ML040711260

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Revised Minutes of Internal Meeting of the Davis-Besse Oversight Panel (Revised RAM Closure Attachment)
ML040711260
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 03/11/2004
From: Grobe J
NRC/RGN-III
To:
NRC/RGN-III
References
-nr, IMC 0350
Download: ML040711260 (31)
v • d • e


Text

March 11, 2004 MEMORANDUM TO: Davis-Besse Nuclear Power Station IMC 0350 Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA by C. Lipa Acting for/

SUBJECT:

REVISED APRIL 22, 2003 MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL (Revised RAM Closure Attachment)

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 April 22, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel; the System Health Assurance Inspection Plan; the Management and Human Performance Phase 2 Inspection Plan; The Restart Action Matrix (RAM) Items approved for closure; and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Dyer, RIII J. Caldwell, RIII K. Coyne, NRR T. Quay, NRR A. Dunlop, RIII D. Thatcher, NRR DB0350

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

SUBJECT:

REVISED APRIL 22, 2003 MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL (Revised RAM Closure Attachment)

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 April 22, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel; the System Health Assurance Inspection Plan; the Management and Human Performance Phase 2 Inspection Plan; The Restart Action Matrix (RAM) Items approved for closure; and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Dyer, RIII J. Caldwell, RIII K. Coyne, NRR T. Quay, NRR A. Dunlop, RIII D. Thatcher, NRR DB0350 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML040711260.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 RBaker CLipa /RA by C. Lipa Acting for/ JGrobe DATE 03/11/04 03/11/04 03/11/04 OFFICIAL RECORD COPY

MEETING MINUTES: Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE: April 22, 2003 TIME: 1:00 p.m. Central ATTENDEES:

J. Grobe M. Phillips J. Hopkins D. Passehl D. Hills D. Simpkins T. Mendiola H. Neih A. Dunlop J. Rutkowski R. Lickus K. Coyne T. Quay W. Ruland R. Gardner Agenda Items:

1. Debrief Sump Inspection Results K. Coyne discussed the results of his ECCS and Containment Spray System sump inspection. Kevin debriefed his inspection with the licensee on April 11, 2003. His report should be signed out in the next few weeks.
2. Discuss Plant Status and Inspector Insights D. Simpkins provided a briefing on current plant activities.
3. Discuss System Health Assurance Inspection Plan M. Farber discussed his system health assurance inspection plan. The plan was approved with minor comments. The approved plan is attached to these minutes.
4. Discuss Air-Operated Valve and Old Containment Sump Issues Inspection Plan A. Dunlop discussed his air-operated valve and old containment sump issues inspection plan. The Panel determined that the licensee was not ready to support inspection of their program to address design deficiencies with a number of air-operated valves and to support inspection of old containment sump design issues. The Plan will be discussed in the next two to three months.
5. Discuss Corrective Action Team Inspection Status R. Gardner discussed the status of the corrective action team inspection. The inspection was originally envisioned to be complete by April 11, 2003, which was chosen to support the licensees published restart date. However, the licensee did not have the technical issues resolved to support the inspection nor were the technical issues resolved to support plant restart as previously communicated to the NRC. The Panel discussed dates for future conduct of the inspection.
6. Discuss Restart Assessment Team Inspection Plan D. Passehl discussed his restart assessment team inspection plan. A number of recommendations were discussed. The Panel determined that the onsite inspection should be conducted somewhat in advance of the proposed "2nd Mode 4 entry through Mode 2." The Panel also determined that the inspection plan should be presented again approximately three to four weeks in advance of actual conduct of the inspection.
7. Discuss Management and Human Performance Phase 2 Inspection Plan D. Passehl discussed that this inspection plan was previously approved but that a signed copy attached to minutes could not be located. The approved plan is attached to these minutes.
8. Discuss Closed Restart Action Matrix (RAM) Items and Closure Forms M. Phillips presented and the Panel discussed a list of RAM items for closure. The RAM items approved for closure are attached to these minutes.
9. Discuss New Allegations The Panel discussed no new allegations.
10. Discuss Any Allegations for Which an Extension Was Requested M. Phillips presented this discussion. There were no allegations for which an extension was requested.
11. Discuss Letter to the Federal Emergency Management Agency (FEMA).

R. Lickus discussed a proposed letter to FEMA, "Request for Assistance Regarding the Proposed Restart of the Davis-Besse Nuclear Power Plant." The Panel determined that Roland move forward with action to have NRC Headquarters send the letter with the Davis-Besse Oversight Panel Chairman on concurrence.

12. Discuss Action Items Due to time constraints the Panel did not discuss the list of action items but during the course of the meeting identified some new items for action.

NEW ACTION ITEM - Adeline Saso and Karen Gladden to immediately add Dennis Kucinich to the standard distribution list on documents for Davis-Besse.

Then remove Dennis Kucinich from distribution 90 days after the NRC reply to his 10 CFR 2.206 Petition is signed out.

13. Discuss New/Potential Licensing Issues J. Hopkins discussed new or potential licensing issues. Jon discussed that upcoming amendment that the licensee is preparing to support normal operating system pressure testing using their existing high pressure injection pumps.
14. Discuss Emerging Issues on the Weekly Status and Approve Updates The Panel discussed a new agenda item pertaining to emerging issues at the site.

