Text

Revised Minutes of Internal Meeting of Davis-Besse Oversight Panel (Revised RAM Closure Attachment)
	ML040760693
Person / Time
Site:	Davis Besse
Issue date:	03/16/2004
From:	Grobe J; NRC/RGN-III
To:	;
References
	Download: ML040760693 (19)
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March 16, 2004 MEMORANDUM TO: Davis-Besse Oversight Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA/

SUBJECT:

REVISED OCTOBER 9, 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 October 9, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Caldwell, RIII G. Grant, RIII S. Reynolds, DRP R. Gardner, DRS B. Clayton, EICS G. Wright, DRP DB0350

MEMORANDUM TO: Davis-Besse Oversight Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel

SUBJECT:

REVISED OCTOBER 9, 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 October 9, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Caldwell, RIII G. Grant, RIII S. Reynolds, DRP R. Gardner, DRS B. Clayton, EICS G. Wright, DRP DB0350 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML040760693.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 JGrobe DATE 03/11/04 03/15/04 03/16/04 OFFICIAL RECORD COPY

MEETING MINUTES: Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE: October 9, 2003 TIME: 11:30 a.m. Central ATTENDEES:

D. Passehl J. Hopkins B. Ruland C. Lipa J. Stang M. Phillips J. Jacobson M. Salter-Williams J. Rutkowski Agenda Items:

1. Discuss/Approve Todays Agenda The Panel approved the agenda, but modified the order of presentations. THE APPROVED AGENDA REFLECTS THE ORDER LISTED IN THESE MINUTES.

2. Discuss Restart Checklist Item 3.c, "Quality Audits and Self-Assessments of Programs" Mr. Jacobson led a discussion of Restart Checklist Item 3.c, "Quality Audits and Self-Assessments of Programs." The results of the NRC's evaluation of Quality Audits was documented in the Programs Inspection Reports 50-346/02-11 and /03-09. The licensee has several procedures in place that should assure that adequate self-assessments are performed in the future. These include a focused self-assessment guideline procedure, a program assessment ownership and development procedure, and a self-assessment procedure for licensee management to select specific programs for self-assessments. The inspection of the licensee's review of Self-Assessments of Programs was performed by Mr. Jacobson and will be documented in Inspection Report 50-346/03-23. THE PANEL APPROVED CLOSURE OF RESTART CHECKLIST ITEM 3.C, "QUALITY AUDITS AND SELF-ASSESSMENTS OF PROGRAMS."

3. Discuss Status of Reactor Vessel Inspections Mr. Jacobson led a discussion of the status of the reactor vessel inspections. The licensee completed its inspections of the reactor vessel bottom head incore monitoring instrumentation nozzles and identified no evidence of leaks. The licensee is in the process of inspecting the reactor vessel upper head control rod drive mechanism penetration flanges. The first step of the upper head inspection involves visually examining the control rod drive mechanism mechanical joints/flanges. That inspection is in process. The licensee has found indications and is working to characterize the indications.

4. Discuss Restart Action Matrix Closure Forms

Mr. Phillips led a discussion of Restart Action Matrix Closure Forms. The Panel approved closure of several RAM Items. THE RESTART ACTION MATRIX ITEMS THAT THE PANEL APPROVED FOR CLOSURE ARE ATTACHED TO THESE MINUTES.

5. Discuss October 6, 2003, email from P. Blanch regarding safety rod withdrawal during Normal Operating Pressure test Mr. Phillips led a discussion on an October 6, 2003, email from P. Blanch regarding safety rod withdrawal during Normal Operating Pressure test. The email questioned the appropriateness of withdrawing safety rods during the test. The Panel determined that this issue should be addressed by the resident inspectors and documented in an inspection report. Mr. Hopkins stated that withdrawal of the safety group was also discussed in the licensees May 14, 2003, License Amendment Application (ADAMS Accession No. ML031360407).

NEW ACTION ITEM (217) - Scott Thomas to review and document the acceptability of the licensees withdrawal of the single safety group of control rods to provide a prompt trip response source of negative reactivity. The review will be documented in a resident inspection report.

