all plants.
3.3.7(3) Evaluate the adequacy of analysis methods Medium RES TBD involving the assessment of risk associated with passive component degradation, including the integration of the results of such analyses into the regulatory decision making process.
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