ML033320422
| ML033320422 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/24/2003 |
| From: | Grobe J Division of Nuclear Materials Safety III |
| To: | |
| References | |
| Download: ML033320422 (43) | |
Text
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 MPhillips/klg CLipa JGrobe 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 S. Thomas J. Stang C. Lipa M. Phillips Z. Falevits B. Ruland A. Mendiola 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.
4 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
5 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.
6 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);
7 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.
8
(
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
9 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?
10 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.
11 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.
12 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.
13 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".
14 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
15 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 Lochb (see URI-42)
CR 0209314 Did FENOC properly evaluate problems raised during the system assessments at D-B for reportability under 10 CFR 50.72 and 50.73?
Farber Closed: See writeup for 02-09314 RAM LER-2002-06 Review and Evaluate EDG Missile Shield LER.
Patricia Open: See writeup for 02=05590 RAM LER-2002-08 Review and Evaluate Containment Air Coolers collective significance LER. See also Condition Report 02-5563.
Sherbin Open ???: See writeup for 02=05563 (closed)
Bill--Review past operability and determine if NCV.
RAM LER-2002-09 Degradation of High Pressure Injection thermal sleeves.
sherbin Closed: See 02=09739 RAM C-02 DG loading - CR # 02-8482 (also see CR 02-05922 &
05925)
Baxter Open: See writeup for 02-08482 RAM NCV-06 Lack of a design basis analysis for containment isolation valve backup air supplies Sherbin Open IR 02-14-01a CR 02-07750 RAM NCV-07 Inadequate blowdown provisions for CAC backup air accumulators Sherbin Open IR 02-14-01b CR 02-07750
Table Number Subject Assigned Status 16 RAM NCV-08 Non-conservative TS value for 90 percent undervoltage relays Baxter Closed by Mazzoni IR 02-14-01i CR 02-07766-(SR)
RAM NCV-09 Non-conservative relay setpoint calculation for the 59 percent undervoltage relays Baxter Closed by Mazzoni IR 02-14-01k CR 02-06737 CR 02-07646-(SR)
RAM NCV-10 No analytical basis for the setpoint to swap service water system discharge path Lougheed Open IR 02-14-01v CR 02-07802 RAM NCV-11 SW surveillance test did not use worst case values Lougheed Open IR 02-14-02a CR 02-07781 RAM NCV-12 Inadequate corrective actions related to SW pump discharge check valve acceptance criteria Lougheed Open IR 02-14-03d CR 02-07657 RAM NCV-13 Failure to perform TS surveillance requirement for HPI pump following maintenance Sherbin Closed to licensee amendment-per Christine IR 02-14-04 CR 02-06996 RAM SUP-15 Review of Licensee 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 Team Not Reviewed
Table Number Subject Assigned Status 17 RAM SUP-16 Review of Licensee Control Systems for Identifying, Assessing, and Correcting Performance Deficiencies: Evaluate the effectiveness of audits and assessments performed by the quality assurance group, line organizations, and external organizations. IP 71152 (CATI to review effectiveness of audits and assessments of CAP only)
Falevits Open: Review of QA audits and licensee self assessments conducted since March 2002 indicated that the CAP implementation areas assessed were rated as either Marginal, Inadequate or Unacceptable. QA has decided to increase audit activities in this area. Still need to review outside organization assessment.
INPO RAM SUP-20 Review of Licensee Control Systems for Identifying, Assessing, and Correcting Performance Deficiencies: Evaluate the effectiveness of the organization's use of industry information for previously documented performance issues. IP 71152 Farber Closed: This item was not formally reviewed; however, the inspector reviewed condition report #s 02-06341 (written 09/20/2002), 02-07042 (written 09/30/2002), and 077547 (written 10/14/2002) which addressed Operating Experience problems. The three condition reports were open and no corrective actions had been determined or taken for any of the three even though CR 02-07547 was classified as a restart item. It is evident that RAM item number SUP - 20 has not been adequately addressed.
Table Number Subject Assigned Status 18 RAM SUP-27 Assessment of Performance in the Reactor Safety Strategic Performance Area:
Inspection Preparation:
Review licensee analyses of corrective actions related to specific findings and general audits where available. IP 71152 Bennett Closed : We have read the major root causes 02-0891(per Christie)
RAM SUP-30 Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Design:
Assess the effectiveness of corrective actions for deficiencies involving design. IP 71152 Team Open: Need inputs from team members reviewing design products RAM SUP-41 Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Procedure Quality: Assess the effectiveness of corrective actions for deficiencies involving procedure quality. IP 71152 Team Open: Need inputs from team members reviewing design products.
