ML040490268

Semiannual Report - Status of Implementation of Davis-Besse Lessons Learned Task Force Report Recommendations - Memo J. Dyer/A. Thadani to W. Travers

ML040490268
Person / Time
Site:	Davis Besse
Issue date:	02/20/2004
From:	Dyer J, Thadani A Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research
To:	Travers W NRC/EDO
Moroney B, NRR/DLPM, 415-3974
References
WITS 200300006
Download: ML040490268 (30)

Text

February 20, 2004 MEMORANDUM TO: William D. Travers Executive Director for Operations FROM: J. E. Dyer, Director /RA/ R. W. Borchardt for Office of Nuclear Reactor Regulation Ashok C. Thadani, Director /RA/ J. Strosnider for Office of Nuclear Regulatory Research

SUBJECT:

SEMIANNUAL REPORT - STATUS OF IMPLEMENTATION OF DAVIS-BESSE LESSONS LEARNED TASK FORCE REPORT RECOMMENDATIONS By memorandum dated March 7, 2003, the Office of Nuclear Reactor Regulation and the Office of Nuclear Regulatory Research submitted an overall plan to implement the recommendations of the Davis-Besse Lessons Learned Task Force (LLTF). The overall plan contains four separate action plans to address, as a minimum, the high-priority items in the areas of:

(1) Stress Corrosion Cracking (SCC); (2) Operating Experience; (3) Inspection, Assessment, and Project Management; and (4) Barrier Integrity Requirements. The remaining lower-priority items are being addressed through the agencys Planning, Budgeting, and Performance Management (PBPM) process. The overall plan also requires semiannual reports that provide the status of implementation of all LLTF recommendations and identify changes to the action plans.

This is the second status report, which covers the period from September 2003 to February 2004. Attachment 1 to this memorandum provides the current status of implementation of all Davis-Besse LLTF Report recommendations. Attachment 2 provides the latest update of the action plan milestones. All high-priority activities scheduled for this period were completed.

Several lower-priority items were also completed, but some were rescheduled as work progressed, based on changes in the projected work scope, availability of resources, and the need to integrate these activities with other emerging work.

The following discussion summarizes the major activities during this report period.

1. Assessment of Stress Corrosion Cracking During this period, activities related to Reactor Pressure Vessel (RPV) Head Inspection Requirements included continued monitoring of licensee outage inspection results pursuant to Order EA-03-009, following up with plants discovering defects, and evaluating requests for alternatives to the Order. Common issues in numerous approved relaxation requests led to a revision to the Order that was issued in February 2004. The revised Order reduced some inspection requirements while maintaining adequate protection, and will result in a reduction in burden on licensees and more efficient use of NRC resources.

W. Travers Development of a plan and technical basis for incorporating the inspection requirements of Order EA-03-009 into Title 10 of the Code of Federal Regulations, Section 50.55a was deferred to allow the staff to concentrate on evaluating the results of current inspections, to process a change to the Order, and to develop additional generic communications that address emerging issues, such as leakage in pressurizer nozzles. The interim inspection guidelines continue to provide adequate protection. We expect to submit a rulemaking plan for Commission approval by June 2004. The rulemaking process is expected to take approximately 2 years.

The staff will also continue to interact with the industry on the industrys proposed inspection guidelines. The staff will review the proposed guidelines and associated technical basis, when submitted. These are anticipated to form the basis for changes to the American Society of Mechanical Engineers (ASME) Code inspection requirements.

The staff also evaluated licensee responses to Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity, which was issued in August 2003. The staff also reviewed licensee reports of inspection of reactor vessel lower head penetrations during fall refueling outages.

2. Assessment of Operating Experience During this period, the interoffice Operating Experience Task Force, under the guidance of an executive Steering Committee, completed its comprehensive assessment of the agencys operating experience function and documented its recommendations in a report to the Steering Committee in November 2003. The Steering Committee forwarded the report to line management in January 2004 with instructions to develop an implementation plan. Due to the extent of the report, which contains 24 discrete recommendations, the target date for the implementation plan was moved from January 2004 to April 2004 to provide the additional time needed to develop an adequate plan. The plan will consider increasing resource allocation in order to complete the implementation by the December 2004 target date.

A separate task force has been addressing the medium-priority recommendation to conduct a follow-on verification of licensee actions in response to previous generic communications. The task force performed an initial screening of previous generic communications, and narrowed the scope of the review to five focus areas. The plan for performing the verification will be reviewed and approved by the NRR Leadership Team.

3. Evaluation of Inspection, Assessment, and Project Management Guidance The scheduled high-priority recommendations included in the action plan were completed.

Inspection program guidance was revised to provide more focused inspections and follow-up to long-standing equipment issues. Program guidance was enhanced regarding NRC oversight of plants in extended shutdowns. Enhancements to inspector training included implementation of a new read and sign training program. Training modules were developed for boric acid corrosion, stress corrosion cracking, and the importance of maintaining a questioning attitude.

