ML033320422

Minutes of Internal Meeting of the Davis-Besse Oversight Panel

ML033320422
Person / Time
Site:	Davis Besse
Issue date:	11/24/2003
From:	Grobe J Division of Nuclear Materials Safety III
To:
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Download: ML033320422 (43)

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November 24, 2003 MEMORANDUM TO: Davis-Besse Nuclear Power Station IMC 0350 Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA/

SUBJECT:

MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL The implementation of the IMC 0350 process for the Davis-Besse Nuclear Power Station was announced on April 29, 2002. An internal panel meeting was held on August 12, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel and the revised Corrective Action Team Inspection inspection plan.

Attachments: As stated cc w/att: D. Weaver, OEDO J. Dyer, RIII J. Caldwell, RIII R. Gardner, DRS B. Clayton, EICS G. Wright, DRP DB0350

November 24, 2003 MEMORANDUM TO: Davis-Besse Nuclear Power Station IMC 0350 Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA/

SUBJECT:

MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL The implementation of the IMC 0350 process for the Davis-Besse Nuclear Power Station was announced on April 29, 2002. An internal panel meeting was held on August 12, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel and the revised Corrective Action Team Inspection inspection plan.

Attachments: As stated cc w/att: D. Weaver, OEDO J. Dyer, RIII J. Caldwell, RIII R. Gardner, DRS B. Clayton, EICS G. Wright, DRP DB0350 DOCUMENT NAME: S:\ADMIN\Karen's Docs\Ml033320422.wpd To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy OFFICE RIII RIII RIII NAME DPassehl for CLipa JGrobe MPhillips/klg DATE 11/24/03 11/24/03 11/24/03 OFFICIAL RECORD COPY

MEETING MINUTES: Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE: August 12, 2003 TIME: 9:00 a.m. Central ATTENDEES:

J. Grobe C. Lipa B. Ruland S. Thomas M. Phillips A. Mendiola J. Stang Z. Falevits Agenda Items:

1. Discuss/Approve Revisions to Inspection Plan for the Corrective Action Team Inspection The Panel discussed the proposed revision to the previously-approved corrective action team inspection plan. The Panel made some suggestions for additional improvement to the proposed plan, and requested that the changes be made next week and brought back to the Chairman for approval. The final version of the approved plan will be attached to these minutes. The Panel noted that it would need confidence prior to restart that the corrective action program for the licensee was effective in preventing cyclical performance.

2. Discuss Schedule for Meeting With Licensee to Discuss Safety Culture and Licensees Long-Term Plans The Panel reviewed various staff availability and concluded that a meeting in August was not feasible. The Panel recommended trying to schedule the meeting in mid-September.

3. Discuss/Update Milestones and Commitments The Panel reviewed and discussed upcoming milestones and commitments.

REVISED INSPECTION PLAN (Cover Letter) Rev. 8-21-03 CORRECTIVE ACTION IMPLEMENTATION TEAM INSPECTION Davis-Besse Nuclear Power Station Inspection Report Number 50-346/2003010(DRS)

(Do not share this Inspection Plan with the licensee)

Inspection Objectives The 0350 Oversight Panel established for Davis Besse determined that a comprehensive review by the NRC was needed to assess the implementation of the licensees upgraded corrective action program. This is required to determine the effectiveness of the corrective action process in identifying, correctly assessing, and promptly correcting risk-significant findings.

In addition, this inspection will fulfill the baseline inspection program requirements for the biennial portion of inspection procedure 71152 (Identification and Resolution of Problems). The biennial inspection objectives are to provide an assessment of the effectiveness of licensee problem identification and resolution (PI&R) programs, including problem identification, evaluation, and resolution, based upon a performance-based review of specific issues; to look for instances where the licensee may have missed identifying potential "generic" concerns, including specific problems involving safety equipment, procedure development, or design control. In addition, the team will also use applicable inspection guidance delineated in IP 93812 (Special Inspection).

Inspection Dates: March 17-21, March 31 to April 4, May18-23, August 11-15 and 25-29, 2003 EXIT: Thursday, September 9, 2003, at 1:30 p.m.

Applicable Inspection Procedures IP 71152, "Identification and resolution of problems" IP 93812, "Special Inspection" Prepared by:

Zelig Falevits Electrical Engineering Branch Reviewed by:

Ronald N Gardner Senior Project Manager Reviewed by:

Christine A. Lipa, Chief Reactor Projects Branch 4 Approved by :

John A. Grobe, Chairman Davis-Besse Oversight Panel 4

INSPECTION PLAN DETAILS I. Inspectors Z. Falevits, Team Leader M. Farber, Assistant Team Leader P. Lougheed, Senior Reactor Engineer R. Daley, Senior Reactor Engineer A. Walker, Senior Reactor Inspector W. Bennett, Corrective Action, Consultant J. Panchison, Mechanical, Consultant W. Sherbin, Mechanical, Consultant F. Baxter, Electrical, Consultant O, Mazzoni Electrical Consultant II Detailed Inspection Schedule Preparation and Inspection Activities Entrance Meeting: March 18, 2003 at 9:30 a.m.

On-site Inspection Weeks: March 17-21, March 31 to April 4, May18-23, August 11-15 and 25-29, 2003 Exit Meeting: Thursday, September 9, 2003, at 1:30 p.m.

Licensee Contacts Regulatory Affairs: David Gudger and Joe Sturdevant Inspection Documentation Inputs Due: September 8, 2003 An inspection report must be issued before October 20, 2003 (45 days from the exit)

III Lead Inspector Preparation Activities Information Requests As part of the inspection preparation, the team leader listed selected corrective action documents in tables below. The team will select the documents to be reviewed. In addition, the team leader will request the required information from the licensee and will ensure that the necessary information be conveyed to the inspection team.

If during the in office preparation weeks, additional information is determined to be necessary, please inform the team leader.

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IV Team Preparation Activities Review of Material Each team member will review the licensee administrative procedures that control the identification, evaluation, and resolution of problems. These documents will be reviewed to provide sufficient knowledge of the licensees revised corrective action program and process, as necessary to conduct an effective and efficient inspection.

Each team member will review documentation on licensee efforts to identify, resolve and prevent structure, system, and component performance problems through performance monitoring, root cause analysis, cause determination, and corrective action to meet the monitoring requirements of the maintenance rule (10 CFR 50.65).

Preparation Meetings A team meeting will be held on Monday, March 10, 2003, at 1:00pm. In this team meeting, the team leader will discuss the inspection plan and distribute available information provided by the licensee and specific inspector items for review and follow-up. Additionally, during this meeting, the team leader will go over inspection logistics and answer team questions.

Over the next several days, each inspector, including the team leader shall review the provided documentation and select additional corrective action items to be reviewed. Also, each inspector will become familiar with the requirements of the applicable NRC IPs.

Requests for Additional Information As soon as possible, but no later than noon on March 12, 2003, team members should provide to the team leader a list of any additional information and/or documents they want to have readily available on the first day of the inspection. The team leader will coordinate with the team members to ensure there is no duplication of efforts.

Selection of Specific Items for Review The samples chosen for review should include a range of issues including:

1. Licensee identified issues mostly documented in Condition Reports/Corrective Action Items (including issues identified during audits or self assessments);

2. NRC identified issues;

3. Issues identified through NRC generic communications;

4. Issues identified through industry operating experience exchange mechanisms (including Part 21 reports, NSSS vendor reports, EPRI reports, experience reports from similar facilities, LERs);

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5. Specific or cross cutting issues identified by safety review committees or other management oversight mechanisms;

6. Issues identified through employee concerns programs V. Inspection Objectives The main objectives of the Corrective Action Team Inspection (CATI) are:

( To determine if the corrective action process at Davis Besse is being effectively implemented to identify risk-significant conditions at an appropriate threshold.