6. Discuss New Allegations and Determine Whether Any Are Required to Be Resolved Prior to Restart Mr. Phillips informed the Panel that there were no new allegations.

7. Discuss Any Allegations for Which an Extension Was Requested Mr. Phillips informed the Panel that there were no allegations for which an extension was requested.

8. Discuss Communication Status Mrs. Lipa informed the Panel that there was a 2 p.m. telephone conference today among communication team members to disposition items.

9. Discuss 1000s of Letters Mrs. Lipa led a discussion of the 1000s of Letters project. New letters from yesterdays Public Meeting have been received in the Division of Resource Management and Administration (DRMA). Mr. Ruland suggested that Mr. Mendiola work with Mrs. Lipa to get problems with the project resolved.

10. Discuss Time Line for 10 CFR 2.206 Petition Mr. Hopkins led a discussion on the time line for the 10 CFR 2.206 Petition submitted on August 25, 2003, (Accession No. ML032400435) by Greenpeace, on behalf of NIRS and UCS. This petition requests the NRC take enforcement actions against FENOC, suspend the Davis-Besse plant license, and preclude plant restart until certain conditions have been met. Mr. Hopkins stated that an acknowledgment letter was sent

two days ago (Accession No. ML032690314). Mr. Hopkins also stated that FirstEnergy Nuclear Operating Company plans to reply on October 17, 2003. The NRC intends to issue a partial final decision on immediate actions requested and then in 120 days or so issue a proposed Directors Decision.

11. Discuss Date for Restart Readiness Assessment Team Inspection to Identify Staff Mr. Passehl led a discussion on the date for staff to be identified for the Restart Readiness Assessment Team Inspection. Mr. Ruland stated that the team should be identified soon recognizing that team members may be replaced due to other commitments and the licensees changing schedule. Mrs. Lipa commented that portions of the inspection that could be done in the near term should be considered. Mr. Passehl took action to review the inspection plan for items that could be inspected sooner rather than later and to work with Regional Technical Support personnel to start staffing inspection.

12. Discuss HPI Modification TIA and Evaluation Approach Mr. Hopkins led a discussion on the high pressure injection pump modification Task Interface Agreement and evaluation approach. Mr. Hopkins commented that the TIA as written may not be what the Region III staff wants. The Panel approved an extension of the due date to October 31, 2003.

NEW ACTION ITEM (218) - Christine Lipa took action to set up a meeting to discuss the HPI Pump TIA and ensure that the TIA as-written reflects the needs of Region III personnel.

13. Discuss New/Potential Licensing Issues Mrs. Lipa discussed a letter dated October 3, 2003, from FirstEnergy Nuclear Operating Company, "Correction of Information Provided in 10 CFR 50.55a Relief Requests Regarding American Society of Mechanical Engineers Boiler and Pressure Vessel Code Inservice Inspection Program at the Davis-Besse Nuclear Power Station, Unit 1" (ML032810388). Mr. Passehl commented that this letter should be evaluated as part of the Completeness and Accuracy Inspection. Mrs. Lipa also discussed other licensing issues, including a supplement to the NRCs 10 CFR 50.54f letter and a licensee commitment mentioned in Licensee Event Report 2003-07.

14. Discuss Plans to Address TI 2515/153, "Reactor Containment Sump Blockage (NRC Bulletin 2003-01)"

Mr. Hopkins commented on the NRC plans to address TI 2515/153, "Reactor Containment Sump Blockage (NRC Bulletin 2003-01)." Mr. Hopkins stated that the licensee response to the Bulletin had been received and that NRCs reply has been drafted and is being routed for concurrence. The Panel was not ready to discuss the plans to address TI 2515/153.

15. Discuss/Update Milestones and Commitments The Panel reviewed and discussed upcoming milestones and commitments.

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 73 Send feedback form on Lipa/ 8/6 - Generate feedback after panel IMC 0350 procedure to Mendiola meetings reduced to once per week; IIPB (8/6) 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; 07/01 - Request two month extension of due date; 07/22 - Due date extended to September 1; 09/25- Due date extended to January 1.