Guidance to ensure there is adequate documentation when accepting deviations from generic communication recommendations was issued, and a follow-up effectiveness review is in progress.

W. Travers A task force has been addressing the medium-priority recommendation to perform an effectiveness review of actions taken in response to past lessons-learned reviews. A report summarizing the results of their evaluation is scheduled to be issued in April 2004.

4. Assessment of Barrier Integrity Requirements With regard to the assessment of improvements in leakage detection and monitoring, there were no milestones scheduled for completion in this report period. However, there are several studies in progress (e.g., reevaluating the basis for Reactor Coolant System leakage requirements and examining the capabilities of various leakage detection systems), which are targeted for completion during 2004. This research is being conducted through the Barrier Integrity Research Program initiated at the Argonne National Laboratory.

No milestones regarding development of improved barrier integrity performance indicators were scheduled for completion in this period.

Attachments: 1. Status of LLTF Recommendations

2. Action Plan Milestone Tables

ML040490268 NRR-106 OFFICE LPDII-2: Lead PM LPDII-2: LA LPDII-2: SC LPDII: PD NRR: LT NRR:OD NAME BMoroney CHawes for: MLMarshall for: EHackett LMarsh JDyer BClayton AHowe (RWBorchardt for)

DATE 02/20/04 02/20/04 02/20/04 02/20/04 02/20/04 02/20/04 OFFICE RES:OD NAME AThadani (JStrosnider for)

DATE 02/20/04 SEMIANNUAL REPORT - STATUS OF IMPLEMENTATION OF DAVIS-BESSE LESSONS LEARNED TASK FORCE REPORT RECOMMENDATIONS Dated: February 20, 2004 DISTRIBUTION NON-Public NRR Mail Room (WITS20030006)

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Status of Davis-Besse LLTF Recommendations DRAFT 2/17/04 LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status

1. Assessment of Stress Corrosion Cracking 3.1.1(1) Assemble foreign and domestic information High RES(DET) 10/04 Addressed in SCC Action Plan.

concerning Alloy 600 (and other nickel based alloys) Collection of information on cracking nozzle cracking and boric acid corrosion. Analyze is in progress and expected to nickel based alloy nozzle susceptibility to stress complete by 03/04 corrosion cracking (SCC), including other Collection of information on boric susceptible components, and boric acid corrosion of acid corrosion will commence in carbon steel, and propose a course of action and an spring 2004 and is targeted for implementation schedule to address the results. completion by 10/04 3.3.2(1) Develop inspection guidance for the periodic High NRR(IIPB) 03/04 Addressed in SCC Action Plan.

inspection of PWR plant boric acid corrosion control TI 152, issued in 11/03, provides programs. interim inspection guidance for follow-up to Bulletin 2003-02, which includes BACC programs.

IP71111.08 (Inservice Inspection Activities) to be revised.

3.2.2(1) Inspect the adequacy of PWR plant boric acid High NRR (IIPB) 03/04 Addressed in SCC Action Plan.

corrosion control programs. Inspections will commence upon issuance of guidance. A follow-up evaluation of adequacy of inspection guidance will be done after first year of inspections.

ATTACHMENT 1

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(3) Develop inspection guidance or revise existing High NRR (IIPB) 03/04 Addressed in SCC Action Plan.

guidance to ensure that VHP nozzles and the RPV TI 150, issued 08/03, provides head area are periodically reviewed by the NRC interim inspection guidance for during licensee ISI activities. follow-up to Order EA-03-009.

IP71111.08 (Inservice Inspection Activities) to be revised.

3.3.4(8) Encourage ASME Code requirement changes for High NRR(DE) TBD Addressed in SCC Action Plan.

bare metal inspections of nickel based alloy nozzles Staff will review EPRI/MRP for which the code does not require the removal of guidelines (MRP-55 and MRP-75),

insulation for inspections. Also, encourage ASME which are expected to form the basis Code requirement changes for the conduct of non- for ASME code changes, when visual NDE inspections of VHP nozzles. issued. Issuance has been delayed several times. Date will be established when proposed guidelines are issued. NRC management has communicated with industry to encourage timely issuance of proposed guidelines.

NRC Staff participates in ASME Code committees.

Alternatively, revise 10 CFR 50.55a to address 06/06 NRC will proceed with rulemaking to these areas. incorporate EA-03-009 guidelines into 10 CFR 50.55a. A rulemaking plan will be prepared by 06/04.

Rulemaking is expected to take about 2 years.