( To determine if the identified problems are being correctly prioritized for resolution and if the prioritization and schedule established by the licensee for implementing and completing the corrective actions is adequate and timely..

( To determine if licensees identified problems in important to safety systems are being evaluated using a systematic method(s) to identify the correct root cause(s) and contributing cause(s).

( To evaluate licensee's implementation of the corrective action program to address identified issues including determination of root cause(s), apparent cause(s),

potential common cause(s), and extent of condition evaluation.

( To determine if the corrective action process at Davis Besse is being effectively implemented and if appropriate corrective action is taken to prevent recurrence of identified problems.

( To review a sample of Restart corrective action items to determine if the corrective action items required to be accomplished prior to plant restart have been correctly characterized and actions had been completed in accordance with licensee and regulatory requirements.

( To review a sample of Post Restart corrective action items to determine if they were properly classified to be addressed after restart.

( To evaluate the licensee's effectiveness in assessing and correcting the risk-significant issues identified during the System Health Assurance/Readiness (SHRR, LIR and SFVP) Reviews

( To accomplish applicable inspection activities required by Inspection Procedures 71152 and 93812.

( To identify any adverse trends or patterns in implementation of the corrective action process.

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( To assess effectiveness and determine how the licensee measures effectiveness of implementation of the corrective action program. Also, to review audits and self-assessments completed and planned to assess Corrective Action implementation.

( To review the assigned items (CRs, URIs, NCVs, LERs etc..,) and focus on adequacy of licensees assessment to identify the correct root/apparent cause(s) and the effectiveness of the corrective action process in addressing these causes, including extent of condition.

( To verify whether the licensee is reporting, in a timely manner, conditions that warrant 50.73 LERs or are they in violation of 50.73?

( Assess for repeat issues (CRs) or identified problems that need rework. Are these issues being trended ?

General Guidance for Review of Condition Reports Review each condition report against the following performance attributes:

( Did the licensee completely and accurately identify the problem in a timely manner, commensurate with its significance and ease of discovery?

( Did the licensee properly evaluate and resolve any operability or reportability issues?

( Did the licensee consider the extent of condition, the generic implications, whether there might be a common cause, or if there have been previous occurrences?

( Assess the validity of the licensees conclusions regarding extent of condition, consideration should be given to whether multiple risk significant design or performance issues have been identified.

( Is the licensee implementing an effective trending program to identify potentially significant adverse trends associated with human or equipment performance?

( Did the licensee classify and prioritize the resolution of the problem, commensurate with its safety significance?

( For any significant conditions adverse to quality, did the licensee identify the root and contributing causes of the problem?

( Did the licensee identify appropriately focused corrective actions to correct the problem? For significant conditions adverse to quality, do the corrective actions address the root and contributing causes.?

( Did the licensee complete the corrective actions in a timely manner, commensurate with the safety significance of the issue? Were extensions of corrective action due 8

dates adequately justified? Was combining of several condition reports under one new condition report justified ?

( If permanent corrective actions require significant time to implement, then verify that interim corrective actions or compensatory actions have been identified and implemented to minimize the problem or mitigate its effects, until the permanent action could be implemented;

( In addition, for samples that involve maintenance rule issues, the inspector should verify the following:

(a) The licensee has designated items under 10 CFR 50.65(a)(1) as appropriate, (b) Determine if corrective actions for 10 CFR 50.65(a)(1) items are adequate, (c) Review maintenance rule repetitive maintenance preventable functional failures (MPFFs) for indications of weaknesses in the licensees corrective action program. In addition, identify any problems with root cause analysis or cause determination and corrective action for items experiencing repetitive MPFFs or exceeding their goals or performance criteria, (d) Ensure that risk assessment, risk management, and emergent work control problems associated with maintenance are identified and resolved promptly.

More Ticklers for review of Condition Reports Status Questions

• Is the CR open or closed?

• How long has it been open?

• If open, where is it in the process?

• If closed, was closure timely?

• Was closure based on a corrective action or an administrative action?

Characterization Questions

• At what significance level was this classified?

• Do you agree with the classification?

• Were all steps of the process completed properly (i.e., accurately and timely)?

• Was an appropriate level of management involved?

• Was proper department assigned responsibility?

• Is the current level the same as originally assigned?

• If not, was revision appropriate?

Analysis Questions

• Was a new or unique activity involved?

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• Were generic (plant and industry-wide) implications addressed?

• Were repetitive problem implications addressed?

• Was the chronology of the issue examined?

• Did the licensee look for precursors?

• Were human factors considered?

• Were procedural problems considered?

• Were environmental factors involved?

• Was training considered?

• Were all the people involved in the issue interviewed?

• Was some form of oversight involved?

Resolution Questions

• Is this a final or interim corrective action?

• If interim, when is final anticipated?

• What is impeding final corrective action?

• Is corrective action focused on event itself or on root cause?

• If this is a repeat event, what is different about this new corrective action?

• If this is a repeat event, does it identify the inadequacy in the previous corrective action?

• If a repeat, was previously defined corrective action completed and still in effect?

• Was present corrective action approved by appropriate level of management?

• How much of the current corrective action is already in place?

• How long has corrective action been in place?

• Does corrective action appear to be effective (staff engaged, no recurrence, etc)?

• Does licensee have a follow-up mechanism in place to test effectiveness?

Team Assignments Successful completion of the CATIs inspection objectives and procedure requirements requires good planning and team work. Therefore, the team is being divided into areas with the following general assignments:

Electrical Engineering/Design/Management/Assessments -Zelig Falevits Electrical Engineering/Design/Operations -Marty Farber Mechanical Engineering/Design/Operations -Patricia Lougheed Electrical Engineering/Design/Operations -Robert Daley Mechanical Engineering/Design/Operations -Al Walker Mechanical Engineering/Design -W. Bennett, Corrective Action, Consultant Mechanical Engineering/Design -J. Panchison, Mechanical, Consultant Electrical Engineering/Design -O. Mazzoni, Electrical, Consultant Mechanical Engineering/Design -W. Sherbin, Mechanical, Consultant Electrical Engineering/Design -F. Baxter, Electrical, Consultant Within these areas, the intent is to ensure that all inspection attributes are met without duplication of effort. To ensure effective teamwork and knowledge sharing, a daily afternoon team meeting will be held at 3:30 p.m. which will focus on how assigned activities are being completed and what remains to be done to accomplish the inspection objectives.

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In addition, a meeting with the licensee will be held at 4:30 PM to inform the licensee of new issues identified and of information requested but not yet received. This meeting is to last not more than 30 minutes.

Assessment of Corrective Action Program At the completion of the inspection, the team will develop a clear and concise discussion of the results of their review. An assessment of the licensees corrective action program/process, based on the inspection results must be developed during the inspection.

By reviewing a sufficient number and breadth of samples, the team should be able to develop insights into the effectiveness of the licensees corrective action process. Compare the results of the teams findings with the results of the licensees findings, audits and assessments of the corrective action process.

IV Issues and Findings The Risk Informed Inspection Notebook and the Significance Determination Process (SDP) for Davis-Besse Nuclear Power Station have been developed and approved. Inspectors shall address the questions of Manual Chapter 0612 and process the finding through phase 2 of the SDP as necessary. Green findings will be documented in the inspection report.

Findings that appear to be "other than green" shall be immediately discussed with the team leader, the licensee and the senior reactor analyst, to ensure that Davis Besse PRA information is correctly considered. Enforcement action for green or non-SDP issues will be handled in accordance with the Enforcement Policy.