Table Number Subject Assigned Status 19 RAM SUP-44 Assessment of Performance in the Reactor Safety Strategic Performance Area: Key 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 Walker Farber Open: This item was not reviewed. Actions on this item must be reviewed at a later date.
RAM URI-13 Potential impact of corrosion on the ground function of electrical conduit in containment Baxter Closed IR 02-12-02 see writeup for CR-06788 RAM URI-14 Potential failure to follow the procedure for Raychem splice removal on electrical cables Baxter Open IR 02-12-03 See 02-05459(closed)
RAM URI-15 Failure to perform comprehensive Moderate Energy Line Break analysis Sherbin Open IR 02-14-01c See writeup for CR 02-07757 RAM URI-16 Lifting of Service Water Relief Valves Lougheed Open IR 02-14-01d See writeup for CR 02-07879 RAM URI-17 Inadequate SW pump room temperature analysis Sherbin Open IR 02-14-01e See writeup for CR 02-07188 RAM URI-18 Inadequate SW pump room steam line break analysis Sherbin Open IR 02-14-01f See writeup for CR 02-07475 CR- 05262
Table Number Subject Assigned Status 20 RAM URI-19 Inadequate cable ampacity analysis Baxter Closed:
IR 02-14-01g See writeup for CR 02-06893(Closed)
RAM URI-20 Inadequate flooding protection for the SW pump house Sherbin Open IR 02-14-01h See writeup for CR 02-07714 RAM URI-21 Poor quality calculation for 90 percent undervoltage relays Baxter Open NCV-08 ?
IR 02-14-01j See writeup for CR 02-07633(SR)
RAM URI-22 Inadequate calculations for control room operator dose (GDC-19) and offsite dose (10 CFR Part 100) related to HPI pump minimum flow valves Farber Closed IR 02-14-01l See writeup for CR 02-06701 CR 02-07701 RAM URI-23 Other GDC-19 and 10 CFR Part 100 issues Farber Closed IR 02-14-01m See writeup for CR 02-07713 RAM URI-24 HPI Pump Operation Under Long Term Minimum Flow Sherbin Open NCV ???
IR 02-14-01n See writeup for CR 02-07684 RAM URI-25 Some small break LOCA sizes not analyzed Sherbin Open NCV ??? Past operability ?
IR 02-14-01o LER 2003-003 See writeup for CR 02-06702 RAM URI-26 Inadequate SW flow analysis Sherbin Closed: see CR-02-06438 IR 02-14-01p RAM URI-27 Inadequate SW thermal analysis Lougheed Open IR 02-14-01q See writeup for CR 02-05372 CR 02-07716 RAM URI-28 Inadequate UHS inventory analysis Sherbin Open IR 02-14-01r See writeup for CR 02-05986 CR 02-07692
Table Number Subject Assigned Status 21 RAM URI-29 No Valid Service Water Pump Net Positive Suction Head Analysis Sherbin Open IR 02-14-01s See writeup for CR 02-05923 RAM URI-30 SW source temperature analysis for AFW Sherbin Closed IR 02-14-01t See writeup for CR 02-06108, (see CATI-0216)
RAM URI-31 Inadequate short circuit calculations Baxter/Maz zoni Closed IR 02-14-01u See writeup for CR 02-06837 CR 02-06302 RAM URI-32 Inadequate SW system flow balance testing Sherbin Open IR 02-14-02b See writeup for CR 02-06064 RAM URI-33 Inappropriate SW pump curve allowable degradation Sherbin Closed IR 02-14-03a See writeup for CR 02-07468 RAM URI-34 Repetitive failures of SW relief valves Lougheed Closed IR 02-14-03b CR 02-07995 RAM URI-35 Non-Conservative Differences in UHS Temperature Measurements Lougheed Open IR 02-14-03c See writeup for CR 02-07716 RAM URI-36 Non-Conservative containment air cooler mechanical stress analysis (SW)
Sherbin Closed IR 02-14-03e See writeup for CR 02-05563 RAM URI-42 Inadequate Implementation of the Corrective Action Process Which Led to Not Identifying a Potentially Reportable Issue regarding the containment air coolers.