J. Grobe discussed the importance of timely and accurately communicating these issues in the weekly status reports.

15. Discuss Items for Licensee Weekly Calls The Panel discussed several items for the licensee weekly calls.
16. Discuss/Update Milestones and Commitments The Panel reviewed and discussed upcoming milestones and commitments. No new items were identified.

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 24a Discuss making Panel Discuss by June 30, after safety information related to significance assessment complete; HQ/licensee calls publicly 6/27 - Invite Bateman to panel mtg.

available To discuss what else is needed to closeout the CAL (i.e. quarantine plan); 7/2 - NRR not yet ready to discuss; 7/16 - See if procedures have changed on CAL closeout -

does JD need to send letter?; 7/18

- Discussed - is there an applicable regional procedure?; 8/6 -

Discussed. Need to determine the final approach on the core removed from the head and the final approach on the head before the quarantine can be lifted; 8/22 -

Revisit action item after letter sent to licensee confirming plans with old vessel head (head may be onsite longer than originally anticipated); 8/29 - Memo to be sent to Region, with a letter to go out next week; 10/01- Discussed.

1) Conduct NRC staff survey-due 10/7 2)Memo to NRR - due 10/11
3) Region to issue letter; 11/07-Letter required from NRR on head quarantine status; 11/19 - Letter in draft; 01/03 - A. Mendiola to look at phone conference writeups on quarantine decision making to determine if they can be released to the public; 01/07 - discussed; 01/21 - discussed; 01/31- A.

Mendiolas action; 02/11 -

Completion of Licensee Phase 3 sampling plan required; 02/21 -

17.5 Rem to cut samples, Less samples may be required; 04/03 -

Completion of Phase 3 sampling plan scheduled for late April -

discuss again then; 04/08 - Revisit in June 2003

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 54a Review TSP amendment D. Pickett 7/9 - Discussed. Will wait for and advise the panel on response from licensee; 7/16 -

the need for a TIA on Discussed - added action item 54b; Davis-Besse (7/2) 8/6 - Sent to the licensee on 7/22 and a response is due by 8/22; 8/22 - Discussed - need to check if response has been received; 8/27

- Received response - DRS is reviewing - will fax to NRR for 54b; 8/29 - Discussed, DRS report of response to be issued to panel prior to item 54b; 10/1-Discussed.

DRS coordinating with NRR 11/07-Discussed - On hold for draft with specific information; 12/10 - B.

Dean believed B. Bateman thought a calculation for sufficient volume of TSP was completed to technical specification value. However questions whether the calculation was to technical specification or actual TSP level remain; 01/03 -

Item under NRR review.

Calculation completion expected on Jan 17. Allegation issue in RIII domain; 01/07 - Allegation Item #3 under NRR Review for Resolution; 01/21 - Item #3 is under Region III control for final letter, holding for NRR input; 02/11 - Writeup for NRR input provided 4 answers, going back to reviewer to ensure specific tasking is clear to answer allegation concerns. Action item 54c created; 02/21 - Allegation at 242 day mark. Effective expression of due date required; 04/03 -

Messrs. Beckner, Grobe, Ruland,

& Mendiola to discuss; 04/08 - J.

Hopkins to set up call for 4/11/03

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 54c In relation to action item A. Mendiola 02/11 - Address first meeting in 54a - Assess method to March ensure Technical Specifications are adequate for a cycle, administrative controls vs.

amending technical specifications (02/11) 73 Send feedback form on Lipa 8/6 - Generate feedback after IMC 0350 procedure to Mendiola panel meetings reduced to once IIPB (8/6) per week; 8/29 - Discussed - no change; 10/1 - Discussed; 11/7 -

D Passehl sent email to C Carpenter and D Coe indicating that we would be able to perform a review of the draft IMC 0350 during the first quarter of 2003; 12/3- discussed; 01/03 - 2 parts, short part- C. Lipa with P. Harris, long part- B. Dean; 01/07 - 2nd larger response will require meeting between all parties; 01/21

- Communications with P. Harris; 01/31-Meeting with P. Harris on Feb 4; 02/11 - Many concerns identified by the panel for inclusion; 02/21 - July 1 due date for larger input.

97 Bulletins 2002-01 and NRR 11/07 - Discussed, further 2002-02 response and research and discussion required; acceptance (9/5) 01/07 - RAI response expected Mid February; 01/31- On track; 02/11 - New Orders will supercede BL2002-01 and BL2002-02 responses with the exception of the BL2002-01 Boric Acid Corrosion program information request; 02/21 - Licensee RAI response delayed. Both Order and BL2002-01 Boric Acid Corrosion program responses to be tracked as RAM items; 04/08 - Discussed, leave open pending NRR review

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 126 Review Davis- Strasma Besse/Vessel Head 02/11 - Checked, but revisiting Degradation web site item; 02/21 - Web site being content for ease of use by reassessed.

the public. (11/07) 127 Decision of the extent of W. Dean 12/10 - Completion date the needs for resolution of requested; 12/19 - Discussed -

the technical root cause Est. delivery Jan. 31st, put in Jan-(11/19) Feb report 03-02; 01/31 - On track; 02/21 - J. Hopkins has the review.