Unless an issue can be shown to be greater than minor, additional inspection time (over approx. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) should not be spent. If an issue appears greater than minor, then sufficient questions need to be asked of the licensee to enable the inspectors to confirm any assumptions and complete the Phase 1 and 2 worksheets. If a color cannot be determined by the end of the inspection, the issue will be described as an "unresolved item," pending final determination of the appropriate risk significance. Some flexibility will be allowed for documenting non-green observations due to the nature of the inspection.

V Documentation Inspection findings normally result in a number of questions being raised. These questions are to be given to the licensee verbally or, if written, the licensee must copy the information and the inspector must retain the written document. As part of the daily interfaces with the licensee, the team leader will go over the status of outstanding questions. Therefore, the team members need to keep the team leader informed of any concerns with timeliness or quality of responses to questions. Lack of response to questions will not be accepted as a reason for any delay in providing an input unless the team leader has been informed prior to the exit and the issue is one that will necessitate a writeup in the report. Any document requests generated on the day of the exit or afterwards must be approved by the team leader, must pertain to areas already inspected, and must be only for the purpose of ensuring an accurate document list entry.

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Issues which the inspector deems meet the criteria for report writeups shall be discussed with the team lead prior to preparing an input. Inputs are to be e-mailed to the team lead within five working days (seven calendar days) of the exit. All documents critically/deliberately reviewed shall be included in the document list. Corrective action documents generated as a result of the inspector's questions shall be listed separately from corrective action documents that were in the licensee's system prior to the inspection.

VI Interface and Coordination Meetings Meetings with the Licensee On Friday, August 29, 2003, at 8:00 a.m. an extensive debrief will be held between NRCl team members and licensees staff to discuss all identified issues during this inspection.

All team members are expected to attend this debrief Routine Interactions Through-out the inspection, inspectors are expected to have routine interactions with licensee employees. It is expected that these interactions will be professional in nature and will normally be conducted without the lead inspector present. Any questions or requests for further information arising from these meetings will be conveyed to the lead inspector.

Exit Meeting The team leader will conduct the exit meeting on September 4, 2003 at 1:30 PM. Team members are expected to provide the team leader a final short summary of findings by Friday August 29. Team members do not need to attend the final exit meeting.

VII Starfire Information This special inspection is estimated to require approximately 960 (+/- 80) hours of direct inspection effort. The review will include mostly Restart as well as a small sample of Post-Restart corrective action items. Approximately 75% (or 700) of these hours should be spent as direct inspection evaluating effectiveness of the licensees corrective action program in assessment and resolution of identified risk significant issues and review of RAM items for closure (charge to IP 93812 with IPE code of ER). Approximately 25% (or 250) of these hours should be spent in reviewing CRs, LERs, URIs, NCVs, audits, self-assessments and other corrective action related issues to determine effectiveness of licensee corrective actions taken and proposed to resolve the identified issues and determine if they are ready for closure (charge to IP 71152 with IPE code of BI,). We need to fulfill the requirements pertaining to assessment of effectiveness of corrective action process delineated in IP 71152. Preparation and documentation for this inspection will use IPEs, SEP, SED, BIP or BID. The direct inspection hours do not include time spent in travel, entrance or exit meetings, debriefing the residents, checking on e-mail, or keeping track of hours to correctly credit them. However, it does include time spent in team meetings and in preparing for team meetings.

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General Information Checking E-mail and Other Such Activities For planning purposes, the lead inspector has assumed that each inspector will spend a maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> each week of the inspection, maximum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, checking e-mail or doing other activities not directly related to the inspection. This time, if used, should be charged to general administration.

Travel Charges All travel time is to be charged in HRMS to an IPE code of "AT", including travel during non-regular hours (see below). For planning purposes, a total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> travel is allotted for travel one way to the site.

Overtime The lead inspector has requested authorization of up to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of overtime for each inspector for each of the onsite weeks. The overtime is to only be used to meet the inspection requirements and must be claimed in HRMS if used. Any overtime spent traveling (although there shouldn't be any) also must be claimed in HRMS using the overtime code of "ADDLT".

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Master Table and Status of Corrective Action Items from CATI Inspection Plan (Rev. 8-88-03)

Open: Reviewed selected/assigned Restart corrective action(CA) item(s) listed in the CR. One or more CA item(s) reviewed remains open due to additional actions needed by the licensee prior to closure. Will be reviewed by team when action completed and item(s) closed.

Closed: Completed review of the selected Restart or (Post Restart) CA item(s).

Licensees actions to address all Restart issues were found to be appropriate. No concerns were noted by the team. The Items reviewed can be closed in the report.

If concerns were identified by the team, document the concern and leave the item open until licensee addresses the concern.

Not Reviewed: Licensee actions to address these Corrective Action Item(s) has not been completed yet. Will be reviewed as they are classified as completed.

Post Restart: For Post Restart CA items assess whether this item was classified correctly as Post Restart or should it be Restart ?

Rollover If a selected corrective action item was rolled over into another CR we need to continue the review of the corrective action item in the CR it was rolled into to determine if the problem was adequately resolved.

Note: Where a Condition Report was generated as a result of NRC findings please note it at the end of your writeup under the status summary. Also, if you reviewed CA items in CRs that are not listed in the table, please add them to the table and note that this is a new item.

General Guidance for Team Review the selected Restart CA items that have been approved/closed. Do not review open CA items. From now on we will review only Restart items The main objective of this Corrective Action inspection is to assess effectiveness of licensees corrective action process to address the findings noted in each corrective action item you review.

Determine if licensee threshold for identification of adverse conditions and prioritization of these findings is appropriate. Are licensees actions to assess the issues to identify the cause(s) and the generic implications, and correct the problem in a timely manner to prevent recurrence appropriate.

Is the licensees audits and assessments process effective in identifying adverse to quality conditions before they reveal themselves and before outside assessments identify the problems.

Are they implementing their corrective action program effectively ? How is it different from before the event ?

Make sure you examine licensee actions to resolve the Big Picture issues and not just individual actions to address findings in each CRs. For example, many CRs and their associated CA items 14

have been issued to document EDG related electrical and mechanical technical issues. Many of these CRs have been rolled over making it difficult to determine if all issues were captured and appropriately addressed. We need to determine if collectively all of the technical Restart issues have been addressed and resolved before they can conclude that all EDGs related issues have been addressed.

If you identify a potential violation, discuss it during the team meetings and make sure you follow the guidance in 0612 (report) and 0609 (SDP) if it applies, have all the information/facts you need to write the violation prior to leaving the site.

You need to provide a writeup for the report, commensurate with each issue you review.

Table Number Subject Assigned Status RAM L-90 Farber Closed: See writeup for 02-Lochb Did FENOC properly 09314 (see evaluate problems raised URI-42) during the system CR assessments at D-B for 0209314 reportability under 10 CFR 50.72 and 50.73?

RAM LER- Review and Evaluate Patricia Open: See writeup for 02=05590 2002-06 EDG Missile Shield LER.

RAM LER- Review and Evaluate Sherbin Open ???: See writeup for 2002-08 Containment Air Coolers 02=05563 (closed) collective significance Bill--Review past operability and LER. See also Condition determine if NCV.

Report 02-5563.

RAM LER- Degradation of High sherbin Closed: See 02=09739 2002-09 Pressure Injection thermal sleeves.