( CR-02-09314)
Farber Open IR 02-17 NCV See L-90 CR-02-09314
Table Number Subject Assigned Status 22 AIT 02-01128 Reactor Operation with Pressure Boundary Leakage 02-08-01 Farber Not Reviewed (We will close the technical issues but not OIs)
AIT 02-08-0 2
Reactor Vessel Head Boric Acid Deposits Farber Not Reviewed AIT 03-00120 Containment Air Cooler Boric Acid Deposits 02-08-03 Farber Not Reviewed AIT 99-00882 Radiation Element Filters 02-08-04 Farber Not Reviewed AIT 94-00025 Service Structure Modification Delay 02-08-05 Farber Not Reviewed AIT 01-02862 Reactor Coolant System Unidentified Leakage Trend 02-08-06 Farber Not Reviewed AIT Inadequate Boric Acid Corrosion Control Program Procedure 02-08-07 Farber Not Reviewed AIT Failure to Follow Boric Acid Corrosion Control Program Procedure 02-08-08 Farber Not Reviewed AIT Failure to Follow Corrective Action Program Procedure 02-08-09 Farber Not Reviewed CA1 01-0282 0
Determine accident flow to EDGs if normal flow was limited to 1050 g.p.m.
Patricia Closed: Non-Restart ?
CR - open; CAs: 4 all closed Related to apparent CCW high 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 2
DC Voltage Drop Calculation Mazzoni Not Reviewed
Table Number Subject Assigned Status 23 2-2 02-0265 8
Inadequate ventilation for rooms 323, 324, 325 (4160 V/A-2)
Sherbin/Ba xter Open: Restart: CR - open; CAs - 8 open; CAs - 7 closed; 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 7
Continued erosion of the EDG heat exchangers at high flow levels.
Patricia Closed: Restart CR - open; CAs - 2 open; CAs - 1 closed; tied to 01-02820 LIR 02-0420 2
LIR-EDG: Oxidation build up on fuses Baxter Open: 4 CA s required, two 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 3
LIR-AFW-Strainers limiting particle size (AFW/A-2)
Lougheed Open: Restart; investigation completed; 15 CA's; 8 closed; 8 open, 2 Rollins; mod (which is major item) still not done 2-2 02-0538 5
LIR EDG-Step 1 block loading calculation C-EE-024.01-006 IS inadequate (EDG/A-2)
Mazzoni/B axter Reviewed by Mazzoni/Daley.
CA-13 still open, Make sure all other Restart CAs have been reviewed.
Table Number Subject Assigned Status 24 RAM 02-0545 9
Potential failure to follow the procedure for Raychem splice removal on electrical cables IR 02-12-03 URI-14 Baxter Closed: CR 02-05459 written on 08/06/02 to address the issue. The CR required 4 CA's, 2 of which had been completed. The 2 open corrective actions were required to be completed prior 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.
Table Number Subject Assigned Status 25 RAM 02-0556 3
URI-36 LER-20 02-08 Non-conservative containment air cooler mechanical stress analysis (SW) IR 02-14-03e 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, structural-related CAC concerns One question was asked (CATI-0059) to obtain ASME Code F, which was used in the structural analysis as a reference. The ASME 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
Table Number Subject Assigned Status 26 RAM 02-0559 0
02-04146 Review and Evaluate EDG Missile Shield LER.
LER-2002-06 URI 02-19-01 Patricia Open: Restart; CR written to document non-acceptance of Operability Evaluation 02-0036 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 does not reflect the design Baxter Closed 2-2 &
18M 02-0564 0
LIR-SW: No design bases/flow verification testing of sw flow to AFW system (SW/A-2)
Lougheed/
sherbin Open: downgraded because reviewer felt calc showed that SW system could handle the AFW flow; Sherbin reviewed &
had questions
Table Number Subject Assigned Status 27 LIR 02-0573 2
LIR-SW: LAR 96-0008 not supported by analysis Farber Not Reviewed 2-2 02-0574 8
LIR-SW: lack of SW/UHS design bases for seismic event and single active failure (SW/A-2)
Lougheed Open: apparent cause investigation completed; 4 actions, none of them done; 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 9
LIR CCW - Non Seismic Piping Over Safety Related Components Sherbin Closed: 2 CAs open, none closed. There are 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 5
LIR-EDG-High Temperature Evaluation ESI Report Farber Not Reviewed LIR 02-0584 8
LIR-EDG-High Temperature Evaluation-Internal Temperature Rise For Cabinets Farber Not Reviewed
Table Number Subject Assigned Status 28 2-2 02-0588 5
LIR-SW: No ECCS cooler/containment air cooler inspection acceptance criteria (SW/A-2)
Lougheed Open: apparent cause investigation completed; CA's not done; had problem with investigation. Discussed with engineers; thought were going to write a CR, but haven't seen it yet.
