ML041460514

Minutes of Internal Meeting of Davis-Besse Oversight Panel

ML041460514
Person / Time
Site:	Davis Besse
Issue date:	05/21/2004
From:	Grobe J NRC/RGN-III
To:	NRC/RGN-III
References
Download: ML041460514 (23)

Text

May 21, 2004 MEMORANDUM TO:

Davis-Besse Oversight Panel FROM:

John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA/

SUBJECT:

MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL 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 January 26, 2004. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel, the approved Followup RRATI Inspection Plan, the approved RAM Closure Forms, and the Open Action Items List.

Attachments: As stated cc w/att:

D. Weaver, OEDO J. Caldwell, RIII G. Grant, RIII S. Reynolds, DRP B. Clayton, EICS DB0350

DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML041460514.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII RIII NAME RBaker/trn DPassehl CLipa JGrobe DATE 05/20/04 05/19/04 05/11/04 05/21/04 OFFICIAL RECORD COPY

MEETING MINUTES:

Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE:

January 26, 2004 TIME:

8:30 a.m. Central ATTENDEES:

J. Grobe C. Lipa M. Phillips D. Passehl W. Ruland A. Mendiola J. Hopkins S. Thomas R. Baker R. Skokowski 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 New/Potential Licensing Issues J. Hopkins informed the Panel that there were no new licensing issues. The TIA concerning Appendix R issues is in review by the technical staff and the final document is expected to be to J. Stang by Friday, January 30.

3.

Discuss Topic of Commissions Interest in Davis-Besse The Panel discussed the newest D. Lochbaum email/letter dated 1/16/04, on the topic of Commission interest in Davis-Besse. D. Lochbaum is interpreting the fact that the Commission has not held a public meeting specifically on the issues of Davis-Besse as a Commission position of no interest. The Panel discussed how to respond to this point; who should respond; should we respond? The suggestion was to refer the item to the EDO office. W. Ruland took the action to coordinate this issue.

NEW ACTION ITEM (239) - W. RULAND TO COORDINATE WITH OEDO TO DETERMINE WHAT APPROPRIATE RESPONSE IS REQUIRED FOR THE 1/16/04 LOCHBAUM EMAIL ON COMMISSION INTEREST IN DAVIS-BESSE.

(Due Date: 02/05/04) 4.

Discuss/Approve Followup RRATI Inspection Plan R. Skokowski led a review of the Followup RRATI Inspection Plan. The Panel suggested several editorial comments which D. Passehl took action to incorporate. The Panel approved the inspection plan, and THE APPROVED INSPECTION PLAN IS ATTACHED TO THESE MINUTES.

5.

Discuss Plant Status and Inspector Insights and Emergent Issues List S. Thomas led a discussion of plant status and inspector insights and emergent issues.

The Plant is currently in Mode 3, stable at 300oF and 440 psig. The licensee entered Mode 3 at 1:08 a.m. on January 26, 2004. The licensee is holding plant conditions stable at 300oF and 440 psig, while conducting repairs to one of the #1 S/G Isolation Valve solenoid control valves. The licensee identified an air leak on solenoid valve 101C. This is one of two Solenoid Operated Valves [SOV] that operates in response to SFRCS signals to close MSIV-101 [#1 S/G Steam Isolation Valve]. Currently, the licensee believes the leakage is such that the system is essentially in a half-trip condition [meaning that if the redundant SOV should receive a trip signal, MSIV-101 would close]. To replace the leaking SOV 101C, MSIV-101 has to be closed to support depressurizing the control air header. The licensee is considering the use of the MSIV-101 bypass valve, when MSIV-101 is closed for the repair of solenoid valve 101C.

A problem solving decision making team has been assembled and is working through the issue.

The licensee has not declared MSIV-101 inoperable because the valve is still capable of performing its safety related function. The licensee will recommence heatup to NOP/NOT following repairs and testing. The resident staff continues to monitor licensee performance around-the-clock during the heatup.

6.

Discuss Allegations: 1) New; 2) Determine If Required to Be Resolved Prior to Restart; and 3) Requested Extensions D. Passehl briefed the Panel on two outstanding allegations which are going to ARB panel today and tomorrow, January 26 & 27. Both concerns are fatigue/overtime issues. D. Passehl will also determine the status of another item from the last public meeting where a member of the public asked why the Quality Assurance step had been removed from the process for developed procedure review. The Panel decided to revisit the current Panel criteria to review allegations for immediate safety concerns. C. Lipa took the lead to bring a recommendation to the Panel for review.