RAM C-02 DG loading - CR # 02-8482 Baxter Open: See writeup for 02-08482 (also see CR 02-05922 &

05925)

RAM NCV-06 Lack of a design basis Sherbin Open analysis for containment IR 02-14-01a isolation valve backup air CR 02-07750 supplies RAM NCV-07 Inadequate blowdown Sherbin Open provisions for CAC IR 02-14-01b backup air accumulators CR 02-07750 15

Table Number Subject Assigned Status RAM NCV-08 Non-conservative TS Baxter Closed by Mazzoni value for 90 percent IR 02-14-01i undervoltage relays CR 02-07766-(SR)

RAM NCV-09 Non-conservative relay Baxter Closed by Mazzoni setpoint calculation for IR 02-14-01k the 59 percent CR 02-06737 undervoltage relays CR 02-07646-(SR)

RAM NCV-10 No analytical basis for the Lougheed Open setpoint to swap service IR 02-14-01v water system discharge CR 02-07802 path RAM NCV-11 Lougheed Open SW surveillance test did IR 02-14-02a not use worst case values CR 02-07781 RAM NCV-12 Inadequate corrective Lougheed Open actions related to SW IR 02-14-03d pump discharge check CR 02-07657 valve acceptance criteria RAM NCV-13 Failure to perform TS Sherbin Closed to licensee surveillance requirement amendment-per Christine for HPI pump following IR 02-14-04 maintenance CR 02-06996 RAM SUP-15 Review of Licensee Team Not Reviewed Control Systems for Identifying, Assessing, and Correcting Performance Deficiencies: Determine whether licensee evaluations of, and corrective actions to, significant performance deficiencies have been sufficient to correct the deficiencies and prevent recurrence. IP 71152 16

Table Number Subject Assigned Status RAM SUP-16 Review of Licensee Falevits Open: Review of QA audits Control Systems for and licensee self assessments Identifying, Assessing, conducted since March 2002 and Correcting indicated that the CAP Performance implementation areas Deficiencies: Evaluate assessed were rated as either the effectiveness of audits Marginal, Inadequate or and assessments Unacceptable. QA has performed by the quality decided to increase audit assurance group, line activities in this area. Still organizations, and need to review outside external organizations. IP organization assessment.

71152 (CATI to review INPO effectiveness of audits and assessments of CAP only)

RAM SUP-20 Farber Closed: This item was not formally reviewed; however, the inspector reviewed Review of Licensee condition report #s 02-06341 Control Systems for (written 09/20/2002), 02-07042 Identifying, Assessing, (written 09/30/2002), and and Correcting 077547 (written 10/14/2002)

Performance which addressed Operating Deficiencies: Evaluate Experience problems. The the effectiveness of the three condition reports were organization's use of open and no corrective actions industry information for had been determined or taken previously documented for any of the three even performance issues. IP though CR 02-07547 was 71152 classified as a restart item. It is evident that RAM item number SUP - 20 has not been adequately addressed.

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Table Number Subject Assigned Status RAM SUP-27 Assessment of Bennett Closed : We have read the Performance in the major root causes Reactor Safety Strategic 02-0891(per Christie)

Performance Area:

Inspection Preparation:

Review licensee analyses of corrective actions related to specific findings and general audits where available. IP 71152 RAM SUP-30 Assessment of Team Open: Need inputs from team Performance in the members reviewing design Reactor Safety Strategic products Performance Area: Key Attribute - Design:

Assess the effectiveness of corrective actions for deficiencies involving design. IP 71152 RAM SUP-41 Assessment of Team Open: Need inputs from team Performance in the members reviewing design Reactor Safety Strategic products.

Performance Area: Key Attribute - Procedure Quality: Assess the effectiveness of corrective actions for deficiencies involving procedure quality. IP 71152 18

Table Number Subject Assigned Status RAM SUP-44 Assessment of Walker Open: This item was not Performance in the Farber reviewed. Actions on this item Reactor Safety Strategic must be reviewed at a later Performance Area: Key date.

Attribute - Equipment Performance: Assess the effectiveness of corrective actions for deficiencies involving equipment performance, including equipment designated for increased monitoring via implementation of the Maintenance Rule. IP 71152 RAM Potential impact of Baxter Closed corrosion on the ground URI-13 function of electrical IR 02-12-02 conduit in containment see writeup for CR-06788 RAM Potential failure to follow Baxter Open the procedure for IR 02-12-03 URI-14 Raychem splice removal See 02-05459(closed) on electrical cables RAM Failure to perform Sherbin Open comprehensive Moderate URI-15 Energy Line Break IR 02-14-01c analysis See writeup for CR 02-07757 RAM Lougheed Open Lifting of Service Water URI-16 IR 02-14-01d See writeup for Relief Valves CR 02-07879 RAM Inadequate SW pump Sherbin Open URI-17 room temperature IR 02-14-01e analysis See writeup for CR 02-07188 RAM Sherbin Open Inadequate SW pump IR 02-14-01f URI-18 room steam line break See writeup for CR 02-07475 analysis CR- 05262 19

Table Number Subject Assigned Status RAM Baxter Closed:

Inadequate cable IR 02-14-01g URI-19 ampacity analysis See writeup for CR 02-06893(Closed)

RAM Inadequate flooding Sherbin Open URI-20 protection for the SW IR 02-14-01h pump house See writeup for CR 02-07714 RAM Baxter Open NCV-08 ?

Poor quality calculation IR 02-14-01j URI-21 for 90 percent See writeup for CR 02-undervoltage relays 07633(SR)

RAM Inadequate calculations Farber Closed for control room operator IR 02-14-01l dose (GDC-19) and See writeup for CR 02-06701 URI-22 offsite dose (10 CFR Part CR 02-07701 100) related to HPI pump minimum flow valves RAM Farber Closed Other GDC-19 and 10 URI-23 IR 02-14-01m CFR Part 100 issues See writeup for CR 02-07713 RAM HPI Pump Operation Sherbin Open NCV ???

URI-24 Under Long Term IR 02-14-01n Minimum Flow See writeup for CR 02-07684 RAM Sherbin Open NCV ??? Past Some small break LOCA operability ?

URI-25 sizes not analyzed IR 02-14-01o LER 2003-003 See writeup for CR 02-06702 RAM Sherbin Closed: see CR-02-06438 Inadequate SW flow URI-26 IR 02-14-01p analysis RAM Lougheed Open Inadequate SW thermal IR 02-14-01q URI-27 analysis See writeup for CR 02-05372 CR 02-07716 RAM Sherbin Open Inadequate UHS IR 02-14-01r URI-28 inventory analysis See writeup for CR 02-05986 CR 02-07692 20

Table Number Subject Assigned Status RAM No Valid Service Water Sherbin Open URI-29 Pump Net Positive IR 02-14-01s Suction Head Analysis See writeup for CR 02-05923 RAM Sherbin Closed SW source temperature IR 02-14-01t URI-30 analysis for AFW See writeup for CR 02-06108, (see CATI-0216)

RAM Baxter/Maz Closed Inadequate short circuit zoni IR 02-14-01u URI-31 calculations See writeup for CR 02-06837 CR 02-06302 RAM Sherbin Open Inadequate SW system URI-32 IR 02-14-02b flow balance testing See writeup for CR 02-06064 RAM Inappropriate SW pump Sherbin Closed URI-33 curve allowable IR 02-14-03a degradation See writeup for CR 02-07468 RAM Lougheed Closed Repetitive failures of SW URI-34 IR 02-14-03b relief valves CR 02-07995 RAM Non-Conservative Lougheed Open Differences in UHS IR 02-14-03c URI-35 Temperature See writeup for CR 02-07716 Measurements RAM Non-Conservative Sherbin Closed containment air cooler IR 02-14-03e URI-36 mechanical stress See writeup for CR 02-05563 analysis (SW)

RAM URI-42 Inadequate Farber Open Implementation of the IR 02-17 Corrective Action Process NCV Which Led to Not Identifying a Potentially See L-90 Reportable Issue CR-02-09314 regarding the containment air coolers.