Through comprehensive review, A.

Hiser determined OI concerns did not effect the technical root cause.

Attachment of Technical Root Cause Review on next Inspection Report; 04/08, sent on Mar 31, leave open pending confirmation of receipt 133 12/29 Taping of debate J.Collins/ 01/03 - Licensee to deliver tape to D.Simpkins J. Strasma; 02/24 - Tape sent

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 136 NRR acceptance of NOP W. Dean 01/07 - Item discussed. Meeting criteria and method summary of November 26, 2002 (01/03) meeting has notation of NRR staff impressions of test plan. Once drafted, issue will be surveyed to staff to determine if consensus is correct; 01/21 - Meeting summary to discuss Flus System, Test agreement, and future inspections; 1/31 - T. Chan fwd to J. Hopkins; 2/11 - J. Jacobson questions need to be folded in (chem-wipes); 2/21

- Polling of staff discussed; 2/24 -

Polling of staff by March 7; 3/25 -

Staff to be polled after 4/4/03 meeting in headquarters, and meeting should address whether a rational basis exists that the bottom head is not leaking, and whether a critical flaw size will not appear during the next operating cycle; 04/08 - J. Hopkins writing mtg summary for 4/4, licensee to address additional questions on 4/9 telephone call 138 Evaluate the effectiveness A. Mendiola, 01/31 - Ongoing; 02/21 - New EDO of the Comm Plan (01/07) C. Lipa Comm Plan for Crisis Update, A.

Mendiola to review for inclusion.

145 Prepare a special D. Passehl 02/21 - date to be determined inspection plan for the restart readiness team inspection. (01/09)

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 147 Generate a list of items to D. Passehl 01/31 - working; consider after restart as 02/11 - Include dates and well as transition back to deadlines to Manual Chapter 0350 the normal 0350 when restart inspections planner terminating the 0350 Panel. The items should include plans to augment inspection of corrective actions, inservice inspection, and safety culture monitoring.

(01/09) 154 Marty has action to M. Farber 02/21 - Date to be determined followup by 1/21 with licensee to understand licensees actions to address common mode failure issues (i.e., topical issues) and brief Panel.

Then develop inspection plan to address topical issues. (01/09) 156 Read Generic Safety J. Hopkins 01/21 - Determine status of GSI-Issue-191, "Assessment of 191; 02/21 - Check GL98-04 Debris Accumulation on response on coatings. Draft GL PWR Sump Pump and Draft Reg Guide needs review Performance" (01/09) for DB relevance; 02/24 - Request Response Review and Program Implementation to GL98-04; 03/04

- activity to be reassigned to Reactor Engineer who will close sump LER; 04/08, D. Hills to discuss with K. Coyne and A.

Dunlop work assignments 174 Review 2/4 transcript for R. Lickus Mr. Witts recommendations (2/18) 175 LER licensee commitment J. Hopkins 02/21 - Attempt to get by end of on Containment Air Cooler February; 03/04 - Licensee wrote Supplement for 01/31/03 CR to address missed commitment (02/21)

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 178 Determine the type of C. Lipa backlog assessment that will be performed and by whom. Two attributes need to be considered: (1) the capability of the licensee to manage the backlog in an operating environment; and (2) the impact of the backlog on equipment reliability.

(03/04) 185 Research the criteria for C. Lipa 04/08 - An Event of Interest abnormal occurrences and document to be drafted instead of report to the Panel. an abnormal occurrence item.

(03/25) Leave open pending completion of the draft.

186 Add Dennis Kucinich to A. Saso the standard distribution list on documents for Davis-Besse. Then remove Dennis Kucinich from distribution 90 days after the NRC reply to his 10 CFR 2.206 Petition is signed out. (04/22)

INSPECTION PLAN SYSTEM HEALTH ASSURANCE PROGRAM FOLLOW-UP Davis-Besse Nuclear Power Station Inspection Report Number 50-346/2003003(DRS)

Inspection Objectives There are two objectives for this inspection:

1. To complete the review of the Latent Issues and System Health Readiness Review reports.
2. To review the licensees disposition of design issues identified as a result of the System Health Assurance Program.

Inspection Dates: January 13 through June 20, 2002 Applicable Inspection Procedures IP 93812, Event Response Prepared by: /RA/ 05/08/2003 Martin J. Farber Reviewed by: /RA/ 05/14/2003 Christine A. Lipa, Chief Reactor Projects Branch 4, DRP Reviewed by: /RA/ 05/08/2003 Ronald N. Gardner, Chief Electrical Engineering Branch, DRS Approved by : /RA DPassehl Acting for/ 06/13/2003 John A. Grobe, Chairman Davis-Besse MC 0350 Panel

INSPECTION PLAN DETAILS I. Inspectors M. Farber, Program Leader R. Daley, Reactor Engineer J. Jacobson, Senior Mechanical Engineer II. Inspection Approach The approach to follow-up inspection of the System Health Assurance Building Block incorporates the following components:

1) Review and evaluate all five Latent Issues Reports.
2) Review and evaluate four additional System Health Readiness Review Reports (two reviews have been completed and are documented in 50-346/2002013)
3) Review the licensees general approach to design issues identified during the System Health Assurance Program (commonly known as paths A, B, and C.
4) Review and evaluate the approach, methodology, and results of the licensees expanded examination of design basis (path B)
5) Review and evaluate the approach, methodology, and results of the licensees examination of five potentially generic (topical) issues (path C).

