ML033630695
| ML033630695 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/12/2004 |
| From: | Collins S NRC/EDO |
| To: | Bell H NRC/OIG |
| Jacobson, J B, NRR/DIPM/IIPB, 415-2977 | |
| References | |
| 03-02S, G20030635, TAC MC1098 | |
| Download: ML033630695 (10) | |
Text
LIMITED DISTRIBUTION January 12, 2004 MEMORANDUM TO: Hubert T. Bell Inspector General FROM: Samuel J. Collins /RA/
Deputy Executive Director for Reactor Programs Office of the Executive Director for Operations
SUBJECT:
RESPONSE TO OFFICE OF INSPECTOR GENERAL (OIG) EVENT INQUIRY CASE NO.03-02S (NRCS OVERSIGHT OF DAVIS-BESSE BORIC ACID LEAKAGE AND CORROSION DURING THE APRIL 2000 REFUELING OUTAGE)
The Nuclear Regulatory Commission (NRC) staff has reviewed the subject report and agrees that improvements should be made to our regulatory programs to enhance the NRCs ability to identify and respond to problems such as those identified at the Davis-Besse plant. The issues identified in the subject OIG report are similar to a subset of those identified by the Davis Besse Lessons Learned Task Force (DBLLTF), and as such, corrective actions have already begun or have been completed for each of the OIG findings. Attached to this memorandum is a matrix that contains each of the findings contained in the OIG report, related DBLLTF recommendations, associated corrective actions, and completion status.
While the subject OIG report focused on the inspection program, it is important to recognize that the problem at Davis-Besse represented an institutional failure on the part of the NRC.
Accordingly, the DBLLTF identified concerns with many aspects of NRC's activities. We believe that our planned corrective actions to the DBLLTF recommendations will address these concerns. A full listing of all the DBLLTF recommendations and associated corrective actions is contained in the, "Semiannual Report - Status of Implementation of Davis-Besse Lessons Learned Task Force Report Recommendations," dated August 29, 2003 (Accession Number ML032310212).
Attachment:
As stated LIMITED DISTRIBUTION
LIMITED DISTRIBUTION January 12, 2004 MEMORANDUM TO: Hubert T. Bell Inspector General FROM: Samuel J. Collins /RA/
Deputy Executive Director for Reactor Programs Office of the Executive Director for Operations
SUBJECT:
RESPONSE TO OFFICE OF INSPECTOR GENERAL (OIG) EVENT INQUIRY CASE NO.03-02S (NRCS OVERSIGHT OF DAVIS-BESSE BORIC ACID LEAKAGE AND CORROSION DURING THE APRIL 2000 REFUELING OUTAGE)
The Nuclear Regulatory Commission (NRC) staff has reviewed the subject report and agrees that improvements should be made to our regulatory programs to enhance the NRCs ability to identify and respond to problems such as those identified at the Davis-Besse plant. The issues identified in the subject OIG report are similar to a subset of those identified by the Davis Besse Lessons Learned Task Force (DBLLTF), and as such, corrective actions have already begun or have been completed for each of the OIG findings. Attached to this memorandum is a matrix that contains each of the findings contained in the OIG report, related DBLLTF recommendations, associated corrective actions, and completion status.
While the subject OIG report focused on the inspection program, it is important to recognize that the problem at Davis-Besse represented an institutional failure on the part of the NRC.
Accordingly, the DBLLTF identified concerns with many aspects of NRC's activities. We believe that our planned corrective actions to the DBLLTF recommendations will address these concerns. A full listing of all the DBLLTF recommendations and associated corrective actions is contained in the, "Semiannual Report - Status of Implementation of Davis-Besse Lessons Learned Task Force Report Recommendations," dated August 29, 2003 (Accession Number ML032310212).
Attachment:
As stated DISTRIBUTION: Package Accession Number:ML033630728 See attached page Incoming Accession Number:ML032930385 Response Accession Number:ML033630695 G20030635 OFFICE PM/IIPB SC/IIPB BC/IIPB D/DIPM NAME JJacobson* JAndersen* SRichards* BBoger*
DATE 12/29/2003 12/30/2003 12/30/2003 12/31/2003 OFFICE RIII ADIP NAME GGgrant *SReynolds JCraig* BBoger for for DATE 12/29/2003 12/31/2003 OFFICE D/NRR DEDR NAME JDyer SCollins DATE 01/8/2004 01/12/2004 OFFICIAL RECORD COPY LIMITED DISTRIBUTION
LIMITED DISTRIBUTION DISTRIBUTION FOR GREEN TICKET NO. G20030635 - SAMUEL J. COLLINS RESPONSE TO HUBERT T. BELL DATED: January 12, 2004 NON-PUBLIC W. Travers S. Collins W. Kane C. Paperiello P. Norry W. Dean J. Dyer/W. Borchardt J. Craig D. Weaver OGC OPA OCA NRR Mailroom (EDO #G20020635)
K. Johnson N. Correa B. Boger S. Reynolds S. Richards D. Coe J. Jacobson IIPB R/F G. Grant S. Burns J. Caldwell A. Howell K. Cyr OIG File LIMITED DISTRIBUTION
LIMITED DISTRIBUTION IG Finding Associated DBLLTF Associated Corrective Actions Completion Status Recommendations
- 1. OIG found that NRC 3.3.2.1 - Develop inspection Short term actions - Issued Bulletin Bulletin, Order, and TI Headquarters did not guidance that provides for 2002-02, Reactor Pressure issued.