( CR-02-09314) 21

Table Number Subject Assigned Status AIT 02- Reactor Operation with Farber Not Reviewed (We will close 01128 Pressure Boundary the technical issues but not Leakage 02-08-01 OIs)

AIT 02-08-0 Reactor Vessel Head Farber Not Reviewed 2 Boric Acid Deposits AIT 03- Containment Air Cooler Farber Not Reviewed 00120 Boric Acid Deposits 02-08-03 AIT 99- Radiation Element Filters Farber Not Reviewed 00882 02-08-04 AIT 94- Service Structure Farber Not Reviewed 00025 Modification Delay 02-08-05 AIT 01- Reactor Coolant System Farber Not Reviewed 02862 Unidentified Leakage Trend 02-08-06 AIT Inadequate Boric Acid Farber Not Reviewed Corrosion Control Program Procedure 02-08-07 AIT Failure to Follow Boric Farber Not Reviewed Acid Corrosion Control Program Procedure 02-08-08 AIT Failure to Follow Farber Not Reviewed Corrective Action Program Procedure 02-08-09 CA1 01-0282 Determine accident flow Patricia Closed: Non-Restart ?

0 to EDGs if normal flow CR - open; CAs: 4 all closed was limited to 1050 Related to apparent CCW high g.p.m. flow to EDG Jacket Water HX.

CAs closed without resolving the issue. Refer to CR 02-03027, 02-03833 and CR 03-02220 SHAI 02-0041 DC Voltage Drop Mazzoni Not Reviewed 2 Calculation 22

Table Number Subject Assigned Status 2-2 02-0265 Inadequate ventilation for Sherbin/Ba Open: Restart: CR - open; 8 rooms 323, 324, 325 xter CAs - 8 open; CAs - 7 closed; (4160 V/A-2) This is a problem with ventilation to the switchgear rooms. Licensee is revising the heat load calc to remove conservatism. Its not finished yet. I would have to look at this when completed. Also there will be a special test performed to confirm heat loads.

CA1 02-0302 Continued erosion of the Patricia Closed: Restart CR - open; 7 EDG heat exchangers at CAs - 2 open; CAs - 1 closed; high flow levels. tied to 01-02820 LIR 02-0420 LIR-EDG: Oxidation build Baxter Open: 4 CA s required, two 2 up on fuses were designated as having been completed, however, the required hardware change for one of these had not been done. The two open CAs were classed as post restart items.

2-2 02-0467 LIR-AFW-Strainers Lougheed Open: Restart; investigation 3 limiting particle size completed; 15 CA's; 8 closed; (AFW/A-2) 8 open, 2 Rollins; mod (which is major item) still not done 2-2 02-0538 LIR EDG-Step 1 block Mazzoni/B Reviewed by Mazzoni/Daley.

5 loading calculation axter CA-13 still open, Make sure all C-EE-024.01-006 IS other Restart CAs have been inadequate (EDG/A-2) reviewed.

23

Table Number Subject Assigned Status Potential failure to follow Baxter Closed: CR 02-05459 written the procedure for on 08/06/02 to address the Raychem splice removal issue. The CR required 4 on electrical cables IR CA's, 2 of which had been 02-12-03 URI-14 completed. The 2 open corrective actions were 02-0545 RAM required to be completed prior 9

to restart. These 2 CAs were scheduled to be completed on or before 04/13/03. Additional review is needed on this item after the additional correction actions are complete.

24

Table Number Subject Assigned Status Sherbin Closed: 1 CA open, 5 CAs closed. Stress analysis concluded that CACs were operable in the past regarding structural concerns identified in CR 02-05563. The structural report concluded on page 9 that...Based on the lack of significance or the continued structural acceptability identified with the numerous finding associated with the CAC coil modules and their support structure, the CAC Operability assessment is considered to be unaffected by the composite findings of all currently identified, 02-0556 structural-related CAC 3 Non-conservative concerns One question was containment air cooler asked (CATI-0059) to obtain RAM URI-36 mechanical stress ASME Code F, which was analysis (SW) IR used in the structural analysis LER-20 02-14-03e as a reference. The ASME 02-08 Code was used appropriately in the evaluation. The issue can be closed when EWR 02-05563 is closed, which installed the new service water trees. LER MISSED ON 1/31/03. Rev 1 to LER was submitted on May 8. See discussion of CR 03-00120 in this report for further information. Another CR written during inspection based on statement of past operability made in LER. See new CR 03-03980 (Closed) for further info. With this one exception on past operability statement, no deficiencies were noted in review of 25

Table Number Subject Assigned Status RAM 02-0559 Review and Evaluate Patricia Open: Restart; CR written to 0 EDG Missile Shield LER. document non- acceptance of 02- LER-2002-06 Operability Evaluation 02-0036 04146 URI 02-19-01 that justified a degraded condition for EDG-1 and EDG 2 tornado missile shields. The condition was originally identified in CR 02-04146.

CA-3 of CR 02-04146 covered rework to the degraded condition but was originally identified as post restart. The Team questioned whether this CR was inappropriately closed.

CA-2 to CR 02-4146 required Design Engineering to complete the TORMIS PRA analysis for the Davis-Besse site, including the 50.59. UCN 02-063 incorporated the TORMIS tornado missile probability analysis in the plant design. It concludes, no additional tornado missile barriers required. Because of the low probability of a tornado missile strike determined by TORMIS, CA-3 originally required repair of the missile barrier post restart. Based on the Teams comments, the Licensee has recently changed this CA to repair the degraded missile shields prior to restart.

LIR 02-5633 USAR Sect. 15.4.4.2.6.6 Baxter Closed does not reflect the design 2-2 & 02-0564 LIR-SW: No design Lougheed/ Open: downgraded because 18M 0 bases/flow verification sherbin reviewer felt calc showed that testing of sw flow to AFW SW system could handle the system (SW/A-2) AFW flow; Sherbin reviewed &

had questions 26

Table Number Subject Assigned Status LIR 02-0573 LIR-SW: LAR 96-0008 Farber Not Reviewed 2 not supported by analysis 2-2 02-0574 LIR-SW: lack of SW/UHS Lougheed Open: apparent cause 8 design bases for seismic investigation completed; 4 event and single active actions, none of them done; failure (SW/A-2) asked number of questions during last week because didn't agree with investigation.

System engineer was going back to relook at issue LIR 02-0574 LIR CCW - Non Seismic Sherbin Closed: 2 CAs open, none 9 Piping Over Safety closed. There are Related Components non-seismic pipes (4 inch drain line and insulated domestic water lines) installed in the CCW Pump Room (RM 328) over the pump motors and other safety related conduits and instrumentation. A review found documentation that these lines were recognized as potentially impacting the safety related components mounted below following a seismic event. While the evaluation stated the failure of these lines would not effect the functionality of the safety related components, it is not clear that the water spray from these lines was included.

LIR 02-0584 LIR-EDG-High Farber Not Reviewed 5 Temperature Evaluation ESI Report LIR 02-0584 LIR-EDG-High Farber Not Reviewed 8 Temperature Evaluation-Internal Temperature Rise For Cabinets 27

Table Number Subject Assigned Status 2-2 02-0588 LIR-SW: No ECCS Lougheed Open: apparent cause 5 cooler/containment air investigation completed; CA's cooler inspection not done; had problem with acceptance criteria investigation. Discussed with (SW/A-2) engineers; thought were going to write a CR, but haven't seen it yet.