Notes:

  • The Corrective Action Team Inspection will review the resolution of a number of risk significant system deficiencies (Path A)
  • A review of the topical area of safe shutdown in the event of a fire is being conducted separately (Path C)

III. Detailed Inspection Schedule Preparation and Inspection Activities

  • Team Leader Preparation: January 6 - 10, 2003
  • Entrance Meeting: January 13, 2003
  • First On-site Inspection Week: January 13 - 17, 2003
  • Additional Weeks as necessary from January 27 - June 20, 2003
  • Final On-site Inspection Week: June 16 - 20, 2003
  • Exit Meeting: June 20, 2003 Inspection Documentation
  • Inputs Due: Close of Business, June 27, 2003
  • Draft Completed: July 11, 2003
  • Management Review and Approval Completed: July 18, 2003
  • An inspection report must be issued before July 20, 2002 (30 days from the exit)

IV. Specific Inspection Activities

a. Lead Inspector Preparation Review the following documents or portions of documents associated with system health program design issues:
2. Latent Issues Review procedure
3. System Health Readiness Review procedure
4. MPR Report Potential Safety Consequences of Nonconforming Conditions at Davis-Besse Phase I: Identification of Key Safety Significant Issues/Questions
5. Resolution of System Health Assurance Plan Design Issues, Revision 0, December 27, 2002
b. Inspection Activities Review the following documents and activities:
3. Five Latent Issues Review reports
4. Four System Health Readiness Review reports
5. MPR Associates Safety Function Validation Project guidelines
6. Collective Significance Review procedure
7. Monitor Safety Function Validation Project activities in-process
8. Review Safety Function Validation Project reports
9. Review Collective Significance Review reports for the five topical areas
10. Review the following Restart Action Matrix items 6 L Were the system assessments at D-B as rigorous as those conducted at Millstone and Cook in flushing out heretofore unidentified non-conforming conditions?

6 L Did FENOC properly evaluate problems raised during the system assessments at D-B for reportability under 10 CFR 50.72 and 50.73?

c. Starfire Information There are currently no resource estimates for this inspection. Direct inspection time will be charged to Inspection Procedure 93812 with an IPE of ER. Preparation and documentation for this inspection will use an IPE or SEP or SED.
d. Findings The Risk Informed Inspection Notebook and the Significance Determination Process (SDP) for Davis-Besse Nuclear Power Station have been developed and approved.

Inspectors must be able to 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 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.

e. Documentation The report will be prepared in general conformance with the format of Manual Chapter 0612, however, considerable flexibility will be allowed for documenting observations due to the nature of the inspection.
f. Interface and Coordination Meetings with the Licensee
  • An entrance meeting was held at 1:30 p.m. on Monday, January 13, 2003.
  • A short licensee debrief will be held at 11:30 a.m., on Friday, at the close of each inspection week, prior to leaving the site.
  • The exit meeting is tentatively scheduled for 10:30 a.m. on Wednesday, May 28, 2003.

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 inspectors will conduct an exit meeting on May 28, 2003.

INSPECTION PLAN FOR MANAGEMENT & HUMAN PERFORMANCE ASSESSMENT PHASE 2 2002-018 Davis Besse Non-Technical Root Cause Inspection Inspection Background and Objectives:

An 0350 Oversight Panel has been established for Davis Besse. The Panel determined that an NRC review of the licensees management and human performance root cause analysis is required. The review, conducted in a phased approach, is to assure the licensee has adequately conducted a root cause analysis to identify pertinent management and human performance issues that contributed to the vessel head degradation, identified appropriate corrective actions, implemented the corrective actions, and evaluated the effectiveness of the corrective actions.

The review will be conducted in three phases: Assessment of root cause(s) identification techniques and associated corrective actions (CA), CA implementation, and CA effectiveness.

This inspection plan addresses all three phases of the inspection. The first phase will assess the licensees root cause analysis and associated corrective actions. The second phase will assess the licensees determination of which items are pre or post restart and will monitor the licensees corrective action implementation. The second phase will also assess the licensees programs for monitoring CA implementation and effectiveness, and the licensees goals to be achieved prior to restart. The third and final phase will assess corrective action effectiveness.

The inspection will be a combination of a dedicated team and feedback from other ongoing NRC inspection as noted in the detailed inspection plan. The findings and conclusions from the inspection activities will be to provide the NRCs 0350 Oversight Panel to use in making a restart determination on Davis-Besse.