integrate the issues raised timely, periodic inspection of Vessel Head and Vessel Head in Generic Letters 88-05 PWR plant boric acid corrosion Penetration Nozzle Inspection and 97-01 into NRCs control (BACC) programs. Programs. Issued Order EA inspection program. 009 which established interim 3.2.2.1 - Implement inspection licensee inspection requirements guidance as necessary to for reactor pressure vessel heads assess the adequacy of PWR at PWRs. Issued Temporary BACC programs. Instruction 2515/150 to provide NRC inspection guidance to follow-3.3.4.3 - Develop inspection up on order.
guidance or revise inspection guidance to ensure that vessel Long-term actions - Inspection head penetration nozzles and procedures are being revised.
the reactor head area are Implementation to commence Due 3/04 periodically reviewed by the upon issuance of revised NRC during licensee ISI procedures.
activities.
Awaiting recommendations 3.3.4.2 - The NRC should Operating experience task force from results of Operating strengthen its inspection review completed. Strengthening Experience Task Force.
guidance pertaining to the the agencys review of operating Completion due 12/04.
periodic review of operating experience should provide experience. highlighted information to both managers and inspectors of issues and events that would otherwise not normally be focused on by the inspection program, such as the effects of boric acid corrosion on 3.1.2.5 - Conduct follow-on reactor vessel heads.
verification of licensee actions High priority issues associated with a sample of Polling of regions, NRR, and RES identified.
other significant generic conducted to identify high priority Due 11/04 communications. issues. Formulating approach for LIMITED DISTRIBUTION
LIMITED DISTRIBUTION IG Finding Associated DBLLTF Associated Corrective Actions Completion Status Recommendations
- 2. OIG determined that 3.3.5.1 - Ensure inspector Developed an inspector read and Training module issued and there was ineffective training includes the effects of sign training process and issued completed.
communication among boric acid corrosion and training module on boric acid Region III managers PWSCC of nickel based alloy corrosion.
concerning boric acid nozzles.
leakage and corrosion at Developed an inspector read and Davis-Besse. 3.3.1.1 - Provide training and sign training module on the Training module issued reinforce expectations to importance of maintaining a with completion date set at managers and staff to maintain questioning attitude using the 12/31/03. Counterpart a questioning attitude. Columbia Space Shuttle accident meeting presentations report. Followed up training with complete.
presentations at regional counterpart meetings.
Changes made to IP 71152 to 3.3.2.3 - The NRC should require review of 3-6 annual provide enhanced Inspection samples to allow for in-depth Procedure changes Manual Chapter guidance to review. Changes made to IP complete. First trend pursue issues and problems 71152 to require that the resident review to be completed in identified during plant status inspectors perform a semi-annual June 2004.
reviews. trend report. This change should enhance the NRCs ability to identify equipment trends that by themselves are not particularly risk significant, but might be indicative of a more significant issue and should also provide for enhanced communication of the identified trends throughout the NRC management chain and with licensees.
3.3.4.2 - The NRC should Awaiting recommendations strengthen its inspection Operating experience task force from results of Operating guidance pertaining to the review completed. Strengthening Experience Task Force.
periodic review of operating the agencys review of operating Completion due 12/04.
LIMITED DISTRIBUTION
LIMITED DISTRIBUTION IG Finding Associated DBLLTF Associated Corrective Actions Completion Status Recommendations
- 3. OIG determined that 3.3.1.1 - Provide training and Developed an inspector read and Training module issued Region III managers, while reinforce expectations to sign training module on the with completion date set at planning inspection managers and staff to maintain importance of maintaining a 12/31/03. Counterpart activities for 12 RFO, a questioning attitude. questioning attitude using the meeting presentations reviewed NRC inspection Columbia Space Shuttle accident complete.
reports which documented report. Followed up training with recurring boric acid presentations at regional leakage and its effects on counterpart meetings.
reactor components at Davis-Besse. Region III Developed an inspector read and also received numerous 3.3.5.1 - Ensure inspector sign training process and issued accounts of boric acid training includes the effects of training modules on boric acid leakage and corrosion boric acid corrosion and corrosion and maintaining a from the Davis-Besse PWSCC of nickel based alloy questioning attitude. Followed up Training module issued and Resident Inspectors. nozzles. training with presentations at completed.