3.1.4(1) Determine if it is appropriate to continue using the Medium RES 07/03 Addressed in SCC Action Plan.

existing SCC models as a predictor of VHP nozzle Complete Report issued. ML032461221 PWSCC susceptibility.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.7(6) Determine whether ISI summary reports should be Low NRR (DE) TBD Addressed in SCC Action Plan.

submitted to the NRC, and revise the ASME Will be included in ASME code submission requirement and staff guidance revisions per 3.3.4(8) above.

regarding disposition of the reports, as appropriate.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status

2. Assessment of Operating Experience, Integration of Operating Experience into Training, and Review of Program Effectiveness 3.1.6(1) Take the following steps to address the High NRR 09/03 Addressed in Operating Experience effectiveness of programs involving the review of (IROB) Complete Action Plan.

operating experience: (1) evaluate the agencys and Evaluations are complete.

capability to retain operating experience information RES Operating Experience Task Force and to perform longer-term operating experience (OETF) completed development of reviews; (2) evaluate thresholds, criteria, and program objectives and attributes guidance for initiating generic communications; (3) and received management evaluate opportunities for additional effectiveness endorsement (05/03). ML031350156 and efficiency gains stemming from changes in OETF submitted specific program organizational alignments (e.g., a centralized NRC improvement recommendations to operational experience clearing house); executive steering committee in (4) evaluate the effectiveness of the Generic Issues 11/03. ML033350063.

Program; and (5) evaluate the effectiveness of the Steering Committee forwarded to line internal dissemination of operating experience to management for implementation in end users. 01/04. ML040080005.

3.1.6(2) Update NRC operating experience guidance High NRR 12/04 Addressed in Operating Experience documents. (IROB) Action Plan. Implementation plan to and be developed by 04/04.

RES 3.1.6(3) Enhance the effectiveness of NRC processes for the High NRR 12/04 Addressed in Operating Experience collection, review, assessment, storage, retrieval, (IROB) Action Plan. Implementation plan to and dissemination of foreign operating experience. and be developed by 04/04.

RES LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.2.4(1) Assess the scope and adequacy of requirements High NRR 09/03 Addressed in Operating Experience governing licensee review of operating experience. (IROB) Complete Action Plan.

Completed 11/03. Addressed in Section 5 of the OETF report.

3.3.4(2) Strengthen inspection guidance pertaining to the High NRR 12/04 Addressed in Operating Experience periodic review of operating experience. (IROB, Action Plan.

IIPB) To be accomplished in conjunction with 3.1.6 (2) above.

3.3.1(1) Provide training and reinforce expectations to NRC High NRR (IIPB) 12/03 Addressed in Operating Experience managers and staff members to address the Complete Action Plan.

following areas: (1) maintaining a questioning A web-based training process was attitude in the conduct of inspection activities; initiated, by which inspectors log on (2) developing inspection insights stemming from and conduct self-paced training. A the DBNPS event relative to symptoms and record of personnel who complete indications of RCS leakage; (3) communicating the training is available for expectations regarding the inspection follow-up of management review and follow-up.

the types of problems that occurred at DBNPS; and Training modules onrecommended (4) maintaining an awareness of surroundings while topics were issued on the system.

conducting inspections. Training requirements Training modules will be updated and should be evaluated to include the appropriate mix new ones added, as needed.

of formal training and on-the-job training commensurate with experience. Mechanisms should be established to perpetuate these training requirements.

3.3.5(1) Maintain expertise in the subject areas by ensuring High NRR (IIPB) 12/03 Addressed in Operating Experience that NRC inspector training includes: (1) boric acid Complete Action Plan.

corrosion effects and control; and (2) PWSCC of See above comments on web-based nickel based alloy nozzles. training.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.1.2(1) Revise NRC processes to require short-term and Medium NRR TBD Target date to be set upon long-term follow-on verification of licensee actions to (IROB) completion of generic communication address significant generic communications (i.e., review [3.1.2(5)].

bulletins and GLs).

3.1.2(2) Establish review guidance for accepting owners Medium NRR 12/03 NRR Office Instructions LIC-100, group and industry resolutions for generic (DLPM, 06/04 LIC-101 and LIC-105 will be revised communications and generic issues. DE, DSSA) to provide specific guidance on use of owners group commitments in licensing activities.

3.2.3(1) Review a sample of NRC safety evaluations of Medium NRR 12/04 owners group submissions to identify whether (DLPM, intended actions that supported the bases of the IIPB)

NRCs conclusions were effectively implemented.

3.2.3(2) Develop general inspection guidance for the Medium NRR 12/04 DLPM Handbook section on Site periodic verification of the implementation of owners (DLPM, Visits provides instructions to PMs groups commitments made on behalf of their IIPB) for periodic review of commitments.

members. Also, IP 71005 (issued 08/03) provides a mechanism for PMs to obtain Region inspector support in obtaining plant information.

3.1.2(5) Conduct follow-on verification of licensee actions Medium NRR 11/04 A task force performed a screening associated with a sample of other significant generic (IROB, process of candidate generic communications, with emphasis on those involving IIPB) communications in 07/03 using generic communication actions that are primarily criteria approved by management.

programmatic in nature. Selection of generic communications and focus areas was completed in 11/03 following management review and input on priorities. Verification plan presented to NRR LT in 12/03, and currently being revised.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.1.3(2) Conduct follow-on verification of licensee actions Medium NRR 12/04 pertaining to a sample of resolved GIs. (DLPM, IIPB) 3.1.2(3) Establish process guidance to ensure that generic Low NRR (IIPB) 12/03 IMC 0040, Preparing, Revising and requirements or guidance are not inappropriately Complete Issuing Documents fo the NRC affected when making unrelated changes to Inspection Manual was revised in processes, guidance, etc. (e.g., deleting inspection 02/04.

procedures that were developed in response to a generic issue).