138 Evaluate the A. 01/31 - Ongoing; 02/21 - New EDO effectiveness of the Mendiola, Comm Plan for Crisis Update, A.

Comm Plan (01/07) C. Lipa Mendiola to review for inclusion.

147 Generate a list of items D. Passehl 01/31 - working; to consider after restart 02/11 - Include dates and deadlines to as well as transition Manual Chapter 0350 restart back to the normal inspections planner; 07/01 -

0350 when terminating Discussed; 7/22 - Dave has list with the 0350 Panel. The Christines comments; 08/05 -

items should include Discussed. Bring back 6 weeks; plans to augment 09/23 - Discussed; 09/30 - The Panel inspection of corrective decision is to separate this into three actions, inservice distinct listings: Inspection Schedule inspection, and safety items for both prior to and following culture monitoring. restart; Focus Areas for post restart; (01/09) and 0350 Panel termination criteria.

The Panel will approve listings.

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 178 Determine the type of C. Lipa 09/23 - S. Burgess was named to lead backlog assessment this inspection; 09/30 - Discussed, that will be performed reevaluation of resources and decision and by whom. Two on who will lead this inspection will be attributes need to be done on 10/2.

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) 189 Collect Information on J. Stang 05/27-Discussed; 07/01 - The the Regulatory Millstone Order was reviewed and the Approach to Research approach is not appropriate. Bill also the Process to Ensure look at the South Texas approach; Proper Regulatory 07/15 -Discussed, title changed; 7/22 -

Footprint upon Restart Lead changed; 09/30 - Discussed, (05/16) history table populated with past 0350 decisions will be presented and decision on this criteria will be made by 10/9.

193 Consider TIA on an J. Stang A concern was identified for the issue pertaining to 10 shutdown function performance goal CFR 50 Appendix R of maintaining reactor coolant level.

Section III-L, An NRC safety evaluation report "Alternative and issued in 1991 apparently allows the Dedicated Shutdown licensee to maintain reactor coolant Capability." (05/27) level above the top of active fuel instead of maintaining level within the range of indication in the pressurizer; 7/1 - John Hannon to determine if a TIA is necessary or the issue is moot.

Sent in draft TIA to HQs J. Stang to review licensing basis first; 09/30 -

Discussed, update will be presented on 10/2.

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 196 Determine whether the J. Grobe 6/24 - Closed; 7/1 - Re-opened - see shift manager is meeting minutes for additional qualified to fulfill the information; 09/30 - Resolution will be shift engineer position available by 10/3.

in an emergency and whether there is an adverse impact on the licensees emergency procedure Implemention. (06/17)

Item re-opened at 7/1 Panel meeting.

197 Develop a J. Stang 6/24 - Lead changed; 08/21 - Lead communication plan changed; 09/30 - Discussed, list of Q with restart Qs and As. & As is being gathered for review and (06/17) forwarding to RA.

201 Coordinate with L. T. Mendiola 6/24 - The Panel determined that Gerke and ask her to when the communication plan is call Rep. Kapturs staff developed for the preliminary regarding the June 13, significance determination for HPI 2003, letter from Pump issue that we consider Chairman Diaz to interfaces with those people who Kaptur. The purpose of receive the letter; 07/15 - Discussed; the call would be to 08/21 - Discussed; 09/30 - Discussed, update Rep. Kaptur on covered by GTG HPI Comm Plan, the recent issues with need to decide if this goes through the the HPI Pumps and EDOs or Chairmans office.

provide information on NRC actions to review LER 2003-02.(06/20) 202 Put a discussion of the J. Strasma actions the NRC took in reviewing concerns involving the reactor coolant pumps in the August 2003 newsletter.

(07/15) 208 Evaluate the need to M. Phillips call back CI regarding Allegation RIII-2002-A-0177 (D-B) after the OI Investigation is complete (08/21)

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 209 Add author of A. Saso Greenpeace 2.206 petition to the standard distribution list on documents for Davis-Besse. Then remove from distribution 90 days after the final NRC reply to the 10 CFR 2.206 Petition is signed out. (9/16) 210 Contact cognizant J. Hopkins personnel in NRC Research regarding the evaluation Research is performing about the combined effects of the deficiencies at Davis-Besse and coordinate a briefing of the Panel. (09/23) 211 (a) Issue a status report J. Jacobson 10/09-Discussed; Mr. Jacobson of the NOP test results provided the Panel with an update on thus far; (b) Issue a the licensees progress to date. Draft status report after the status reports are pending.