2-2 02-0590 4
LIR-AFW-Design bases calculations not located (AFW/A-2)
Lougheed Open: Apparent cause investigation completed; corrective actions not done; review not finished LIR &
RAM 02-0592 3
No Valid Service Water Pump Net Positive Suction Head Analysis IR 02-14-01s URI-29 Lougheed Open: Restart: CR - open; CAs: 2 open; 2 closed. NPSH calc received from ProtoPower. The calculation reveals that during a SFAS alignment and the strainer in backwash, insufficient NPSH exists for SW pump P3-3.
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 8
LIR-RCS: No basis found for operating limits specified in TS 3/4.4.8 (RCS/A-2)
Lougheed Open: CR in review 2 post start CAs open Still reviewing Unclear if TS bases are backed up with calcs RAM 02-0598 6
02-0769 2
Inadequate UHS inventory analysis IR 02-14-01r URI-28 Sherbin Lougheed Open: Still under review by Sherbin.
LIR 02-0606 2
LIR-EDG: Fuel filter inlet operating pressure exceeds vendor limits for change Sherbin Open: 3 CAs, all open. DB only records inlet pressure, not DP. Not doing what vendor recommended
Table Number Subject Assigned Status 29 RAM 02-0606 4
Inadequate SW system flow balance testing IR 02-14-02b URI-32 Sherbin Open: Restart: CR - open; CAs - 2 open; Two issues are identified relative to the integrated flow balance testing that is done on the SW System. Everything is still open.
LIR 02-0620 9
LIR-EDG Undervoltage Auxiliary Relays Logic Is Not Tested To Meet GL 96-01 Mazzoni Open: This is a restart item.
The CR was written 09/19/02 and no CA s have yet been identified. The cause analysis section states that No corrective action is required.
LIR &
Adds 02-0621 5
Excessive indicated Total RCS flow error in SP-03358.
Sherbin Open: 1CA closed, 1 CA open:
Revised procedure 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 0
SSDPC: ECCS pump room heat load calculation is non-conservative (HPI/A-2)
Sherbin Open: Restart: CR - open; CAs - 1 open; CAs - 7 closed; As the result of a re-analysis of the ECCS Pump Rooms during 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
Table Number Subject Assigned Status 30 2-2 02-0638 4
SSDPC: Enhancement to calculation 5020 flooding of ECCS rooms due FWLB (HPI/A-2)
Lougheed Open: Restart: CR - open; CAs - None; New issue. The calculation does not consider 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.
RAM 02-0643 8
02-0633 3
Inadequate SW flow analysis IR 02-14-01p URI-26 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 under design basis conditions, design basis flowrates in some cases are not achievable; the 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 6
LIR-RCS: PZR vent flow capacity has no design basis (RCS/A-2)
Sherbin Open: This CR is rolled over to CR 02-06547. Calc
- 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.
Table Number Subject Assigned Status 31 LIR 02-0666 1
LIR-EDG: Relays SAX, SEQX, K6&97/C1 are not tested to meet GL-96-01 Mazzoni Open: RE-Class as post restart No CA specified.
LIR 02-0666 7
LIR-EDG Output Modules Are Not Tested As Part Of The Sequencer To Meet GL 96-01 Mazzoni Open: Re-class as post restart One CA specified.
CA1 02-06677 Corrective Action implementation CRs provided by the RIs.
Farber Open: recently downgraded making CR in progress.
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.
& 2-2 02-0670 2
Potential for Inadequate HPI pump minimum recirculation following LOCA: some small break LOCA sizes not analyzed.