3.1.3(1) Evaluate, and revise as necessary, the guidance for Low RES 10/04 MD 6.4 to be revised.

proposing candidate GIs.

3.3.4(7) Reassess the basis for the cancellation of the Low NRR (IIPB) 12/03 Review of canceled procedures in inspection procedures that were deleted by 03/05 progress. Additional time added Inspection Manual Chapter, Change Notice 01-017 because the scope of the review to determine whether there are deleted inspection exceeds the original projection.

procedures that have continuing applicability.

Reactivate such procedures, as appropriate.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status

3. Evaluation of Inspection, Assessment, and Project Management Guidance 3.2.5(2) Revise inspection guidance to provide assessments High NRR (IIPB) 12/03 Addressed in Inspection Program of: (1) the safety implications of long-standing, Complete Action Plan.

unresolved problems; (2) corrective actions phased IP 71152 (Problem Identification and in over several years or refueling outages; and Resolution) was revised in 09/03.

(3) deferred modifications.

3.3.5(4) Develop guidance to address the impacts of IMC High NRR (IIPB) 12/03 Addressed in Inspection Program 0350 implementation on the regional organizational Complete Action Plan.

alignment and resource allocation. Evaluation completed 10/03 (ML033010385).

IMC 0350 revision issued in 12/03.

3.3.7(2) Establish guidance to ensure that decisions to allow High NRR 12/03 Addressed in Inspection Program deviations from agency guidelines and (DLPM) Complete Action Plan.

recommendations issued in generic communications Guidance issued through DLPM are adequately documented. Handbook update in 02/03, and a training package distributed to NRR via NRR web site and by EDO memo to other offices and regions in 04/03.

Followup to assess effectiveness of training materials will be done in 2004.

APP. F Conduct an effectiveness review of the actions Medium NRR 02/04 Task force conducting review.

taken in response to past lessons-learned reviews. (IIPB) 04/04 LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(5) Review the range of NRC baseline inspections and Medium NRR (IIPB) 12/04 plant assessment processes, as well as other NRC programs, to determine whether sufficient programs and processes are in place to identify and appropriately disposition the types of problems experienced at DBNPS. Additionally, provide more structured and focused inspections to assess licensee employee concerns programs and safety conscious work environment.

3.2.5(1) Develop inspection guidance to assess scheduler Medium NRR (IIPB) 12/03 Procedure 71111.15 (Operability influences on outage work scope. Complete Evaluations) was revised in 02/04.

3.3.1(2) Develop inspection guidance to assess repetitive or Medium NRR (IIPB) 12/03 IP 71152 (Problem Identification and multiple TS action statement entries, as well as, the 03/04 Resolution) was revised in 09/03.

radiation dose implications associated with repetitive IMC 2515, App. D (Plant Status) to tasks. be revised.

3.3.3(1) As an additional level of assurance, identify Medium NRR (IIPB 12/04 alternative mechanisms to independently assess and EDO) plant performance as a means of self-assessing NRC processes. Once identified, the feasibility of such mechanisms should be determined.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.7(1) Reinforce expectations for the implementation of Medium NRR 12/03 DLPM Handbook Site Visits section guidance in the PM handbook for PM site visits, (DLPM) 03/04 provides guidance to PMs on coordination between PMs and resident inspectors, activities to be conducted during site and PM assignment duration. Reinforce visits. The Morning Calls section expectations provided to PMs and their supervisors discusses interactions with Region regarding the questioning of information involving personnel.

plant operation and conditions. Also, strengthen the guidance related to the license amendment review Office Instruction LIC-100, Rev. 1 process to emphasize the need to consider current (issued 01/04) provides guidance on system conditions, reliability, and performance data considering current conditions during in SERs. In order to improve the licensing licensing action reviews.

decision-making process, the NRC should Ofice Instruction LIC-101 provides strengthen its guidance regarding the verification of guidance on the amendment review information provided by licensees. process and use of RAIs for obtaining information. IP 71005 (issued 08/03) provides a mechanism for PMs to obtain Region inspector support in obtaining plant information.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.4(1) Review inspection guidance pertaining to refueling Medium NRR (IIPB) 12/03 IP 71111.20 (Refueling and Other outage activities to determine whether the level of 08/04 Outage Activities) was revised in inspection effort and guidance are sufficient given 11/03. Additional changes to be the typically high level of licensee activity during made.

relatively short outage periods. The impact of extended operating cycles on the opportunity to inspect inside containment and the lack of inspection focus on passive components should be reviewed. This review should also determine whether the guidance and level of effort are sufficient for inspecting other plant areas which are difficult to access or where access is routinely restricted.