INSPECTION PLAN FOR MANAGEMENT & HUMAN PERFORMANCE ASSESSMENT PHASE 2 2002-018 Inspection Dates:

Phase 1: September 4 through October 4 Phase 2: TBD Phase 3: TBD Inspection Procedure:

Prepared by: /RA BClayton Acting for/ 04/30/03 G. C. Wright, RIII, DRP Date Project Engineer/Team Lead Reviewed by: /RA/ 04/29/03 Christine Lipa Date Chief, Projects Branch 4, DRP Reviewed by: /RA/ 04/30/03 Brent Clayton Date Management & Human Performance Oversight Manager Approved by: /RA DPassehl Acting for/ 06/13/03 Jack Grobe, Chairman, Date Davis-Besse Oversight Panel

INSPECTION PLAN FOR MANAGEMENT & HUMAN PERFORMANCE ASSESSMENT PHASE 2 2002-018 Inspection Details VII. Inspectors:

Geoff Wright, Team Lead, RIII Rick Pelton, NRR Jeff Jacobson,NRR Julio Lara, RIII William Corcoran, Contractor II Schedule:

Phase 1 Docket = 05000346 Report No. = 50-346/2002017 Insp. Proc. = 93812 Inspection IPE= ER Preparation IPE = SEP Documentation IPE = SED Preparation Time: September 4-6, 2002 Entrance Meeting: September 9, 2002 Inspection Dates: September 9 to 13 September 30 to October 4 Exit Meeting: TBD Phase 2 Report No. = 50-346/2002018 Preparation Time: Continuing Entrance Meeting: 2/24 Inspection at DBNP: 2/24 - 3/7/2003 Exit Meeting: TBD

INSPECTION PLAN FOR MANAGEMENT & HUMAN PERFORMANCE ASSESSMENT PHASE 2 2002-018 III Preparation:

On August 15, 2002, FirstEnergy, Davis-Besse Nuclear Power Station provided the NRC with its root cause analysis report on Failure to Identify Significant Degradation of the Reactor Pressure Vessel Head. Copies of the document will be provided to all team members for review. The Team Leader will make arrangements with Davis-Besse staff for suitable facilities and material for the team. In addition to the analysis, copies of the licensees management and human performance excellence plan (August Revision) will be provided.

Inspection Activities:

Phase 1: Evaluate root cause determination methodology implementation and corrective action(s) appropriateness.

This portion of the inspection will be conducted by the team identified above.

Inspection Activities:

Entrance Meeting: September 9, 2002 Inspection Time: September 9 through October 4 Exit Meeting: TBD.

1. Evaluate the effectiveness of the licensees implementation of its root causes assessment tools, e.g. Events and Causal Factors Analysis, Hazard-Barrier-Target Analysis, and Management Oversight and Risk Tree (MORT) Analysis.
1. Effectiveness of technique implementation
2. Appropriateness of material reviewed
3. Correlation(s) between Findings and Conclusions
4. Correlation(s) between Conclusions and Recommendations
2. Assess correlation(s) and appropriateness of the licensees CAs against root causes.
3. Assess correlation(s) and appropriateness of the licensees CAs against the Davis-Besse Management and Human Performance Excellence Plan (August Revision) items.
4. Identify the differences between Recommendations and CAs as described in the licensees Management and Human Performance Building Block. Evaluate the capability of the differences to correct identified deficiencies and prevent recurrence.
5. Additional activities IF licensee has progressed far enough to allow assessment:

This activity will include a review, as appropriate, of the licensees Return to Service Plan, Restart Action Plan, and Restart Action Plan Process.

INSPECTION PLAN FOR MANAGEMENT & HUMAN PERFORMANCE ASSESSMENT PHASE 2 2002-018

1. Assess appropriateness of the licensees corrective action implementation schedule, i.e., which corrective action are to be implemented pre-startup and which can be delayed until after startup.
2. Assess appropriateness of licensees performance targets to be achieved prior to restart, i.e., what performance level should the organization be at, prior to restarting the facility.
3. Assess appropriateness of the licensees monitoring activities for CA implementation and effectiveness.
4. Assess compensatory measures for CA which
1. will not be fully implemented.
2. where CA have not been in place long enough to evaluate effectiveness.
6. Present assessment findings and conclusions to 0350 Oversight Panel
7. Schedule Exit meeting.

Phase 2: Assess licensee CA implementation schedule and implementation of CAs This portion of the inspection will be accomplished by a combination of a special inspection AND feedback from other NRC special inspections.

Inspection Activities:

Entrance Meeting: 2/24/2003 Inspection Time: 2/24 - 3/7/2003 Exit Meeting: TBD.

1. Perform the following assessment to the extent not accomplished in E above.

This portion of the inspection will be accomplished by a special inspection.

1. Assess appropriateness of the licensees corrective action implementation schedule, i.e., which corrective action are to be implemented pre-startup and which can be delayed until after startup.
2. Assess appropriateness of licensees performance targets to be achieved prior to restart, i.e., what performance level should the organization be at, prior to restarting the facility.
3. Assess appropriateness of the licensees monitoring activities for CA implementation and effectiveness.
4. Assess changes to the licensees CAs and/or implementation plan for impact on program effectiveness.
5. Assess compensatory measures for CAs which
a. will not be fully implemented.
b. where CA have not been in place long enough to evaluate effectiveness.
c. where changes to improvement plan have been make which reduce the original scope of the program.