NOP inspection of record has been completed; (c) Issue a status report after the upper reactor vessel head and lower reactor vessel head tests are completed. The reports are to be forwarded to NRC Division of Engineering personnel.

(09/23)

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 212 Determine whether the J. Stang Communication Team has received all electronic and written correspondence from external sources. If there is reasonable confidence that the Communication Team has all the correspondence then develop a set of bullets explaining why there is reasonable confidence.

(09/23) 213 Update the punch list C. Lipa that will be used to ensure that NRC activities necessary for restart are accomplished with intermediate steps and their due dates. (09/25) 214 Discuss with Region III C. Lipa Public Affairs Officers whether to include a discussion of the September 20, 2003, rally sponsored by the Union of Concerned Scientists in the next monthly NRC newsletter. (09/25)

DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 215 Contact the J. Stang Congressional Affairs office to obtain a current listing of Q &

As on matters pertaining to restart and coordinate with Mr.

Mendiola to provide an updated package to the Panel for review and incorporation into the Comm Plan.

216 Submit a TIA which J. Lara addresses issues and questions related to the licensee's 1991 10 CFR Appendix R exemption request regarding Alternative Shutdown (ASD) regulations.

217 Review and document S. Thomas the acceptability of the licensee's withdrawal of the single safety group of control rods to provide a prompt trip response source of negative reactivity. The review will be documented in a resident inspection report.

218 Set up a meeting to C. Lipa discuss the HPI Pump TIA and ensure that the TIA as-written reflects the needs of Region III personnel.

APPROVED RAM CLOSURES FROM 10/9/03 PANEL MEETING RAM Item No. - E-31 Closed: Y Date of E-Mail - 02/26/03 at 2:00 pm Author - Blanch Description of Issue - Jack to provide answer to Paul Blanch: Please review the enclosed photo that was taken sometime in March 1993. From this photo, it appears that a nozzle was leaking at that time. The reddish brown deposits do not originate from flange leakage. Are we missing something?

Restart Checklist Item: N/A Description of Resolution - John Jacobson and Christine Lipa called Mr. Blanch on August 1, 2003, and discussed the issue. Mr. Blanch stated that he was satisfied with our response at that time. This item is closed.

Reference Material - None.

RAM Item No. - L-90 Closed: Y Date of Letter - 02/10/03 Author - Lochbaum Description of Issue - Did FENOC properly evaluate problems raised during the system assessments at D-B for reportability under 10 CFR 50.72 and 50.73? In a letter dated February 10, 2003, the Union of Concerned Scientists questioned whether the licensee was properly evaluating the reportability of issues identified during the system reviews. This was based on a subjective comparison to the number of LERs issued under similar review programs conducted at plants such as Cook and Millstone.

Restart Checklist Item: 2.all Description of Resolution - The inspectors reviewed the corrective actions and considered them adequate and appropriate to the circumstances. All restart-related corrective actions were verified to be complete including submission of LERs and LER supplements. The inspectors examined the licensees operability/reportability status on a periodic basis to ensure that significant issues were being properly evaluated for reportability on an ongoing basis. Since CR 02-09413 was issued, the licensee had issued 9 initial LERs and one supplement. The inspectors also assessed operability/reportability for a number of CRs, classified as a condition adverse to quality, being reviewed for corrective actions as part of this inspection. No discrepancies were identified. Based on the acceptability of the basic cause, the corrective actions, the extent of condition evaluation, and inspector reviews of additional condition reports, the inspectors concluded that the licensee is properly evaluating issues for operability and reportability.

Reference Material - Condition Report (CR) 02-09314, Untimely Determination of Reportability and NRC Inspection Report Number 50-346/02-17, dated December 9, 2002.