3.3.4(4) Revise IMC 0350 to permit implementation of IMC Medium NRR (IIPB) 10/03 IMC 0350 revised 12/31/03.

0350 without first having established that a Complete significant performance problem exists, as defined by the ROP.

3.3.2(2) Revise the overall PI&R inspection approach such Low NRR (IIPB) 12/03 Addressed in Inspection Program that issues similar to those experienced at DBNPS Complete Action Plan.

are reviewed and assessed. Enhance the guidance for these inspections to prescribe the format of IP 71152 (Problem Identification and information that is screened when determining which Resolution) was revised in 09/03.

specific problems will be reviewed.

3.3.2(3) Provide enhanced Inspection Manual Chapter Low NRR (IIPB) 12/03 Addressed in Inspection Program guidance to pursue issues and problems identified Complete Action Plan.

during plant status reviews.

IP 71152 (Problem Identification and Resolution) was revised in 09/03.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.3.2(4) Revise inspection guidance to provide for the Low NRR (IIPB) 12/03 Addressed in Inspection Program longer-term follow-up of issues that have not Complete Action Plan.

progressed to a finding.

I P 71152 revised in 09/03.

3.3.3(2) Perform a sample review of the plant assessments Low NRR (IIPB) 03/04 conducted under the interim PPR assessment process (1998-2000) to determine whether there are plant safety issues that have not been adequately assessed.

3.3.4(6) Provide ROP refresher training to managers and Low NRR (IIPB) 12/03 Planning being done by Training staff members. 06/04 3.3.5(2) Reinforce IMC 0102 expectations regarding regional Low NRR (IIPB) 12/03 Discussed at DRP/DRS counterparts manager visits to reactor sites. Complete meeting in July 2003.

E-mail sent to all Division Directors.

3.3.5(3) Establish measurements for resident inspector Low NRR (IIPB) 12/03 Metrics were developed in 12/03.

staffing, including the establishment of program 12/04 ML032410588.

expectations to satisfy minimum staffing levels. Date extended to allow data collection for one annual ROP cycle to establish minimum staffing levels.

3.3.7(5) Fully implement Office Letter 900, Managing Low NRR 05/03 OL 900 implemented by isuance of Commitments Made by Licensees to the NRC, or (DLPM) Complete NRR Office Instruction LIC-105.

revise the guidance if it is determined that the audit of licensees programs is not required. Reports will continue to be submitted.

Further, determine whether the periodic report on Instructions for review are in LIC-105.

commitment changes submitted by licensees to the NRC should continue to be submitted and reviewed.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status

4. Assessment of Barrier Integrity Requirements 3.2.1(1) Improve the requirements pertaining to RCS High RES(DET) TBD Addressed in Barrier Integrity Action unidentified leakage and RCPB leakage to ensure Plan.

that they are sufficient to: (1) provide the ability to Report by Argonne Lab due 07/04.

discriminate between RCS unidentified leakage and Additional actions will be scheduled RCPB leakage; and (2) provide reasonable after review of report..

assurance that plants are not operated at power with RCPB leakage.

3.1.5(1) Determine whether PWR plants should install on- High RES(DET) 03/05 Addressed in Barrier Integrity Action line enhanced leakage detection systems on critical Plan.

plant components, which would be capable of Report by Argonne Lab due 07/04.

detecting leakage rates of significantly less than 1 Additional actions will be scheduled gpm. after review of report..

3.2.1(2) Develop inspection guidance pertaining to RCS High NRR(IIPB) 01/05 Addressed in Barrier Integrity Action unidentified leakage that includes action levels to Plan.

trigger increasing levels of NRC interaction with licensees in order to assess licensee actions in response to increasing levels of unidentified RCS leakage. The action level criteria should identify adverse trends in RCS unidentified leakage that could indicate RCPB degradation.

3.3.3(3) Continue ongoing efforts to review and improve the High RES 12/05 Addressed in Barrier Integrity Action usefulness of the barrier integrity PIs. These review (DRAA) Plan.

efforts should evaluate the feasibility of establishing a PI which tracks the number, duration, and rate of primary system leaks that have been identified but not corrected.

LLTF Lead Target No. LLTF Recommendation Priority Org. Date Status 3.2.1(3) Inspect plant alarm response procedure High NRR (IIPB) 03/05 Addressed in Barrier Integrity Action requirements for leakage monitoring systems to Plan.

assess whether they provide adequate guidance for IP 71111.22 to be revised by 08/04.

the identification of RCPB leakage. Inspections will be done after that.

3.3.4(9) Review PWR plant TS to identify plants that have High NRR TBD Addressed in Barrier Integrity Action non-standard RCPB leakage requirements. (IROB) Plan.

Plants with nonstandard TS were identified in a 07/03 study Pursue changes to those TS to make them (ML031980077).

consistent among all plants. TS changes will be coordinated with other changes in leakage requirements.

3.3.7(3) Evaluate the adequacy of analysis methods Medium RES TBD Deferred due to budget constraints involving the assessment of risk associated with and higher priority work.

passive component degradation, including the integration of the results of such analyses into the regulatory decision making process.