B. Assess CA implementation.

1. Assess licensees follow through with implementation schedule
2. Monitor licensees metrics for assessing CA implementation
3. Present assessment findings and conclusions to 0350 Oversight Panel
4. Schedule Exit meeting.

RAM Item No. - L-52 Closed: Y Date of Letter - 7/15/02 Author - UCS-25 Description of Issue - When NRC inspectors examine an incident, are they formally trained and instructed to test the licensees theory by reviewing plant-specific and industry experience?

Restart Checklist Item: N/A Description of Resolution - NRC inspectors examine an incident through implementation of Inspection Manual Chapter 93800 (AIT) and development of a charter. Part of the inspection program is to risk-inform the inspection to focus on safety significance of issues and areas to inspect. Qualification training for inspectors includes a mandatory Root Cause/Incident Investigation course. This course provides the basics in several approaches to identifying the cause of an incident, and is used by inspectors to develop the NRCs assessment of root cause, which is then compared to the licensees. The course includes looking at previous history (plant-specific or generic). Depending on the nature of the incident, the AIT Charter will contain appropriate focus on operating experience.

Reference Material - Inspection Module 93800, Inspection Manual Chapter 1245 RAM Item No. - L-65 Closed: Y Date of Letter - 08/18/02 Author - Gurdziel # 3 Description of Issue - Acid leaking down the head may flow into the holes that are used by the studs causing the threads to no longer be full size. Also, the acid may flow into the grooves of the reactor vessel to reactor head o-rings, changing their dimensions.

Restart Checklist Item: 2.c Description of Resolution - The containment Extent of Condition inspection and Boric Acid Corrosion extent of condition inspections looked at the licensees programs to ensure that the studs and threads were acceptable. See inspection reports 02-09 and 02-12.

Reference Material - IR 2002-009 and IR 2002-012.

RAM Item No. - L-66 Closed: Y Date of Letter - 09/07/02 Author - Gurdziel # 4

Description of Issue - Check of some existing welds on the replacement head couldnt be done due to the placement of lifting lugs. Couldnt you remove the stainless steel on the bottom surface and test that way?

Restart Checklist Item: N/A Description of Resolution - The licensee applied for and was granted code relief to not inspect these welds. Inspection from the interior surface of the vessel is not technically feasible.

Reference Material - ADAMS Accession Nos. ml022830831 & ml023050104 RAM Item No. - L-68 Closed: Y Date of Letter - 09/07/02 Author - Gurdziel # 4 Description of Issue - Lack of Quality Control and electrician supervision based on inadequate threads on a bolted connection.

Restart Checklist Item: N/A Description of Resolution - The condition was identified by the licensee, and placed into the licensees corrective action system for resolution. This is the normal process for handling identified discrepancies. It is not appropriate to automatically assume that any personnel error resulting in a hardware deficiency automatically points to lack of quality control and supervision.

There are examples where quality control may not even be involved in the evolution in question, and supervisors do not normally re-check all work performed by each worker they supervise.

RAM Item No. - L-69 Closed: Y Date of Letter - 09/07/02 Author - Gurdziel # 4 Description of Issue - Could the missing machine screws on wires to a micro switch be the result of vibration instead of poor assembly?

Restart Checklist Item: N/A Description of Resolution - The condition was identified by the licensee, and placed into the licensees corrective action system for resolution. This is the normal process for handling identified discrepancies. It is inappropriate to speculate at this point. The corrective action process is designed to determine the cause of the event and initiate corrective actions to prevent recurrence.

RAM Item No. - L-73 Closed: Y Date of Letter - 10/05/02 Author - Gurdziel # 9 Description of Issue - Institute a $ 50M fine against company and fines against many individuals associated with QA, Management, ISEG, and anyone found to be dishonest.

Restart Checklist Item: N/A Description of Resolution - The NRC will follow its normal enforcement process for taking actions against individuals and the company. That process calls for the issuance of a significance determination and determining whether any of the violations were willful. The first phase has been completed, in that the NRC has determined that the finding was significant, resulting in a red violation. The second process, determining if the associated violations were willful, is under investigation by the NRCs Office of Investigations, and may not be completed prior to restart of the facility. Once the Office of Investigation completes its work, if any violations were determined to be wilful, the results are forwarded to the Department of Justice for review. The Department may either choose to take the case, or refer it back to the NRC for civil action. At that point, the NRC would proceed to take action, which, depending on the willful nature of the violation, could be anything ranging from no action to banning the individuals from being involved in any NRC-regulated activity for life.

RAM Item No. - L-77 Closed: Y Date of Letter - 11/21/02 Author - Gurdziel # 14 Description of Issue - I still havent seen the full transcript of the October meeting or the Management Root Cause to be done on Operations, Corporate QA, and the one on Site QA (4 documents).

Restart Checklist Item: N/A Description of Resolution - All of the documents referenced in the description are currently available on the NRCs Davis-Besse website. Associated ADAMS accession numbers are as follows: ml030150838, ml030240394, ml030240408, ml030240424, ml030240440, and ml030240482.

Reference Material - ADAMS Accession Nos. ml030150838, ml030240394, ml030240408, ml030240424, ml030240440, and ml030240482.

RAM Item No. - L-87 Closed: Y Date of Transcript - 08/15/02 Author - Mr. Riccios question to 0350 Panel at public mtg.