NEW ACTION ITEM (240) - C. LIPA TO DEVELOP RECOMMENDATIONS FOR REVISING THE PANELS CRITERIA FOR DETERMINING IF AN ALLEGATION IS A RESTART ISSUE TO FOCUS ON SAFETY CONCERNS. (Due Date: 02/03/04) 7.

Discuss Action Items C. Lipa led a review of the Open Action Items. Four new Action Items were added to the open action items list, and one item was closed. THE UPDATED OPEN ACTION ITEMS LIST IS ATTACHED TO THESE MINUTES.

8.

Discuss RAM Closure Items M. Phillips led a review of RAM closure items. THE RESTART ACTION MATRIX ITEMS THAT THE PANEL APPROVED FOR CLOSURE ARE ATTACHED TO THESE MINUTES.

9.

Discuss Current Status and Planned Actions to Complete AITS Item R04-0052 -

Response to Ohio Citizens Action Group Analysis of Davis-Besse Safety Culture Surveys R. Baker briefed the Panel on the status of AITS Item R04-0052. The due date has been extended until February 5, and J. Strasma will work with G. Wright, upon his return from Davis-Besse, to finalize the response letter to the Ohio Citizens Action Group.

NEW ACTION ITEM (241) - R. BAKER TO MEET WITH J. STRASMA AND DETERMINE POLICY FOR DISPOSITIONING OF FUTURE LETTERS RECEIVED FROM SPECIAL INTEREST GROUPS/INDIVIDUALS. (Due Date: 02/03/04) 10.

Discuss Punch List C. Lipa led a review of the Punchlist. R. Baker took the action to update the Punchlist with the Panels comments.

NEW ACTION ITEM (242) - D. PASSEHL TO REVIEW MC 0350 AND PHILOSOPHY ON WHICH DOCUMENTATION IS REQUIRED FOR PUBLIC DISSEMINATION AND WHICH SHOULD BE PURGED FOLLOWING PLANT RESTART. (Due Date: 02/05/04) 11.

Discuss Agenda for Licensees Weekly Status Call C. Lipa led a discussion of specific issues to address with the licensee during the weekly call. One additional topic for discussion was noted; discuss the licensees goals for restart for several of the Performance Indicators which are not trending well, i.e., Operator Work-arounds and SRO Review of Condition Reports.

12.

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

13.

Review Key Items Scheduled for Next Panel Meetings C. Lipa discussed key items scheduled for upcoming Panel meetings.

INSPECTION PLAN Revision 4 RESTART READINESS ASSESSMENT TEAM INSPECTION II Davis-Besse Nuclear Power Station Inspection Report Number 50-346/2004004(DRP)

(Do not share this Inspection Plan with the licensee)

Inspection Objectives The objective of this inspection is to verify that the licensee has taken effective corrective actions to address the causes of the operational problems observed during the Restart Readiness Assessment Team Inspection conducted in December 2003. That inspection determined that the plant was not ready to enter power operations without further observation and assessment of plant operations by the NRC.

At the conclusion of this inspection, the team will present its findings to the Davis-Besse Oversight Panel. The NRC will use the findings from this inspection as input for the staffs restart readiness assessment.

Inspection Dates:

Week of February 2, 2004 EXIT:

TBD Applicable Inspection Procedures IP 93812, Special Inspection IP 93802, "Operational Safety Team Inspection" Prepared by: /RA/

R. A. Skokowski, Team Leader Reviewed by: /RA/

Christine A. Lipa, Chief Reactor Projects Branch 4 Approved by : /RA/

John A. Grobe, Chairman Davis-Besse Oversight Panel

INSPECTION PLAN DETAILS I.