2-2 02-0590 LIR-AFW-Design bases Lougheed Open: Apparent cause 4 calculations not located investigation completed; (AFW/A-2) corrective actions not done; review not finished LIR & Lougheed Open: Restart: CR - open; RAM CAs: 2 open; 2 closed. NPSH calc received from ProtoPower. The calculation reveals that during a SFAS No Valid Service Water alignment and the strainer in 02-0592 Pump Net Positive backwash, insufficient NPSH 3 Suction Head Analysis IR exists for SW pump P3-3.

02-14-01s URI-29 Closure of CA-4 to CR 02-05923 states that the calculation proves operability of NPSH requirements. The insufficient NPSH was not mentioned.

2-2 02-0594 LIR-RCS: No basis found Lougheed Open: CR in review 2 post 8 for operating limits start CAs open Still reviewing specified in TS 3/4.4.8 Unclear if TS bases are (RCS/A-2) backed up with calcs 02-0598 Sherbin Open: Still under review by Inadequate UHS 6 Lougheed Sherbin.

RAM inventory analysis IR 02-0769 02-14-01r URI-28 2

LIR 02-0606 LIR-EDG: Fuel filter inlet Sherbin Open: 3 CAs, all open. DB 2 operating pressure only records inlet pressure, not exceeds vendor limits for DP. Not doing what vendor change recommended 28

Table Number Subject Assigned Status Sherbin Open: Restart: CR - open; CAs - 2 open; Two issues are Inadequate SW system identified relative to the 02-0606 RAM flow balance testing IR integrated flow balance testing 4

02-14-02b URI-32 that is done on the SW System. Everything is still open.

LIR 02-0620 LIR-EDG Undervoltage Mazzoni Open: This is a restart item.

9 Auxiliary Relays Logic Is The CR was written 09/19/02 Not Tested To Meet GL and no CA s have yet been 96-01 identified. The cause analysis section states that No corrective action is required.

LIR & 02-0621 Excessive indicated Total Sherbin Open: 1CA closed, 1 CA open:

Adds 5 RCS flow error in Revised procedure SP-03358 SP-03358. acceptance criteria to verify that the sum of computer points F857 and F858 are equal to the flow determined from the secondary side heat balance, +/- 2.5%, or other acceptance criteria consistent with the error inherent to the test methodology (calculation of this error is a corrective action in CR 02-06885).

2-2 02-0637 SSDPC: ECCS pump Sherbin Open: Restart: CR - open; 0 room heat load CAs - 1 open; CAs - 7 closed; calculation is As the result of a re-analysis of non-conservative the ECCS Pump Rooms during (HPI/A-2) post-LOCA conditions it is necessary to qualify the equip in the rooms to an air temperature of 140 F for a duration of 30 days. The open CA documents the need for this analysis. See 02-06736 29

Table Number Subject Assigned Status 2-2 02-0638 SSDPC: Enhancement to Lougheed Open: Restart: CR - open; 4 calculation 5020 flooding CAs - None; New issue. The of ECCS rooms due calculation does not consider FWLB (HPI/A-2) flooding of the rooms for Train 2 (i.e., there is no mechanistic way consistent with the calculation method to flood Train 2). It looks like CAs still must be assigned.

Sherbin Closed: Restart Both CRs have been rolled into CR 02-06337. Protoflo calculations02-123 and 02-113 have been performed to address a large number of SW flow issues. These calculations conclude that 02-0643 under design basis conditions, Inadequate SW flow 8 design basis flowrates in some RAM analysis IR 02-14-01p 02-0633 cases are not achievable; the URI-26 3 calculation was reviewed and approved by the Licensee.

Discussions with the Licensee revealed that flows are OK, however nothing was documented in the calculation.

The licencee initiated CR 03-03977 to revise the calculations.

2-2 02-0653 LIR-RCS: PZR vent flow Sherbin Open: This CR is rolled over to 6 capacity has no design CR 02-06547. Calc basis (RCS/A-2) #C-NSA-64.02-031 was initiated and the preliminary results when compared with existing values concludes that the calculated flows for the high point vent system are equivalent or bounded by the existing flow rates. When calculation is issued as final, this issue can be closed.

30

Table Number Subject Assigned Status LIR 02-0666 LIR-EDG: Relays SAX, Mazzoni Open: RE-Class as post 1 SEQX, K6&97/C1 are not restart tested to meet GL-96-01 No CA specified.

LIR 02-0666 LIR-EDG Output Modules Mazzoni Open: Re-class as post restart 7 Are Not Tested As Part One CA specified.

Of The Sequencer To Meet GL 96-01 CA1 02- Corrective Action Farber Open: recently downgraded 06677 implementation CRs making CR in progress.

provided by the RIs. Reason for downgrade is questionable and is being reviewed. The reason for downgrade was that this is a new event dissimilar from previous. It is unclear why this is true, especially with both being SCAQ. Still under review.

DG, 02-0670 Potential for Inadequate Sherbin Open: The licensee issued CR RAM 2 HPI pump minimum 02-06702 to document

& 2-2 recirculation following concerns to access the ability LOCA: some small break of the HPI pumps to perform LOCA sizes not analyzed. during SBLOCA. Of the 11 Also potential for CAs in this CR, 7 are still inadequate HPE pump open. DB said LER will be minimum recirculation submitted on this issue, but as following LOCA of 5/26, it has not been (HPI/A-2)IR 02-14-01o submitted. HPI Minflow URI-25 question (CATI-0026) is open 31

Table Number Subject Assigned Status LIR 02-0676 LIR-AFW-CR: CR Sherbin Open: (1 CA) For a small 7 95-0351 addresses the break LOCA with licensing water content of bearing assumptions, AFW is required lube oil. The Justification for the long-term LOCA for continued operation mission time (e.g., 30 days) relies on inputs that are and the SGs will not not bounding for depressurize since no safety mitigation of design basis grade means of secondary accidents using licensing side depressurization is assumptions. available. Clear definitions of long-term periods of operability are needed to ensure that equipment relied upon for long-term accident mitigation is capable and qualified for the required mission times.

LIR 02-0677 LIR-AFW-CR 95-0906 Walker Open: 2 CAs, one completed, 3 Extent of Condition did Farber the other scheduled for not have to be evaluated 3/31/04 due date about a year per PCAQR procedure. from now. This is a Mode 4 No action to prevent restraint.

recurrence. (OE)

Potential impact of Baxter Closed corrosion on ground 02-0678 RAM function of electrical 8

conduit in containment IR 02-12-02 see URI-13 LIR 02-0682 The referenced Sherbin Open: No open CAs.

1 surveillance procedures Baxter Reviewer (Sherbin) has should be revised to questions on AFW pump include a low point flow required flow. See CATI-0169, determination. This flow which resulted in issuance of should be that used in the CR 03-02651.

USAR Section 15 analyses. Ref: Calc.

C-NSA-50.03-022 Rev 2.

02-0683 Baxter Open: CR 02-6302 rolled over Inadequate short circuit 7 to CR 02-7305.

RAM calculations IR 02-14-01u 02-0630 URI-31 2

32

Table Number Subject Assigned Status Inadequate cable Baxter Open: CA written to evaluate 02-0689 RAM ampacity analysis IR voltage drop. Post restart item.

3 02-14-01g URI-19 (REVISED)

DG & 02-0699 HPI Flow Test Sherbin Open: 3 CAs closed, 3 CAs RAM 6 Acceptance Criteria open. T.S. 4.5.2 H requires Versus T.S. 4.5.2.H that "...following completions of Failure to perform TS modifications to the HPI or LPI surveillance requirement subsystems that alter the for HPI pump following subsystem flow maintenance IR 02-14-04 characteristics... " that the NCV-13 affected HPI pump is capable of delivering a total of 750 gpm at 400 psig at the RCS nozzle.