DAVIS-BESSE LLTF ACTION PLAN MILESTONE TABLES ATTACHMENT 2

DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS REGARDING STRESS CORROSION CRACKING Last Update: 02/17/04 Lead Division: DLPM Supporting Divisions: DE, DSSA, DIPM, & DRIP Supporting Offices: RES & Regions Milestone Date Lead Support (T=Target)

(C=Complete)

Part I - Reactor Pressure Vessel Head Inspection Requirements

5. Collect and summarize information 03/04 (T) RES/DET DE available worldwide on Alloy 600, Alloy 690 and other nickel based alloy nozzle cracking for use in evaluation of revised inspection requirements.

[LLTF 3.1.1(1)-High ]

6. Critically evaluate existing SCC models 07/03 (C) RES/DET DE with respect to their continuing use in the ML032461221 susceptibility index. ML032461224

[LLTF 3.1.4(1)-Medium]

7. a. Complete initial evaluation of individual 05/04 (T) DE DLPM plant inspections in response to Bulletins Regions and Orders.

b. Continue to review future inspection Ongoing DE DLPM results until permanent guidelines are Regions issued.

8. Incorporate Order EA-03-009 Note (2) DE DRIP requirements into 10 CFR 50.55a DSSA

1. Develop rulemaking plan 06/04 (T) DLPM

2. Publish proposed rule 06/05 (T)

3. Evaluate/incorporate public comments and publish final rule.

06/06 (T)

9. Monitor and provide input to industry TBD DE RES/DET efforts to develop revised RPV Head Note (1) DSSA inspection requirements (ASME Code RegionsSection XI). Industry

[LLTF 3.3.4(8)-High LLTF 3.3.7(6)-Low]

Milestone Date Lead Support (T=Target)

(C=Complete)

10. Participate in meetings and establish Ongoing DE RES/DET communications with appropriate DLPM stakeholders (e.g., MRP, ASME). DRIP

[LLTF 3.3.4(8)-High] DSSA industry

11. Review and evaluate revised ASME Code TBD DE RES/DET requirements when issued. Note (1)

[LLTF 3.3.4(8)-High]

12. If revised ASME Code requirements are TBD DE DRIP acceptable, establish schedule to Note (1) DIPM incorporate by reference into DSSA 10 CFR 50.55a. RES/DET

[LLTF 3.3.4(8)-High] industry public Part II - Boric Acid Corrosion Control

1. Collect and summarize information 10/04 (T) RES/DET DE available worldwide on boric acid corrosion of pressure boundary materials for use in evaluation of revised inspection requirements.

[LLTF 3.1.1(1)-High]

2. a. Evaluate individual plant responses to 06/03 (C) DE DLPM Bulletin 2002-01 regarding Boric Acid ML031760568 Inspection Programs (60-day responses and necessary follow-up)

b. Issue public document to summarize 07/03 (C) DE DLPM evaluation of plant responses. ML032100653 DRIP

3. Participate in meetings and establish Ongoing DE RES/DET communications with appropriate DLPM stakeholders (e.g.,MRP, ASME). DRIP DSSA industry

4. Evaluate need to take additional 06/03 (C) DE DLPM regulatory actions and determine ML031760568 DRIP appropriate regulatory tool(s). DIPM DSSA Regions

5. Issue Bulletin 2003-02 on Reactor Vessel 08/03 (C) DE DLPM Lower Head inspection ML032320153

6. Develop milestones for additional 07/03 (C) DE DLPM regulatory actions, as necessary. DSSA DRIP Milestone Date Lead Support (T=Target)

(C=Complete)

7. Incorporate revised requirements for Note (3) DE DRIP inspection of lower head and other RCPB DSSA components into 10 CFR 50.55a DLPM

1. Develop rulemaking plan TBD

2. Publish proposed rule TBD

3. Evaluate/incorporate public comments TBD and publish final rule.

8. Review and evaluate the adequacy of 01/05 (T) DE RES/DET revised ASME Code Requirements for Note (1)

Pressure Testing/Leakage Evaluation being developed by the ASME Code,Section XI, Task Group on Boric Acid Corrosion.

Part III - Inspection Programs

1. Develop inspection guidance or revise 03/04 (T) DIPM DE existing guidance to ensure that VHP Regions nozzles and the RPV head area are periodically reviewed by the NRC during licensee ISI activities.

[LLTF 3.3.4(3)-High]

2. Develop inspection guidance that provides 03/04 (T) DIPM DE for timely, periodic inspection of PWR Regions plant BACC programs.

[LLTF3.3.2(1)-High]

3. Develop inspection guidance for DE assessing the adequacy of PWR plant 03/04 (T) DIPM RES/DET BACC programs (implementation Regions effectiveness, ability to identify leakage, adequacy of evaluation of leaks).