Inspectors Rick Skokowski, Byron SRI, Team Leader George Wilson, Duane Arnold SRI John Zeiler, Vogtle SRI Tim Hoeg, Grand Gulf SRI John Rutkowski, Davis-Besse RI II Detailed Inspection Schedule Preparation and Inspection Activities Entrance Meeting: February 2, 2004 On-site Inspection Weeks: Week of February 2, 2004 Inspection Report Number 50-346/04-04 Exit Meeting: TBD Licensee Contacts Davis-Besse Lead: Mike Roder (ext. 7951)

Regulatory Interface Lead: Gerry Wolf (ext. 8114); Gary Becker (Support)

Inspection Documentation Inputs Due: February 13, 2004 Draft Completed: February 23, 2004 Management Review and Approval Completed (target): March 1, 2004 An inspection report must be issued by 45 days from the exit III.

Inspection Objectives The objective of this inspection is to determine whether the plant is ready to enter power operations and what conclusions can be made regarding plant operations once the plant returns to normal routine operations. This inspection is scheduled to precede the Davis-Besse reactor restart from an extended outage. During this inspection, emphasis will be placed on the effectiveness of the licensees operations activities to ensure the safe operation of the plant, including the effectiveness of other organizational components in supporting operations.

The Davis-Besse Oversight Panel developed a Restart Action Matrix (RAM) which identifies items requiring review and closure. The RAMs assigned to the RRATI are:

SUP-32 (IP95003 02.03.b3)- Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Design: Determine if the System is operated consistent with the design and licensing documents.

SUP-35 (IP95003 02.03.c 2.a) - Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Human Performance:

Review specific problem areas and issues identified by inspections to determine if concerns exist in organizational practices such as pre-job briefings, control room team work, shift turnover, self-checking and procedural use and adherence.

SUP-48 (IP95003 02.03.f.1) - Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Configuration Control: Assess the effectiveness of corrective actions for deficiencies involving configuration control.

Note: DRP is taking the lead for closure of SUP-48 but other inspections have addressed pieces of it. Assess the licensees actions regarding auxiliary feedwater configuration control to address SUP-48.

The team will also assess the Davis Besse Readiness for Restart Checklist Items:

5.b System Readiness for Restart; and 5.c Operations Readiness for Restart.

IV.

Team Inspection Plan The team will evaluate how the licensee addressed fundamental weaknesses in their ability to operate the plant during Restart Readiness Team Inspection performed in December 2003. This inspection will incorporate the conclusions of the licensees restart readiness assessments to allow for an integrated evaluation of the plants readiness to resume operation.

Weaknesses observed during the earlier Restart Readiness Assessment Team Inspection were:

1) The preparation for and performance of major activities had significant deficiencies which indicated a lack of awareness by the operators of plant equipment and status.

2) Several examples were noted with the operators not following management expectations and written standards.

3) Work control was disorganized and there appeared to be a lack of project oversight to ensure proper rigor in the work control process. The work schedule changed frequently and may have contributed to some of the problems.

4) Several system engineers for safety-related systems were not qualified.

5) Corrective actions for operational events in September 2003 were inadequate.

This inspection will include an evaluation of the licensees corrective actions for the above weaknesses and assess the potential for long-term effectiveness.

A.

OPERATIONS The overall goal of this assessment is to verify that the plant operations department is prepared to conduct a safe startup and continued plant operations. The RRATI will make this assessment by evaluating the effectiveness of several operations management control processes and directly observing shift operations. The RRATI will conduct inspection activities during plant evolutions both during day and backshift periods. The objective is to assess as many complex activities as possible during the inspection week. Inspectors will adjust their work schedule as appropriate to accomplish this objective.

Inspectors will document their observations on the attached "Issues Log." on a real time basis. The operations observations will be integrated and summarized to support the licensee daily debriefs and the exit meeting. These logs will be the primary basis for report documentation. As such, observations will be documented in sufficient detail to support entry into an inspection report and in the table in the back of the report. For example, procedures observed need to be fully described, with the name, title, revision, etc. Issues with specific operators need to include their name and title/position during the shift. Positive and negative observations are to be recorded. Use extra sheets if necessary. Negative observations need to be completely described with supporting/reference information.

A.1 Control Room - All

Assess the effectiveness of shift turnovers. Determine if adequate time is allotted for the conduct of turnovers and if control room documentation (e.g., shift logs and night orders) is useful and available.

Assess operator professionalism and communications within the control room.

Determine the effectiveness with which operations appropriately controls support activities in progress, including maintenance, troubleshooting, and testing activities which can potentially influence plant operations.