RAM Item No. - C-02 Closed: Y Description of Issue - Concerns with EDGs capability to start and carry sequenced and steady state loads.

Description of Resolution - The cause analysis report identified and evaluated all concerns in sufficient detail. All technical concerns were addressed by appropriate licensee corrective actions (CAs 6, 7, 9, 13, 14, 15, 16, and 19 to Condition Reports 02-08482 and 02-05385). The inspectors concluded that the CR process was satisfactory in capturing and bringing to resolution all concerns related to EDG loading.

Reference Material - CR 02-08482, CR 02-05385, and Calculation C-EE-0241.01-006, Rev. 0 RAM Item No. - C-18 Closed: Y Description of Issue - Reduce Pressurizer high level limit from 305 to 228 inches. The licensee had been operating with an administrative control of 228 inches. This is an open licensing action. Need to inspect the licensee's operating procedures to see that the licensee has appropriately captured the administrative control.

Description of Resolution - License amendment No. 225 was issued on August 12, 2003, closing out this action. The licensees procedures contained the old administrative limit of 228 inches before this same limit was imposed by the amended TS.

Reference Material - ADAMS Accession No. ml031681426.

RAM Item No. - C-21 Closed: Y Description of Issue - How will the licensee consider the containment radiation monitors operable? (LLTF Issue)

Description of Resolution - The monitors will be considered operable if they pass the surveillance tests specified in Technical Specification 4.3.3.1, Radiation Monitoring Instrumentation Surveillance Requirements. The TS specifies a shiftly channel check; monthly channel functional test, and a channel calibration every 18 months. Of note, these monitors were never inoperable during the last operating cycle except during the associated surveillance tests. Even while rust built up on the particulate filters, the filters were never allowed to accumulate sufficient rust to result in the monitor being inoperable. Filter change outs were scheduled, sometimes as often as daily, to ensure that the cartridges were not overly clogged and the monitor remained operable.

Reference Material - Licensee Technical Specification 4.3.3.1 and RAM Closure forms associated with the May 27, 2003, Panel Meeting.

RAM Item No. - C-24 Closed: Y Description of Issue - Both Order and Bulletin 2002-01 Boric Acid Corrosion program response to be tracked as RAM items.

Description of Resolution - The licensee responded to the associated Order by letter dated March 1, 2003. The licensee committed to the Order requirements and did not request any exceptions or relaxations. With regard to Bulletin 2002-01, the NRC, in a letter dated June 25, 2003, concluded that the licensee provided an acceptable 15-day response (item 1 of the bulletin). Consistent with the NRC review of the Bulletin responses for the other plants, NRC Bulletin 2002-01 items 2 and 3 remain open for Davis-Besse. Item 2 concerns future inspections and does not need to be closed for restart because the licensee has committed to the requirements of the Order for inspections. Item 3 concerns compliance with GL 88-05, which is addressed by Restart Checklist item 3.d, "Boric Acid Corrosion Control Program Acceptability," which effectively tracks this item.

RAM Item No. - C-28 Closed: Y Description of Issue - Need to ensure unqualified containment coatings (mostly on conduit) are evaluated to ensure they will not lead to any sump blockage.

Description of Resolution - This item is duplicative of Restart Checklist Item 2.c.1, Containment Sump. The issue is addressed in detail and closed in NRC Inspection Report Number 50-346/03-17.

Reference Material - NRC Inspection Report No. 50-346/03-17 (ADAMS Accession No.

ml032721592).

RAM Item No. - C-33 Closed: Y Description of Issue - Evaluate the licensee's radiation protection management stability given the turnover in radiation protection managers, allegations and employment discrimination cases since February 2002.

Description of Resolution - Discussions with a cross section of radiation protection personnel including technicians, supervisors, health physics staff and managers indicated that radiation protection management had improved, that personnel issues had been or were being resolved, and that the radiation protection organization had a positive attitude. This attitude change was felt to be the result of program ownership by individuals and team building. The inspectors concluded that management stability in the radiation protection organization was not an issue and that the radiation protection organization was capable of supporting plant restart.

Reference Material - NRC Inspection Report No. 50-346/03-017 (ADAMS Accession No.

ml032721592).