1) This Technical Specification Bill - Was downgrading of cannot be directly verified by this item appropriately test, since system pressure done ? cannot be easily held at 400 psia during full HPI injection.

(The same applies to LPI). 2)

Although not literally stated, it is logically inferred that this head flow characteristic is expected to be maintained at all times when the system is required. Furthermore, this Technical Specification is unclear in that it does not specify whether the flows are to be applied with the minimum recirculation valves open or closed. Additional review is needed on this item after the additional correction actions are complete.

DG 02-0711 EQ Walkdown: Baxter/Om Closed:

0 Unqualified Splice Found ar on Internal Motor Leads Also see CR for HV240a 09027(Closed) 33

Table Number Subject Assigned Status LIR 02-0714 LIR CCW - Lack Of Sherbin Open: There are 5 CAs, 2 8 Functional Testing Of open, 2 closed, 1 Review.

Letdown Cooler And RCP Interlocks are installed on the Interlocks Letdown Cooler and RCP Seal Cooler to prevent overpressurization of CCW piping in the event of a cooler tube rupture. There is no verification of the interlocks between pressure switch actuation and the associated isolation valve (i.e. no test to verify the valves close on a high pressure signal). Since these interlocks provide overpressure protection, functional testing of the pressure switch / isolation valve interlock should be periodically performed.

LIR 02-0715 LIR CCW - Baxter/Om Not Reviewed: Restart; CR -

9 Non-Compliance With ar open; CAs - 1 open USAR Single Failure everything open.

Statements 2-2 02-0716 LIR CCW-Design Lougheed Not Reviewed: apparent 5 performance limits not cause investigation completed; reflected in test no corrective actions procedures (CCW/A-2) 2-2 02-0716 LIR CCW-Lack of CCW Lougheed Not Reviewed: apparent 9 flow verification to cause investigation completed; essential components 4 CA's: 3 done, 1 open, rolls (CCW/A-2) in 3 other CR's.

34

Table Number Subject Assigned Status Sherbin Open: Restart; CALC 67.005, Service Water Pump Room Ventilation System Capability -

some non-conservative assumptions and comments were identified with respect to this calculation. Based on Inadequate SW pump NRC comments, the room temperature calculation was revised and analysis: concluded that design basis 18M 02-0718 Non-conservative temperature (40-104) could not 8 assumption in calc be maintained during both RAM 67.005, SW ventilation winter and summer. This capacity IR 02-14-01e requires a modification to seal URI-17 and close the penthouse louvers to prevent heat loss during winter. This should be considered an NCV. Although both winter and summer conditions must be addressed, there appears to be no CA that addresses the summer issue.

35

Table Number Subject Assigned Status LIR 02-0723 LIR-AFW: The interim Sherbin Open:1 CA open. The auxiliary 6 revision of the AFW feedwater system has a basic system description requirement to supply water to indicates pump capacity the steam generators (SGs)

(flow vs. head) while they are pressurized.

requirements beyond the This has been previously current design capabilities quantified as a requirement to of the AFW pumps supply 600 gpm to a steam generator that is at a pressure of 1050 psig (the design pressure of the SGs).In the SD revision in process, the pressure requirement is being changed to 1155 psig with the flow rate of 600 gpm being unchanged. The reviewer (Sherbin) has questions on AFW pump required flow at SG pressure of 1155 psig. See CATI-0169, which resulted in issuance of CR 03-02651 36

Table Number Subject Assigned Status 18M 02-0737 LIR-CCW-SW to CCW Sherbin Closed: This CR has 5 CAs, 8 makeup line flow 2 open & 3 closed. Sherbin verification test questioned calculation discrepancies contained in CR that determined adequate flow could be supplied from SW to CCW. In particular, calc had a math error, and calc conclusion stated that the normal dp between SW and CCW is at least 50 psi.

Consideration of post accident operation with potentially less dp is not addressed. A lower dp is nonconservative. A new CR number 03-00410 was written as result of questions on calc. Initial review by DB indicates calc must be changed, but new values are within the acceptance criteria for makeup.

Adds 02-0740 Reactor Coolant Pump Lougheed Closed: Need to follow up on 2 Vendor Technical Manual ensuring licensee is going to Closure Stud Elongation write CR on revision to calc Specification Should be Updated 2-2 02-0740 LIR-SW: Potential loss of Lougheed Open: apparent cause 9 all Service Water due to investigation completed; 12 SR flooding in the sw pump CA's, 8 completed; 4 open room (SW/A-2) done; rolled in two CRs; review not finished (see also 02-07760) 37

Table Number Subject Assigned Status Sherbin Open: CR 02-05262 addresses this concern. There is discussion in this CR to issue ECR 02-0682-00 to 02-0747 Inadequate SW pump remove aux steam line from 5 room steam line break SW pump room, but CA later RAM 02-0526 analysis IR 02-14-01f says that it is enhancement to 2 See URI-18 remove aux steam line. Is it required to be removed, or enhancement? Sherbin asked the question on 6/4 if ECR is required.

Adds 02-0754 Failure to review or Walker Open: No corrective actions

& LIR 7 document the screening Farber were identified and the CR was for 16 NRC Information classified as an administrative Notices. Mode 4 restraint.

(IR 02-11 reviewed this CR) 2-2 02-0759 LIR EDG-High Sherbin/ Open: Restart: CR - open; 6 temperature overall Baxter CAs - 14 open; CAs - 9 (EDG/A-2) closed; The CAs that are open (SR) basically reflect the major modification to the EDG HVAC. The ones closed for the most part are the easy ones. Ref. 02-07599 (IR 02-11 reviewed this CR) 02-5845, 5848 2-2 02-0760 LIR-RCS: Cable Baxter Open: 4 of 9 CAs open.

9 separation high point vent SR valves (RCS/A-2)

Poor quality calculation Baxter Open: CR 02-07633-(SR) 02-0763 for 90 percent rolled over to CR RAM 3 undervoltage relays IR 02-07646-(SR).

02-14-01j URI-21 RAM 02-0765 Inadequate corrective Lougheed Open: rolled to 02-05784, 7 actions related to SW which had its apparent cause pump discharge check investigation completed but all valve acceptance criteria corrective actions canceled; IR 02-14-03d NCV-12 haven't finished review 38

Table Number Subject Assigned Status Sherbin Open: New HPI pumps will be HPI Pump Operation Baxter installed, and new min flow 02-0768 Under Long Term needs to be evaluated. This RAM 4 Minimum Flow IR CR will not be further reviewed 02-14-01n URI-24 ( in the mechanical area) at this time.

LIR 02-0770 Multiple open work Farber Closed: 3 non-startup CAs 1 6 request to install open 2 closed Performed in inspection openings in the coordination with 02-07600.

service structure No problems identified.

02-0805 Other GDC-19 and 10 Farber Closed: Rolled over to RAM 02-0771 CFR Part 100 issues IR 02-07701

& 2-2 3 02-14-01m URI-23 Sherbin Closed: Restart; CR - closed; CAs - 1 closed; This issue required a procedure change.

Inadequate flooding Changes made are OK, protection for the SW however, this issue should be 02-0771 RAM pump house IR considered an NCV since the 4

02-14-01h procedure prior to the change See URI-20 did not address flood barriers and unisolated equipment breeches in the service water pump rooms.