Verify that equipment, including equipment required by Technical Specifications, secondary and support systems, is operable to support the current plant condition, pending mode changes, and power operations.

By accompanying control room operators and by reviewing operations logs, verify that log-keeping standards and implementation are adequate to support plant restart.

Assess the adequacy of annunciator response, number of continuously lit annunciators, and response to out of service equipment and components.

Evaluate the status of control room annunciators, alarms, and recorders. Verify the acceptability of the licensees methodology for compensatory measures for those indications not operating properly.

Evaluate control room/plant operator awareness of equipment status. Walk down portions of selected safety systems and evaluate the licensees configuration control practices. Confirm that valve and breaker positions conform to procedure requirements

and that positions required by procedure are consistent with those on controlled plant drawings and system lineup procedures.

Assess the ability of the plant staff to identify, prioritize, and resolve plant deficiencies.

Coordinate with other RATI inspectors to evaluate engineering/technical issues, concerns, or operability determinations.

Assess the quality and effectiveness of pre-job briefings to determine if the licensees corrective actions from the December 2003 RRATI were effective.

A.2 Equipment Status - Name Perform a brief review of the adequacy of system lineups for high pressure injection, auxiliary feedwater, low and high pressure injection, and the emergency power distribution systems. Use system P&IDs and procedure checklists. Include within the scope instrument root valves, transmitters, indicators, etc., to verify proper alignment, labeling, etc.

Determine if equipment status changes and corresponding entry into or exit from Technical Specification Action Statements are appropriately documented. Determine if the licensee has adequate controls to ensure the independent verification of equipment status, particularly when equipment is returned to service. Assess the adequacy of operability verification testing when returning equipment to service.

Perform a general plant tour to identify material condition discrepancies that should have been identified and documented by the licensee's staff, particularly field operators and system engineers. (All inspectors)

A.3 Operations corrective actions Review the licensee's corrective actions from the September 2003 operational events and determine why the licensee's corrective actions were inadequate based on the results from the December 2003 RRATI. Assess the adequacy of the licensee's corrective actions from the December 2003 RRATI findings and assess the adequacy and effectiveness of the corrective action going forward.

Review the licensee's root cause determination and corrective actions from the December 30, 2003, event when operations personnel did not recognize entry into the component cooling water Technical Specification Action Statement 3.7.3.1 following tagout of CC 1328 (Control Rod Drive Booster Pump 1 Suction Valve). Refer to CR 03-11414.

B.

MAINTENANCE AND SURVEILLANCE TESTING B.1 Maintenance - Name

Observe two maintenance activities that involve Technical Specification Limiting Conditions for Operation or safety-related equipment performance, or otherwise influence the safe operation of the plant. Verify that the maintenance jobs are appropriately prioritized and dispositioned in a timely manner. Verify that the maintenance activities are coordinated with control room operations and that appropriate briefings and turnovers are held with control room operators.

Verify that the maintenance is performed in accordance with current written and approved instructions that are detailed enough to perform the intended maintenance and adequately document the maintenance performed.

Determine if engineering input into maintenance activities is at an appropriate level to ensure safe and reliable current plant operations.

Determine if appropriate post-maintenance testing is being specified following the conduct of maintenance activities and that there is involvement of engineering in specifying the tests when appropriate.

B.2 Surveillance Testing - Name

Observe one or two surveillance tests in the mechanical, electrical, or instrument and controls area. Verify that:

Required administrative approvals were obtained before testing was started and, when appropriate, entry into Technical Specification Action Statements was documented.

Testing is being accomplished by qualified personnel in accordance with current and approved procedures that are adequate to meet Technical Specification requirements.

Test instrumentation is calibrated and properly used.

Procedures are adequate to satisfy the test requirements of the Technical Specification surveillances.

Test results meet technical specification acceptance criteria.

Test discrepancies or problems are documented and properly resolved in a timely manner.

Surveillance testing is completed within the required technical specification frequency.

C.

ENGINEERING AND TECHNICAL SUPPORT - Name

By interviewing personnel and reviewing documents related to equipment performance problems, evaluate the effectiveness of the technical staff, including plant, technical, and design engineers, in supporting safe operation of the plant.

Verify appropriate qualification of system engineers in accordance with the licensees program.