RAM Item No. - CAL-02 Closed: Y Description of Issue - Determine the root cause of the degradation around the RPV head penetrations, and promptly meet with the NRC to discuss this information after you have reasonable confidence in your determination.

Description of Resolution - This CAL item was closed by update letter E issued to the licensee on September 19, 2003.

Reference Material - Confirmatory Action Letter Update E dated September 19, 2003 (ADAMS Accession No. ml032650662).

RAM Item No. - SUP-01 Closed: Y Description of Issue - Problem Identification: Determine that the evaluation documents how long the issue existed, and prior opportunities for identification.

Description of Resolution - By letter dated April 18, 2002, FirstEnergy Nuclear Operating Company (FENOC) submitted its Root Cause Analysis Report of the reactor pressure vessel (RPV) head degradation in accordance with the Confirmatory Action Letter dated March 13, 2002. On May 7, 2002, the Nuclear Regulatory Commission (NRC) staff held a public meeting with FENOC representatives to discuss the technical aspects of the root cause analysis.

Revision 1 of the Report was submitted by letter dated September 23, 2002. The Davis-Besse Root Cause Analysis Report provided a broad scope assessment of the root cause, covering various programmatic, implementation and managerial issues, along with a description of the technical sequence of events from the initiation of cracking in the control rod drive mechanism (CRDM) nozzles to the formation of the cavity identified in March 2002. The NRC staff reviewed the report and based on the information currently available, the NRC staff concludes that the licensees analysis presents a plausible scenario of the degradation at Davis-Besse. In the absence of direct physical evidence, the basis for the staffs conclusion is experience with past boric acid corrosion events and the extension of that knowledge to the extreme Davis-Besse case. Uncertainties with regard to the technical details of the RPV head degradation (including the sequence, rate and nature of the mechanisms that resulted in the degradation) preclude a definitive conclusion to the technical Root Cause Analysis Report. However, the level of understanding of the root cause is sufficient for this licensee to proceed with use of the replacement head from the canceled Midland plant.

In addition to the technical root cause reviews, the licensee also conducted seven individual assessments in the Management & Human Performance area as follows:

1. Root Cause Analysis, Failure to Identify Significant Degradation to the Reactor Pressure Vessel Head, dated August 13, 2002;

2. Root Cause Analysis, Failure in Quality Assurance Oversight to Prevent Significant Degradation of the Reactor Vessel Head, dated September 10, 2002;

3. Root Cause Analysis, Lack of Operations Centrality in Maintaining, Assuring, and Communicating the Operational Safety Focus of Davis-Besse and Lack of Accountability of Other Groups to Operations in Fulfilling that Role, dated November 22, 2002;

4. Root Cause Analysis, Assessment of Engineering Capabilities, dated January 3, 2003;

5. Evaluation of FENOC Company Nuclear Safety Review Board, dated August 13, 2002;

6. Evaluation of Corporate Management Issues, dated December 18, 2002; and

7. Collective Significance Review of the Causal Factors Associated with the Reactor Pressure Vessel Head Degradation at Davis-Besse, dated March 17, 2003.

These reports were reviewed as part of the NRCs Management and Human Performance special inspections, and the results of those reviews are documented in Inspection Reports 50-346/02-15 and 50-346/02-18 dated February 6, 2003, and July 24, 2003, respectively. As stated in the July 24, 2003, letter to FENOC, the overall assessment was of appropriate depth and breadth to develop actions to correct and prevent recurrence of the management and human performance deficiencies associated with the reactor head degradation.

Reference Material - Confirmatory Action Letter Update E dated September 19, 2003 (ADAMS Accession No. ml032650662); NRC Inspection Report 50-346/02-15 (ADAMS Accession No.

030380037); NRC Inspection Report No. 50-346/02-18 (ADAMS Accession No. ml 032050528) and NRC Inspection Report No. 50-346/03-04 (ADAMS Accession No. ml 031320705).

RAM Item No. - SUP-02 Closed: Y Description of Issue - Problem Identification: Determine that the evaluation documents how long the issue existed, and prior opportunities for identification.