Description of Issue - Mr. Riccio asked what needs to be done to assure that the design basis is maintained and understood, and whats to give the public any confidence that not only the industry and licensee has taken steps to improve its processes. Mr. Grobe said that he will consider it in how we structure the inspections we do at D-B.

Restart Checklist Item: 2 Description of Resolution - Answered in private at meeting. Restart checklist includes design adequacy of systems. Inspections conducted to evaluate design compliance include the System Health and Safety System Design Inspection (Inspection Report Nos. 02-13 and 02-14, respectively) which were forwarded to the licensee by one cover letter dated February 26, 2003.

Reference Material - ADAMS Accession No. ml030630314.

RAM Item No. - L-95 Closed: Y Date of Letter - 3/8/03 Author - Gault Description of Issue - NRC should not have allowed DB to operate with hole in vessel; unnecessarily put residents on Lake Erie at risk from a LOCA; and DB should be operated by some other company with safety-focused personnel.

Description of Resolution - Letter from J. Dyer to Ms. Gault addressing all issues dated April 14, 2003.

Reference Material - ADAMS Accession No. ml031070170.

RAM Item No. - L-96 Closed: Y Date of Transcript - 07/16/02 Author - Mr. William Brumls question to 0350 Panel at public mtg.

Description of Issue - Mr. Bruml asked when NRC was going to publish the results of inspections of the RV head. Mr. Grobe mentioned two studies - 1) NRC risk assessment; and 2) detailed analysis being done by RES. Inspection documentation should be out within next month or two.

Description of Resolution - The inspection report addressing the inspection of the head was issued on November 29, 2002 (IR02-07). The NRC risk assessment is attached to the issuance of the preliminary red finding, which was issued on February 25, 2003. The detailed analysis being done by research will not be completed before restart. Given the replacement of the reactor vessel head this schedule is acceptable.

Reference Material - Inspection Report 02-07 addressing the RV head is ADAMS Accession No. ml023370100; NRC risk assessment and preliminary red letter to licensee is ADAMS Accession No. ml030560426.

RAM Item No. - L-97 Closed: Y Date of Transcript - 08/15/02 Author - Mr. Lochbaums issue presented to 0350 Panel at public mtg.

Description of Issue - Mr. Lochbaum stated that NRC during inspections and PI verifications, should see if there are bonus plans or incentives that might bias licensees decision making process. Grobe stated he would forward to DIPM.

Description of Resolution - E-mail sent from Grobe to C. Carpenter on April 8, 2003, providing Mr. Lochbaums statement to DIPM.

Reference Material - None.

RAM Item No. - L-98 Closed: Y Date of Transcript - 08/15/02 Author - Mr. Gunters question to 0350 Panel at public mtg.

Description of Issue - Mr. Gunter stated that he was concerned with the accuracy and document trail regarding FENOCs root cause analysis of the RPV head degradation. Mr.

Gunter said that it seems to raise the question about FENOCs devotion to telling the truth. Mr.

Grobe stated that the NRC heard the licensees position that inaccurate information didnt play a role and that will be part of what we evaluate during our inspection in this building block area.

Description of Resolution - Restart Checklist revised (revision 2) to include an item 4.d, Completeness and Accuracy of Information.

Reference Material - ADAMS Accession No. ml030290155 RAM Item No. - L-99 Closed: Y

Date of Transcript - 08/20/02 Author - Mr. Keegans question to 0350 Panel at public mtg.

Description of Issue - Mr. Keegan wanted specific information on embrittlement and pressurized thermal shock for the reactor at D-B. Mr. Grobe said that we can get you in touch with the right people that can give you more information on pressurized thermal shock.

Description of Resolution - Information provided privately to Mr. Keegan after meeting adjourned.

RAM Item No. - L-100 Closed: Y Date of Transcript - 10/16/02 Author - Mr. Douglass question to 0350 Panel at public mtg.

Description of Issue - Mr. Douglas was asking the NRC to consider a photographic procedure to inspect and document the condition of the RVH. Finally, he said, I certainly do request that you consider the photographic procedure and be sure that it gets stuck in the paper publically, so that we can have some kind of confidence that this place isnt going to - you know where again. Mr. Grobe answered, Right. We can do that.

Description of Resolution - Per J. Grobe, this item is complete. Davis-Besse does video examinations of the head.

RAM Item No. - L-101 Closed: Y Date of Transcript - 12/10/02 Author - Mr. Whitcombs question to 0350 Panel at public mtg.

Description of Issue - Mr. Whitcomb asked why the restart checklist was not part of the presentation. Ms. Lipa stated that his suggestion was a good one and that the NRC would do it in future meetings Description of Resolution - Subsequent public meetings have included, as appropriate, the restart checklist as slides for discussion.

RAM Item No. - L-102 Closed: Y Date of Transcript - 01/14/03

Author - Ms. Luekes question to 0350 Panel at public mtg.

Description of Issue - During a discussion of safety culture and the safety culture assessment of employees, Ms. Lueke asked whether the appraisal form format will be available to the NRC.

Mr. Grobe said that he did know that level of detail could get it for her. Ms. Lueke said Okay.