V Issues and Findings The Risk Informed Inspection Notebook and the Significance Determination Process (SDP) for Davis-Besse Nuclear Power Station have been developed and approved.

Inspectors will 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" will be immediately discussed with the team leader, 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.

Unless an issue can be shown to be greater than minor, additional inspection time should not be spent. If an issue appears greater than minor, then sufficient questions need to be asked of the licensee to enable the inspectors to confirm any assumptions and complete the Phase 1 and 2 worksheets. If a color cannot be determined by the end of the inspection, the issue will be described as an "unresolved item," pending final determination of the appropriate risk significance. Some flexibility will be allowed for documenting non-green observations due to the nature of the inspection.

VI Documentation Inspection findings normally result in a number of questions being raised. These questions are to be given to the licensee verbally or, if written, the licensee must copy the information and the inspector must retain the written document. As part of the daily interfaces with the licensee, the team leader will go over the status of outstanding questions. Therefore, the team members need to keep the team leader informed of any concerns with timeliness or quality of responses to questions. Lack of response to questions will not be accepted as a reason for any delay in providing an input unless the team leader has been informed prior to the exit and the issue is one that will necessitate a writeup in the report. Any document requests generated on the day of the exit or afterwards must be approved by the team leader, must pertain to areas already inspected, and must be only for the purpose of ensuring an accurate document list entry.

Issues which the inspector deems meet the criteria for report writeups will be discussed with the team lead prior to preparing an input. Inputs are to be e-mailed to the team lead in accordance with the established schedule. All documents critically/deliberately reviewed will be included in the document list. Corrective action documents generated as a result of the inspector's questions will be listed separately from corrective action documents that were in the licensee's system prior to the inspection.

VII Interface and Coordination Meetings Meetings with the Licensee Status meetings will be held each day during the inspection. Daily debriefings with the licensee will start on or about February 2, 2004. Team members are not expected to attend the daily debriefs unless there are significant or complex issues. An expanded debrief will be held with the licensee (excluding management) on the day prior to the exit meeting. All inspectors are expected to attend the expanded debriefing unless there are extenuating circumstances.

Exit Meeting The team leader will conduct the exit meeting on a date to be determined. Unless there are extenuating circumstances, team members will need to attend the final exit meeting and be prepared to answer any questions that may be raised by the licensee. Team members are expected to provide the team leader with a summary of findings for use at the exit meeting.

VIII Starfire Information This special inspection is estimated to require approximately 280 (+/- 40) hours of direct inspection effort. Charge to IP 93812 with IPE code of ER. Preparation and documentation for this inspection will use IPEs, SEP, SED, respectively.

IX General Information Travel Charges All travel time is to be charged in HRMS to an IPE code of "AT".

Overtime Overtime will be approved to accomplish the objectives of the inspection. Any overtime spent traveling (although there shouldn't be any) also must be claimed in HRMS using the overtime code of "ADDLT".

Issues Log Date/Time Area Inspector Activity Comments Grade + 0 -

ST/RT - shift turnover/relieve turnover C&C - command & control LK - Logkeeping WC - work control OK&A - Operators Knowledge & Awareness SS - Shift Staffing C - Communications P&PA - Procedures & Procedure Adherence OT - Operator Training ED - Equipment Control/Deficiencies CC - Configuration Control AR - Alarm Response MAINT - Maintenance TEST - Testing ENG - Engineering

January 26, 2004 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Number Action Item (Date generated)

Assigned to Comments Due Date 197 Develop a communication plan with restart Qs and As.

(06/17)

J. Stang 6/24-Lead changed; 08/21-Lead changed; 09/30-Discussed, list of Q &

As is being gathered for review and forwarding to RA; 10/14-Discussed, J.

Shea is compiling the list of Q & As for review by the Panel and results will be forwarded to the RA; 10/21-Brainstorming session to occur 10/23 to final presentation to Panel; 11/20-The list of Q&As will be inserted to the Comm Matrix today; 12/15-Discussed, Plan with Panel Chairman; 12/30-Discussed, major rework in progress and plan will need to go back into concurrence; 1/26-Discussed, the revised Comm Plan is being routed for concurrence with the final Q&As to be emailed to the region by 1/28.