Also potential for inadequate HPE pump minimum recirculation following LOCA (HPI/A-2)IR 02-14-01o URI-25 Sherbin Open: The licensee issued CR 02-06702 to document concerns to access the ability of the HPI pumps to perform during SBLOCA. Of the 11 CAs in this CR, 7 are still open. DB said LER will be submitted on this issue, but as of 5/26, it has not been submitted. HPI Minflow question (CATI-0026) is open
Table Number Subject Assigned Status 32 LIR 02-0676 7
LIR-AFW-CR: CR 95-0351 addresses the water content of bearing lube oil. The Justification for continued operation relies on inputs that are not bounding for mitigation of design basis accidents using licensing assumptions.
Sherbin Open: (1 CA) For a small break LOCA with licensing assumptions, AFW is required for the long-term LOCA mission time (e.g., 30 days) and the SGs will not depressurize since no safety grade means of secondary side depressurization is 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 3
LIR-AFW-CR 95-0906 Extent of Condition did not have to be evaluated per PCAQR procedure.
No action to prevent recurrence. (OE)
Walker Farber Open: 2 CAs, one completed, the other scheduled for 3/31/04 due date about a year from now. This is a Mode 4 restraint.
RAM 02-0678 8
Potential impact of corrosion on ground function of electrical conduit in containment IR 02-12-02 see URI-13 Baxter Closed LIR 02-0682 1
The referenced surveillance procedures should be revised to include a low point flow determination. This flow should be that used in the USAR Section 15 analyses. Ref: Calc.
C-NSA-50.03-022 Rev 2.
Sherbin Baxter Open: No open CAs.
Reviewer (Sherbin) has questions on AFW pump required flow. See CATI-0169, which resulted in issuance of CR 03-02651.
RAM 02-0683 7
02-0630 2
Inadequate short circuit calculations IR 02-14-01u URI-31 Baxter Open: CR 02-6302 rolled over to CR 02-7305.
Table Number Subject Assigned Status 33 RAM 02-0689 3
Inadequate cable ampacity analysis IR 02-14-01g URI-19 Baxter Open: CA written to evaluate voltage drop. Post restart item.
(REVISED)
DG &
RAM 02-0699 6
HPI Flow Test Acceptance Criteria Versus T.S. 4.5.2.H Failure to perform TS surveillance requirement for HPI pump following maintenance IR 02-14-04 NCV-13 Bill - Was downgrading of this item appropriately done ?
Sherbin Open: 3 CAs closed, 3 CAs open. T.S. 4.5.2 H requires that "...following completions of modifications to the HPI or LPI subsystems that alter the subsystem flow characteristics... " that the affected HPI pump is capable of delivering a total of 750 gpm at 400 psig at the RCS nozzle.
- 1) This Technical Specification cannot be directly verified by test, since system pressure 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 0
EQ Walkdown:
Unqualified Splice Found on Internal Motor Leads for HV240a Baxter/Om ar Closed:
Also see CR 09027(Closed)
Table Number Subject Assigned Status 34 LIR 02-0714 8
LIR CCW - Lack Of Functional Testing Of Letdown Cooler And RCP Interlocks Sherbin Open: There are 5 CAs, 2 open, 2 closed, 1 Review.
Interlocks are installed on the 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 9
LIR CCW -
Non-Compliance With USAR Single Failure Statements Baxter/Om ar Not Reviewed: Restart; CR -
open; CAs - 1 open everything open.
2-2 02-0716 5
LIR CCW-Design performance limits not reflected in test procedures (CCW/A-2)
Lougheed Not Reviewed: apparent cause investigation completed; no corrective actions 2-2 02-0716 9
LIR CCW-Lack of CCW flow verification to essential components (CCW/A-2)
Lougheed Not Reviewed: apparent cause investigation completed; 4 CA's: 3 done, 1 open, rolls in 3 other CR's.
Table Number Subject Assigned Status 35 18M RAM 02-0718 8
Inadequate SW pump room temperature analysis:
Non-conservative assumption in calc 67.005, SW ventilation capacity IR 02-14-01e URI-17 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 NRC comments, the calculation was revised and concluded that design basis temperature (40-104) could not be maintained during both winter and summer. This requires a modification to seal 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.
Table Number Subject Assigned Status 36 LIR 02-0723 6
LIR-AFW: The interim revision of the AFW system description indicates pump capacity (flow vs. head) requirements beyond the current design capabilities of the AFW pumps Sherbin Open:1 CA open. The auxiliary feedwater system has a basic requirement to supply water to the steam generators (SGs) while they are pressurized.
