ML040760051

Semiannual Report - Status of Implementation of Davis-Besse Lessons Learned Task Force Report Recommendations - Correction - Memo to the Commission Fr Travers

ML040760051
Person / Time
Site:	Davis Besse
Issue date:	03/26/2004
From:	Travers W NRC/EDO
To:	Diaz N, Mcgaffigan E, Merrifield J NRC/Chairman, NRC/OCM
Moroney B, NRR/DLPM, 415-3974
References
Download: ML040760051 (14)

Text

March 26, 2004 MEMORANDUM TO: Chairman Diaz Commissioner McGaffigan Commissioner Merrifield FROM: William D. Travers /RA/

Executive Director for Operations

SUBJECT:

SEMIANNUAL REPORT - STATUS OF IMPLEMENTATION OF DAVIS-BESSE LESSONS LEARNED TASK FORCE REPORT RECOMMENDATIONS - CORRECTION My memorandum dated February 23, 2004, forwarded the second semiannual report of the status of implementation of the Davis-Besse Lessons Learned Task Force Report recommendations dated February 20, 2004. Subsequently, it was noted that the numbering of the milestones in Attachment 2 of the report had been inadvertently changed while merging input files, which could incorrectly indicate that some milestones had been omitted. Please replace Attachment 2 of the subject report with the attached corrected copy.

cc: SECY OGC OCA OPA OCFO OCIO CONTACT: Brendan Moroney, NRR/DLPM 301-415-3974

ML040760051 EDO-004 OFFICE LPDII-2: PM LPDII-2: LA LPDII-2: SC LPDII: PD NRR: LT NAME BMoroney BClayton WBurton EHackett LMarsh DATE 3/17/04 3/17/04 3/17/04 3/17/04 3/18/04 OFFICE NRR:ADPT NRR:OD EDO NAME BSheron JDyer WTravers DATE 3/22/04 3/25/04 3/26/04 CONTACT: Brendan Moroney, NRR/DLPM 301-415-3974

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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

1. 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 ]

2. 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]

3. 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 results until permanent guidelines are Ongoing DE DLPM issued. Regions

4. 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)

5. 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)

6. 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

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

[LLTF 3.3.4(8)-High]

8. 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

2. 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, Regions 2.b. Obtain executive management 05/03 (C) endorsement. ML031350156 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.a 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 surroundings while conducting inspections.

Milestone Date Lead Support (T=Target)

(C=Complete)

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]

1. 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 procedure 3/04 (T) NRR/DIPM RES/DET 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 capabilities RES/DSARE of currently used and state-of-the-art NRR/DSSA leakage detection systems [LLTF NRR/DE 3.2.1(1):High, 3.1.5(1):High] NRR/DRIP NRR/DIPM

4. Develop recommendations for inspection 1/05 (T) NRR/DIPM RES/DET guidance pertaining to RCS unidentified NRR/DE leakage that includes action levels to NRR/DSSA trigger increasing levels of NRC interaction with licensees in response to increasing levels of unidentified RCS leakage [LLTF 3.2.1(2):High]

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

Milestone Date Lead Support (T=Target)

(C=Complete)

Part II. Performance Indicators (PI)

1. Develop and implement improved barrier 6/04 (T) NRR/DIPM RES/DRAA integrity PI based on current RES/DET requirements and measurements [LLTF NRR/DE 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 risk- TBD RES/DRAA NRR/DIPM 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 from NRR/DE Part 1 [LLTF 3.3.3.(3):High] NRR/DSSA Regions