[LLTF 3.2.2(1)-High]

4. Perform follow-up evaluation of inspection 03/05 DIPM DE guidance after first year of conducting RES/DET inspections. Regions Notes: (1) Milestone dates are dependent upon issuance of industry proposals.

(2) Requirements for inspection of upper head only will be the subject of this rulemaking.

(3) A rulemaking plan for a comprehensive, performance-based rule will be developed for lower head and other RCPB components. Requirements for upper head inspection may ultimately be included.

DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS REGARDING OPERATING EXPERIENCE PROGRAM EFFECTIVENESS Last Update: 12/31/03 Lead Division: DRIP Supporting Divisions: DE, DSSA, DIPM, & DLPM Supporting Offices: RES & Regions Milestone Date Lead Support (T=Target)

(C=Complete)

Part I - Operating Experience Program: Objective Phase

1. Form Task Force with Steering Committee 03/03 (C) NRR/RES and develop Charter. ML030900117

b. Identify desirable agency operating 04/03 (C) Task Force DRIP, experience program objectives and DIPM, attributes, and DLPM, DE, DSSA, 2.a. Provide documented staff proposals of 04/03 (C) DET/RES, operating experience program objectives ML031200312 DRAA/RES, and attributes. ML031490535 DSARE/RES, 05/03 (C) Regions 2.b. Obtain executive management ML031350156 endorsement.

Part II - Operating Experience Program: Assessment Phase

1. Define functional needs/areas and 9/03 (C) Task Force DRIP, processes to meet objectives and DIPM, attributes. DLPM, DE, DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions

2. Review and evaluate current processes. 9/03 (C) Task Force DRIP,

[LLTF 3.1.6(1)] DIPM, DLPM, DE, DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions

Milestone Date Lead Support (T=Target)

(C=Complete)

3. Identify areas for improvements. 09/03 (C) Task Force DRIP,

[LLTF 3.2.4(1)] DIPM, DLPM, DE, DSSA, DET/RES, DRAA/RES, DSARE/RES, Regions

4. Task Force issues draft report. 09/03 (C) Task Force ML032740058

5. Task Force provides final report to Steering 11/03 (C) Task Force Committee documenting its specific ML033350063 program improvement proposals.

6. Steering Committee sends report to line 01/04 (T) Steering management for implementation detail. Committee 6.a Responsible organizations achieve consensus on proposals to implement. 01/04 (T) NRR/RES Regions Part III - Operating Experience Program: Implementation Phase

1. Develop implementation plan based on 6.a 04/04 (T) NRR/RES Regions in Part II.

1. Implement specific improvements per 12/04 (T) implementation plan (1/04-12/04).

[LLTF 3.1.6(2)]

[LLTF 3.1.6(3)]

[LLTF 3.3.4(2)]

2. Establish processes to monitor 09/05 (T) NRR/RES Regions effectiveness.

Part IV - Inspection Program Enhancements

1. Provide training and reinforce expectations 12/03 (C) DIPM DE, to NRC managers and staff members DSSA, to address the following areas: DET/RES, (1) maintaining a questioning attitude in Regions the conduct of inspection activities; (2) developing inspection insights stemming from the DBNPS event relative to symptoms and indications of RCS leakage; (3) communicating expectations regarding the inspection follow-up of the types of problems that occurred at DBNPS; and (4) maintaining an awareness of Milestone Date Lead Support (T=Target)

(C=Complete) surroundings while conducting inspections.

Training requirements should be evaluated to include the appropriate mix of formal training and on-the-job training commensurate with experience.

Mechanisms should be established to perpetuate these training requirements.

[LLTF 3.3.1(1)]

2. Implement actions to maintain NRC 12/03 (C) DIPM DE, expertise by ensuring that NRC inspector DSSA, training includes: (1) boric acid corrosion DET/RES, effects and control; and (2) PWSCC of Regions nickel based alloy nozzles. [LLTF 3.3.5(1)]

DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS REGARDING INSPECTION, ASSESSMENT, AND PROJECT MANAGEMENT GUIDANCE Last Update: 12/31/03 Lead Division: DIPM Supporting Division: DLPM Supporting Office: Regions Milestone Date Lead Support (T=Target)

(C=Complete)

Part 1 - Evaluation of Inspection Guidance Related To Problem Identification and Resolution The NRC should revise its inspection guidance to provide assessments of: (1) the safety implications of long-standing, unresolved problems; (2) corrective actions phased in over several years or refueling outages; and (3) deferred modifications. [LLTF 3.2.5.(2) High]

The NRC should revise the overall PI&R inspection approach such that issues similar to those experienced at DBNPS are reviewed and assessed. The NRC should enhance the guidance for these inspections to prescribe the format of information that is screened when determining which specific problems will be reviewed.

[LLTF3.3.2.(2) Low]

The NRC should provide enhanced Inspection Manual Chapter guidance to pursue issues and problems identified during plant status reviews

[LLTF3.3.2.(3) Low]

The NRC should revise its inspection guidance to provide for the longer-term follow-up of issues that have not progressed to a finding.