However, Region III regional counterpart meetings.
managers did not direct any inspection activities during 12 RFO to verify Changes have been made to IP that FENOC completed its 71152 to require in-depth follow-up action plan, documented of licensee evaluations and in Region III Inspection corrective actions of 3-6 issues per Complete Report 50-346/99010, to year in addition to those issues resolve its boric acid reviewed as part of the biennial leakage and corrosion corrective action team inspection.
problems. Awaiting recommendations 3.3.4.2 - The NRC should Operating experience task force from results of Operating strengthen its inspection review completed. Strengthening Experience Task Force.
guidance pertaining to the the agencys review of operating Completion due 12/04.
periodic review of operating experience should provide experience. highlighted information to both managers and inspectors of issues and events that would otherwise not normally be focused on by the inspection program, such as the LIMITED DISTRIBUTION
LIMITED DISTRIBUTION IG Finding Associated DBLLTF Associated Corrective Actions Completion Status Recommendations
- 4. OIG determined that the 3.3.5.1 - Ensure inspector Developed an inspector read and Training module issued and Senior Resident Inspector, training includes the effects of sign training process and issued completed.
Resident Inspector, and boric acid corrosion and training modules on boric acid possibly the ISI Inspector PWSCC of nickel based alloy corrosion.
reviewed Davis-Besse nozzles.
CR 2000-0782 during Developed an inspector read and 12 RFO. These sign training module on the Training module issued inspectors did not 3.3.1.1 - Provide training and importance of maintaining a with completion date set at recognize the significance reinforce expectation to questioning attitude using the 12/31/03. Counterpart of the boric acid corrosion managers and staff to maintain Columbia Space Shuttle accident meeting presentations described in CR 2000- a questioning attitude. report. Followed up training with complete 0782. presentations at regional counterpart meetings.
Changes have been made to IP 71152 to require in-depth follow-up Complete of licensee evaluations and corrective actions of 3-6 issues per year in addition to those issues reviewed as part of the biennial corrective action team inspection.
3.3.4.2 - The NRC should Operating experience task force Awaiting recommendations strengthen its inspection review completed. Strengthening from results of Operating guidance pertaining to the the agencys review of operating Experience Task Force.
periodic review of operating experience should provide Completion due 12/04.
experience. highlighted information to both managers and inspectors of issues and events that would otherwise not normally be focused on by the inspection program, such as the effects of boric acid corrosion on reactor vessel heads.
LIMITED DISTRIBUTION
LIMITED DISTRIBUTION IG Finding Associated DBLLTF Associated Corrective Actions Completion Status Recommendations
- 5. Region III inspectors at 3.3.5.1 - Ensure inspector Developed an inspector read and Training module issued and Davis-Besse did not relay training includes the effects of sign training process and issued completed.
the information depicted in boric acid corrosion and training modules on boric acid CR 2000-0782 to Region PWSCC of nickel based alloy corrosion.
III managers. nozzles.
Consequently, the information contained in 3.3.1.1 - Provide training and Developed an inspector read and CR 2000-0782 was not reinforce expectation to sign training module on the Training module issued provided to NRC managers and staff to maintain importance of maintaining a with completion date set at Headquarters staff and a questioning attitude. questioning attitude using the 12/31/03. Counterpart was not considered in Columbia Space Shuttle accident meeting presentations NRCs November 2001 report. Followed up training with complete. Presentation decision to allow Davis- presentations at regional given to NRR Executive Besse to operate past counterpart meetings. Training Team and Leadership December 31, 2001. included the need for managers to Team.
seek out minority opinions when making risk-significant decisions.
Changes to IP 71152 to require Procedure changes semi-annual trend reports. This complete. First trend will be a vehicle for documenting review to be completed in equipment trends and allow for June 2004.
clear communication of the issues throughout the management chain.
3.3.4.2 - The NRC should strengthen its inspection Operating experience task force Awaiting recommendations guidance pertaining to the review completed. Strengthening from results of Operating periodic review of operating the agencys review of operating Experience Task Force.
experience. experience should provide Completion due 12/04.
highlighted information to both managers and inspectors of issues and events that would otherwise not normally be focused on by the LIMITED DISTRIBUTION
LIMITED DISTRIBUTION LIMITED DISTRIBUTION