This has been previously quantified as a requirement to 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
Table Number Subject Assigned Status 37 18M 02-0737 8
LIR-CCW-SW to CCW makeup line flow verification test discrepancies Sherbin Closed: This CR has 5 CAs, 2 open & 3 closed. Sherbin questioned calculation 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 2
Reactor Coolant Pump Vendor Technical Manual Closure Stud Elongation Specification Should be Updated Lougheed Closed: Need to follow up on ensuring licensee is going to write CR on revision to calc 2-2 SR 02-0740 9
LIR-SW: Potential loss of all Service Water due to flooding in the sw pump room (SW/A-2)
Lougheed Open: apparent cause investigation completed; 12 CA's, 8 completed; 4 open done; rolled in two CRs; review not finished (see also 02-07760)
Table Number Subject Assigned Status 38 RAM 02-0747 5
02-0526 2
Inadequate SW pump room steam line break analysis IR 02-14-01f See URI-18 Sherbin Open: CR 02-05262 addresses this concern. There is discussion in this CR to issue ECR 02-0682-00 to remove aux steam line from SW pump room, but CA later says that it is enhancement to remove aux steam line. Is it required to be removed, or enhancement? Sherbin asked the question on 6/4 if ECR is required.
Adds
& LIR 02-0754 7
Failure to review or document the screening for 16 NRC Information Notices.
Walker Farber Open: No corrective actions were identified and the CR was classified as an administrative Mode 4 restraint.
(IR 02-11 reviewed this CR) 2-2 02-0759 6
(SR)
LIR EDG-High temperature overall (EDG/A-2)
Sherbin/
Baxter Open: Restart: CR - open; CAs - 14 open; CAs - 9 closed; The CAs that are open 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 SR 02-0760 9
LIR-RCS: Cable separation high point vent valves (RCS/A-2)
Baxter Open: 4 of 9 CAs open.
RAM 02-0763 3
Poor quality calculation for 90 percent undervoltage relays IR 02-14-01j URI-21 Baxter Open: CR 02-07633-(SR) rolled over to CR 02-07646-(SR).
RAM 02-0765 7
Inadequate corrective actions related to SW pump discharge check valve acceptance criteria IR 02-14-03d NCV-12 Lougheed Open: rolled to 02-05784, which had its apparent cause investigation completed but all corrective actions canceled; haven't finished review
Table Number Subject Assigned Status 39 RAM 02-0768 4
HPI Pump Operation Under Long Term Minimum Flow IR 02-14-01n URI-24 Sherbin Baxter Open: New HPI pumps will be installed, and new min flow needs to be evaluated. This CR will not be further reviewed
( in the mechanical area) at this time.
LIR 02-0770 6
Multiple open work request to install inspection openings in the service structure Farber Closed: 3 non-startup CAs 1 open 2 closed Performed in coordination with 02-07600.
No problems identified.
02-0805 RAM
& 2-2 02-0771 3
Other GDC-19 and 10 CFR Part 100 issues IR 02-14-01m URI-23 Farber Closed: Rolled over to 02-07701 RAM 02-0771 4
Inadequate flooding protection for the SW pump house IR 02-14-01h See URI-20 Sherbin Closed: Restart; CR - closed; CAs - 1 closed; This issue required a procedure change.
Changes made are OK, however, this issue should be considered an NCV since the procedure prior to the change did not address flood barriers and unisolated equipment breeches in the service water pump rooms.
RAM 02-0771 6
Non-Conservative Differences in UHS Temperature Measurements IR 02-14-03c URI-35 Lougheed Closed: apparent cause investigation completed; 2 corrective actions; had questions on what licensee was doing - answers still owed
& inspection not complete
Table Number Subject Assigned Status 40 RAM 02-0775 0
NCV-06 Lack of a design basis analysis for containment isolation valve backup air supplies IR 02-14-01a NCV-06 & Inadequate blowdown provisions for CAC backup air accumulators IR 02-14-01b NCV-07 Sherbin Closed : Air operated valves SW1356, SW1357 and SW1358 are containment 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 Cause Analysis based on published NRC position, which requires accumulators function for 30 days, consistent with the accident analysis. CR 03-02475(Closed) reports that accumulators are sized according to Calculation 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.