Lougheed Closed: apparent cause Non-Conservative investigation completed; 2 Differences in UHS 02-0771 corrective actions; had RAM Temperature 6 questions on what licensee Measurements IR was doing - answers still owed 02-14-03c URI-35

& inspection not complete 39

Table Number Subject Assigned Status RAM 02-0775 Sherbin Closed : Air operated valves 0 SW1356, SW1357 and SW1358 are containment NCV-06 isolation valves equipped with air volume tanks. The air volume tanks were upgraded to seismic Category 1. On 5/29/03, DB Regulatory Affairs requested that this CR be placed into the reject status in order to add information to the Lack of a design basis Cause Analysis based on analysis for containment published NRC position, which isolation valve backup air requires accumulators function supplies IR 02-14-01a for 30 days, consistent with the NCV-06 & Inadequate accident analysis. CR blowdown provisions for 03-02475(Closed) reports that CAC backup air accumulators are sized accumulators IR according to Calculation 02-14-01b NCV-07 C-ME-011-06-007, which was not yet reviewed by Sherbin.

New CR 03-02475 (Closed) was written because Sherbin identified it was not identified by DB in CR 02-07750. This new CR says new accumulators will be installed with drain valves. These drain valves could be used for blowdown.

40

Table Number Subject Assigned Status Sherbin Open: Condition report 02-07757 was written on 10/09/2002 to address this item. The CR was rolled over into CR 02-06370, which required that eight corrective actions be completed. Seven Failure to perform of these corrective actions had comprehensive Moderate been completed and were 02-0775 RAM Energy Line Break closed. Most of the work on 7

analysis IR 02-14-01c see the remaining corrective URI-15 action, number eight, had been completed. Testing of one important relay was due for completion on or before 04/30/2003. Results of the evaluation of this relay should be reviewed for closing of this item.

DG 02-0776 Flood Analysis Patricia Closed: Restart; CR - open; 0 Discrepancies in the CAs - 2 open; CAs - 2 closed Service Water Pipe There are several non-seismic Tunnel and Valve Rooms pipes in the service water tunnel and valve rooms that have not been specifically evaluated for flooding effects.

The significant issues are still open.(see 02-07409)

RAM 02-0776 Non-conservative TS Baxter Open: CR 02 7766 rolled over 6 value for 90 percent to CR 02-7646-(SR).

undervoltage relays IR 02-14-01i NCV-08 RAM 02-0778 Lougheed Open: apparent cause 1 investigation completed; SW surveillance test did reviewed calculation (which is not use worst case values same one as for 02-7750) and IR 02-14-02a NCV-11 identified concerns. Calc is being revised. Turned over to Sherbin.

41

Table Number Subject Assigned Status RAM 02-0780 Lougheed Open: apparent cause No analytical basis for the

& 2 investigation completed; 2 setpoint to swap service 18M corrective actions; had water system discharge questions on what licensee path IR 02-14-01v was doing - answers still owed NCV-10

& inspection not complete LIR 02-0791 PM Program is Farber Open: 2 CAs were required 3 Unverifiable and both were scheduled for completion 3/15/04 more than a year from now. This CR was considered as a restart item.

LIR 02-0798 LIR-EDG: GE HGA relays Walker Not Reviewed 6 failure (IN 97-12) Baxter Repetitive failures of SW Lougheed Closed: to 02-05738 (URI-16) 02-0799 RAM relief valves IR 02-14-03b 5

URI-34 LIR 02-0808 LIR CCW - Required Lougheed Not Reviewed: Restart, 4 CCW Flow Rate everything open.

Inconsistencies 2-2 02-0825 Concerns with ultimate Lougheed Open: apparent cause 1 heat sink analysis post investigation completed; no LOCA (SW/A-2) corrective actions; review not finished 18M 02-0831 SHRR-Potential Baxter/Om Not Reviewed 2 inadequate surveillance ar testing - transfer to offsite power 42

Table Number Subject Assigned Status LIR 02-0833 The DB-1 licensing basis Sherbin Open: 1 CA open.

1 has to be revised to The issue is that SWS is unambiguously state the required to feed AFW system required event during a DBA. This involves a combinations for the AFW clear understanding of the system during a large and concepts and assumptions small break LOCA. A related to SSE + LOCA distinction must be made (SBLOCA and LBLOCA). The between allowable load DB-1 licensing basis has to be combinations and revised to unambiguously state required event the required event combinations. combinations for the AFW system during a large and small break LOCA. A distinction must be made between allowable load combinations and required event combinations RAM 02-0848 DG loading - CR # Baxter Open: Under Review.

(C- 2 02-8482 (REVISED)

02) (also see CR 02-05922 &

05925) C-02 DG 02-0902 EQ Walkdowns: Baxter Open: Inspector needs to 7 Unqualified Splice Found question appropriateness of on Internal Motor Leads closure. (REVISED) for HVCF5B 2-2 02-0903 LIR EDG-Single failure of Baxter/Om Open: EDG issue.

8 EDG 2 could inop EDG 1 ar also (EDG/A-2) 43

Table Number Subject Assigned Status RAM 02-0931 Inadequate Farber Closed: 2 restart CAs open; (L-90 4 Implementation of the None closed URI- Corrective Action Process

42) Which Led to Not Identifying a Potentially Reportable Issue regarding the containment air coolers.

IR 02-17 URI-42 Did FENOC properly evaluate problems raised during the system assessments at D-B for reportability under 10 CFR 50.72 and 50.73?

Lochbaum L-90 (see URI-42)

RAM 02-0973 Sherbin Open: Prepare ISI procedures 9 for the routine visual inspection 02-0992 of HPI thermal sleeves 2-1, 8 1-1, and 1-2 stated in LER due 3/7/03, but scheduled 6/17/03 Degradation of High CR 02-09928 is rolled over to Pressure Injection CR 02-09739 which will thermal sleeves. evaluate the conditions of HPI LER-2002-09 Thermal Sleeve 2-1 (HP59). 7 open CAs, 4closed. Lots of work was done here in Root Cause, and the appropriate corrective actions were specified.

44

Table Number Subject Assigned Status DG 03-0012 CAC Thermal Sherbin Open:1 CA closed, 2 open.

0 Performance Roll-up (See Davis Besse committed to SR LER-08) NRC to perform evaluation of collective significance of degraded conditions of Containment Air Coolers which have been documented in various CRs.

Lots of work was done here.

The collective significance of CAC issues has been evaluated. These issues included thermal performance degradation, structural degradation of CAC supports caused by boron, and radiological concerns. A question was raised (CATI-0236) regarding justification of acceptability of reduction in thermal performance related to the time it takes to reduce containment accident pressure to 1/2 the maximum value.

Specifically, the time to 1/2 design pressure went from 16.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to 58.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> with the degraded CACs. This would result in an increase in containment leakage because the pressure stays higher for a longer period of time. Page 14 of collective significance review stated that... exceeding 1/2 containment design pressure within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has no impact on dose consequences... Sherbin questioned how this statement could be made, since pressure stays higher for a longer period of time. A new CR number 03-45

Table Number Subject Assigned Status SHR 03-0051 Calculation error affects Baxter/Om Not Reviewed R 1 Tech Spec value ar SHR 03-0051 Errors in calculation Baxter/Om Not Reviewed R 9 C-ICE-083.03-004 result ar in errors in Technical Specification Allowable Value and test procedures DB-MI-03203 and 04 (I&C and Electrical)

SHR 03-0056 MSLB analysis credits Sherbin Closed: 1CA open, 1 closed, R 1 MSIV closure under MSLB analyses are unclear as reverse flow to whether credit is taken for MSIV Closure in the affected loop which will be subject to reverse flow when the break is between the steam generator and the MSIV.

03- Potential Overload on Baxster Not Reviewed 04375 load center breakers (SR) feeding MCCs LER- AC system analysis Mazzoni/ Reviewing 2003- shows potential loss of Senior 007 offsite power following Resident design basis accident 46