Description of Resolution - Closed in private discussion after meeting concluded. Ms. Lueke informed that the NRCs Management and Human Performance Inspection Team will have available any records they deem necessary to complete this inspection, including but not limited to the appraisal forms.

RAM Item No. - L-103 Closed: Y Date of Transcript - 01/14/03 Author - Ms. Luekes question to 0350 Panel at public mtg.

Description of Issue - Ms. Lueke had a copy of the NRC report to Congress re the 1985 event at D-B. She referred to sections on underlying causes and asked about procedures that the licensee put in place to prevent future occurrences and if they were followed through. Mr.

Grobe stated that there were six separate root cause assessments in different areas and that they will be made publically available shortly.

Description of Resolution - All six root cause associated reports are publicly available and can be retrieved easily from the NRCs Davis-Besse website.

Reference Material - All documents are available at NRCs Davis-Besse website.

RAM Item No. - L-104 Closed: Y Date of Transcript - 01/14/03 Author - Mr. Douglass question to 0350 Panel at public mtg.

Description of Issue - Mr. Douglas had proposed photographic monitoring techniques in a previous meeting. At this meeting, he restated his proposals, expressed concern that he had not received a response from the NRC. At the end of his presentation, Mr. Douglas requested

...that the NRC stays in operation and stays on top [of] Davis-Besse until they do get these photographic and monitoring systems in. Mr. Grobe responded, Yea, I think Bill and I are here for the long haul so well make sure that the changes are lasting. Mr. Douglas then said that he ...hopes to see and here them [photographic and monitoring system] soon.

Description of Resolution - Per J. Grobe, this item is complete. Davis-Besse does video examinations of the head.

RAM Item No. - L-105 Closed: Y Date of Transcript - 01/14/03 Author - Ms. Musers question to 0350 Panel at public mtg.

Description of Issue - One of the subjects that Ms. Muser touched upon was high level waste storage. Mr. Grobe said that he could get her a contact that is involved in the Yucca Mountain project.

Description of Resolution - Closed in private discussion after meeting concluded - contact provided.

RAM Item No. - C-05 Closed: Y Description of Issue - Operators - clear understanding of their responsibility to us.

Description of Resolution - Mr. J. Dyer, Regional Administrator, met with all licensee operators on October 9, 2002, and stressed to them the responsibilities of the operators to meeting NRC requirements and ensuring safe operations at the facility.

RAM Item No. - C-12 Closed: Y Description of Issue - Process Code exemption requests for use of the Midland Head at Davis-Besse.

Description of Resolution - NRR has reviewed all of the licensees requests for code relief and the associated approvals are contained in letters to the licensee, which are in ADAMS as Accession Nos. ml022830831 and ml023050104.

Reference Material - Documented in IR 50-346/02-07 (ADAMS Accession No. ml023370100) and letters to licensee, which are in ADAMS as Accession Nos. ml022830831 and ml023050104.

RAM Item No. - C-14 Closed: Y Description of Issue - Issue letter to the licensee to officially lift the Quarantine on the Old RPV Head.

Description of Resolution - This is a duplicate of CAL-01 item. As such, this item is being closed and the issue will be tracked via CAL-01.

RAM Item No. - CAL-06 Closed: Y Description of Issue - Provide a plan and schedule to the NRC, within 15 days of the date of this letter, for competing and submitting to the NRC your ongoing assessment of the safety significance for the RPV head degradation.

Description of Resolution - Closed per CAL Update Letter dated December 24, 2002.

Reference Material - ADAMS Accession No. ml023600267 RAM Item No. - SUP-03 Closed: Y Description of Issue - Problem Identification: Determine that the evaluation documents the plant specific risk consequences (as applicable) and compliance concerns associated with the issue(s) both individually and collectively.

Description of Resolution - Preliminary Red finding letter with attached significance determination results and inspection report 02-08.

Reference Material - Inspection Report 02-08 is ADAMS Accession No. ml022750524; preliminary red finding letter with attached significance determination results is ADAMS Accession No. ml030560426 RAM Item No. - SUP-12 Closed: Y Description of Issue - Independent Assessment of Extent of Condition and Generic Implications. Perform a focused inspection(s) to independently assess the validity of the licensee's conclusions regarding the extent of condition of the issues.

Description of Resolution - Extent of Condition inspection reports 02-09 and 02-12 and Management & Human Performance Phase I and II inspections (report nos. 02-15 and 02-18).

Reference Material - ADAMS Accession Nos. ml022560237 (02-09), ml023370132 (02-12),

ml030380037 (02-15), and ml032050528 (02-18).

RAM Item No. - SUP-13 Closed: Y Description of Issue - Strategic Performance Area(s) Identification: Using the information contained in the Assessment Action Matrix, identify the strategic performance areas for which performance has significantly declined (e.g. Reactor Safety, Radiation Safety, or Safeguards).

Description of Resolution - General panel activity resulting in issuance of the complete Restart Checklist, which addresses all areas where the plants performance must be monitored

and determined to be acceptable prior to authorizing restart. Latest version is Revision 2, issued on January 28, 2003.

Reference Material - ADAMS Accession No. ml030290155.

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