[LLTF3.3.2.(4) Low]

2. Make changes to IP 71152 to require 01/02 (C) DIPM annual follow-up of three to six issues.

2. PI&R focus group assess lessons learned 03/03 (C) DIPM Regions recommendations.

3. Develop draft procedure changes based on 04/03 (C) DIPM Regions PI&R group recommendations and provide ML031390010 to regions for review.

4. Provide training on procedure changes. 09/03 (C) DIPM

5. Issue procedure changes. 09/03 (C) DIPM

Milestone Date Lead Support (T=Target)

(C=Complete)

PART 2 - Evaluation of IMC 0350 Guidance The NRC should develop guidance to address the impacts of IMC 0350 implementation on the regional organizational alignment and resource allocation. [LLTF3.3.5.(4) High]

1. Assess past and present IMC 0350 data 06/03 (C) DIPM Regions and associated inspection approaches. ML031890873

2. Develop enhanced structure to the 08/03 (C) DIPM Regions inspection approach used for IMC 0350 ML032250336 plants.

3. Develop draft revisions to IMC and issue 09/03 (C) DIPM for regional comment.

4. Issue procedure revisions. 12/03 (C) DIPM

5. Include estimated resources for IMC 0350 12/03 (C) DIPM plants into budget cycles. ML033010385 Part 3 - Evaluation of Project Management Guidance The NRC should establish guidance to ensure that decisions to allow deviations from agency guidelines and recommendations issued in generic communications are adequately documented.

[LLTF 3.3.7.(2) High]

1. The DLPM Handbook will be updated with 02/03 (C) DLPM a new section that addresses documenting staff decisions.

2. A training package emphasizing 04/03 (C) DLPM compliance with the requirements of MD ML030300067 3.53 will be developed and distributed to all Offices and regions.

3. Follow up with Offices and Regions to 02/04 (T) DLPM determine effectiveness of training.

ACTION PLAN FOR ADDRESSING DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS REGARDING ASSESSMENT OF BARRIER INTEGRITY REQUIREMENTS Last Update: 12/31/03 Lead Division: RES/DET Supporting Divisions: DRAA,DSARE Supporting Offices: NRR, Regions Milestone Date Lead Support (T=Target)

(C=Complete)

Part I: Leakage

1. Review PWR TS to identify plants that 7/03 (C) NRR/DRIP have non-standard RCPB leakage ML031980277 requirements [LLTF 3.3.4(9):High]

2. Review plant alarm response 3/04 (T) NRR/DIPM RES/DET procedure requirements for leakage monitoring systems and assess their adequacy for identification of RCPB leakage [LLTF 3.2.1(3):High]

3. Re-evaluate basis for RCS leakage 7/04 (T) RES/DET RES/DRAA requirements and assess the RES/DSARE capabilities of currently used and NRR/DSSA state-of-the-art leakage detection NRR/DE systems [LLTF 3.2.1(1):High, NRR/DRIP 3.1.5(1):High] NRR/DIPM

4. Develop recommendations for 1/05 (T) NRR/DIPM RES/DET inspection guidance pertaining to RCS NRR/DE unidentified leakage that includes NRR/DSSA action levels to trigger increasing levels of NRC interaction with licensees in response to increasing levels of unidentified RCS leakage

[LLTF 3.2.1(2):High]

Milestone Date Lead Support (T=Target)

(C=Complete)

5. Develop recommendations for (1) 3/05 (T) NRR/DIPM NRR/DE improving plant procedures for NRR/DRIP RES/DRAA identifying RCPB leakage, (2) RES/DET NRR/DSSA consistent TS, and (3) use of on-line, NRR/DLPM enhanced leakage detection systems on critical components [LLTF 3.1.5(1):High, 3.2.1(1):High, 3.2.1(3):High, 3.3.4(9):High]

6. Use appropriate regulatory tools to TBD NRR/DRIP RES/DRAA implement improved requirements RES/DSARE

[LLTF 3.2.1(1):High] RES/DET NRR/DSSA NRR/DE NRR/DLPM Part II. Performance Indicators (PI)

1. Develop and implement improved 6/04 (T) NRR/DIPM RES/DRAA barrier integrity PI based on current RES/DET requirements and measurements NRR/DE

[LLTF 3.3.3.(3):High] NRR/DSSA Regions

2. Develop and, if feasible, implement an 12/05 (T) NRR/DIPM RES/DRAA additional PI capable of tracking the RES/DET number, duration, and rate of primary NRR/DE system leaks. [LLTF 3.3.3.(3):High] NRR/DSSA Regions

3. Determine feasibility of establishing a TBD RES/DRAA NRR/DIPM risk-informed barrier integrity PI [LLTF NRR/DSSA 3.3.3.(3):High] NRR/DE RES/DET Regions

4. Evaluate the need to modify existing TBD NRR/DIPM RES/DRAA barrier integrity PIs based on potential RES/DET new requirements for RCS leakage NRR/DE from Part 1 [LLTF 3.3.3.(3):High] NRR/DSSA Regions