Table Number Subject Assigned Status 41 RAM 02-0775 7
Failure to perform comprehensive Moderate Energy Line Break analysis IR 02-14-01c see URI-15 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 of these corrective actions had been completed and were closed. Most of the work on the remaining corrective 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 0
Flood Analysis Discrepancies in the Service Water Pipe Tunnel and Valve Rooms Patricia Closed: Restart; CR - open; CAs - 2 open; CAs - 2 closed There are several non-seismic 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 6
Non-conservative TS value for 90 percent undervoltage relays IR 02-14-01i NCV-08 Baxter Open: CR 02 7766 rolled over to CR 02-7646-(SR).
RAM 02-0778 1
SW surveillance test did not use worst case values IR 02-14-02a NCV-11 Lougheed Open: apparent cause investigation completed; reviewed calculation (which is same one as for 02-7750) and identified concerns. Calc is being revised. Turned over to Sherbin.
Table Number Subject Assigned Status 42 RAM 18M 02-0780 2
No analytical basis for the setpoint to swap service water system discharge path IR 02-14-01v NCV-10 Lougheed Open: apparent cause investigation completed; 2 corrective actions; had questions on what licensee was doing - answers still owed
& inspection not complete LIR 02-0791 3
PM Program is Unverifiable Farber Open: 2 CAs were required 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 6
LIR-EDG: GE HGA relays failure (IN 97-12)
Walker Baxter Not Reviewed RAM 02-0799 5
Repetitive failures of SW relief valves IR 02-14-03b URI-34 Lougheed Closed: to 02-05738 (URI-16)
LIR 02-0808 4
LIR CCW - Required CCW Flow Rate Inconsistencies Lougheed Not Reviewed: Restart, everything open.
2-2 02-0825 1
Concerns with ultimate heat sink analysis post LOCA (SW/A-2)
Lougheed Open: apparent cause investigation completed; no corrective actions; review not finished 18M 02-0831 2
SHRR-Potential inadequate surveillance testing - transfer to offsite power Baxter/Om ar Not Reviewed
Table Number Subject Assigned Status 43 LIR 02-0833 1
The DB-1 licensing basis has to be revised to unambiguously state the required event 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.
Sherbin Open: 1 CA open.
The issue is that SWS is required to feed AFW system during a DBA. This involves a clear understanding of the concepts and assumptions related to SSE + LOCA (SBLOCA and LBLOCA). The DB-1 licensing basis has to be revised to unambiguously state the required event 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 (C-02) 02-0848 2
DG loading - CR #
02-8482 (also see CR 02-05922 &
05925) C-02 Baxter Open: Under Review.
(REVISED)
DG 02-0902 7
EQ Walkdowns:
Unqualified Splice Found on Internal Motor Leads for HVCF5B Baxter Open: Inspector needs to question appropriateness of closure. (REVISED) 2-2 02-0903 8
LIR EDG-Single failure of EDG 2 could inop EDG 1 also (EDG/A-2)
Baxter/Om ar Open: EDG issue.
Table Number Subject Assigned Status 44 RAM (L-90 URI-42) 02-0931 4
Inadequate Implementation of the Corrective Action Process 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)
Farber Closed: 2 restart CAs open; None closed RAM 02-0973 9
02-0992 8
Degradation of High Pressure Injection thermal sleeves.
LER-2002-09 Sherbin Open: Prepare ISI procedures for the routine visual inspection of HPI thermal sleeves 2-1, 1-1, and 1-2 stated in LER due 3/7/03, but scheduled 6/17/03 CR 02-09928 is rolled over to CR 02-09739 which will evaluate the conditions of HPI 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.
Table Number Subject Assigned Status 45 DG 03-0012 0
SR CAC Thermal Performance Roll-up (See LER-08)
Sherbin Open:1 CA closed, 2 open.
Davis Besse committed to 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-
Table Number Subject Assigned Status 46 SHR R
03-0051 1
Calculation error affects Tech Spec value Baxter/Om ar Not Reviewed SHR R
03-0051 9
Errors in calculation C-ICE-083.03-004 result in errors in Technical Specification Allowable Value and test procedures DB-MI-03203 and 04 (I&C and Electrical)
Baxter/Om ar Not Reviewed SHR R
03-0056 1
MSLB analysis credits MSIV closure under reverse flow Sherbin Closed: 1CA open, 1 closed, MSLB analyses are unclear as 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.
03-04375 (SR)
Potential Overload on load center breakers feeding MCCs Baxster Not Reviewed LER-2003-007 AC system analysis shows potential loss of offsite power following design basis accident Mazzoni/
Senior Resident Reviewing