02/02/04 208 Evaluate the need to call back CI regarding Allegation RIII-2002-A-0177 (D-B) after the OI Investigation is complete (08/21)

M. Phillips 10/14-Investigation is still ongoing; 12/23-Discussed, awaiting DOJ Investigation.

TBD 212 Determine whether the 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)

J. Stang 10/14-Discussed, Set of bullets still under development; item will be discussed at next Panel meeting on 10/16; 11/04 -Discussed, J. Stang is adding to Comm. Matrix; 11/20-Only remaining is the documented criteria for proof of reasonable confidence; 12/15-Discussed, all inputs received from panel members-closure memo to document completeness confidence in draft and will go to Panel next week; 12/30-Discussed, Bullets in review and NRR will forward to Region; 1/06-Discussed, List of Bullets in final review and will be disseminated 1/09/04; 1/20-Discussed, List of Bullets will be sent to Region for review at next Panel; 1/26-Discussed, the final list of bullets will be emailed to the region by 1/29.

01/20/04

January 26, 2004 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Number Action Item (Date generated)

Assigned to Comments Due Date 219 Brief Jim Caldwell on how Immediate Action Maintenance issue was resolved. He would like to see the revised procedure.

(10/21)

S. Thomas 10/28-Brief will include research information on Exelon approach; 11/20-NRC is reviewing a copy of the licensees revised procedure; 12/15-Discussed, FENOC rep met with SRI 12/14 to review new procedure; 12/18-Discussed, need to setup briefing for RA; 1/06-Discussed, brief will be given to Branch Chief with follow on briefing then setup for Jim Caldwell; 1/20-Discussed, Briefing will be given during Jim Caldwells site visit, 01/22/04; 1/26-Discussed, briefing was held onsite 1/22. Panel decided this item is Closed.

01/22/04 220 Develop inspection plan requirements which include review of post restart security program effectiveness. (10/28)

D. Passehl 11/20-The plan is being developed and supplemented from baseline requirements; 12/15-Discussed, draft plan in final; 01/13-Discussed, decided this action item refers to only security inspections; 1/26-Discussed, Jim Creed will update region Panel members prior to Panel on 01/30/04.

02/02/04 224 Rewrite the proposed IN on TSP to be generic and reflect attainable plant conditions and what information should be disseminated to the industry concerning Boric Acid Corrosion Control Programs. (12/09)

D. Hills 12/15-Discussed, D. Hills is working; 12/23-Discussed, this issue will be discussed internally in RIII and brought to Panel on 1/06/03 for a final decision on how to proceed; 1/20-Discussed, revised IN is with Panel Chairman for review.

02/15/04 228 Place all Email requests sent throughout Agency, responses received, and issue resolutions in ADAMS package for documentation.

(12/16)

M. Mitchell 1/06-Discussed, will verify ADAMS package is in place to support collection of emails and responses-email requests will be resent due to small response to date.

01/23/04 231 As soon as the final RRATI report is issued, Email a copy to Rick Jacobs at INPO.(12/19)

D. Passehl 1/20-Discussed, expect report to be complete by 01/30/04.

02/09/04

January 26, 2004 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Number Action Item (Date generated)

Assigned to Comments Due Date 232 Track the status of the response to Gunter on Fire Protection Issues due 01/09/04. (12/30)

J. Stang 12/30-Discussed, J. Dyer briefed on 12/29/03; J. Caldwell brief scheduled for 12/31/03; 01/13-Discussed, due date extended until 01/16/04; 01/15-Discussed, the due date extended for final draft, by agreement with Region to 01/23/04; 1/26-Discussed, expect final response from Tech review by end of the week, 1/30.

01/23/04 234 Develop protocol paper for NRC representative on DOJ committee interface with 0350 Panel for updates.

(01/06)

W. Ruland 10/15/04-Discussed, protocol paper regarding decision making being drafted as a letter from Sam Collins to Bruce Boger and includes criteria for Immediate Action; 1/20-Discussed, the draft has been sent to B. Boger for DOJ comments; 1/26-Discussed, B.

Boger is reviewing with senior management.

01/16/04 235 Advise panel on need for post-restart inspection, based on review of our Greenpeace 2.206 petition and the immediate action response letter we issued on Nov 26, 2003 (01/08)

J. Jacobson 01/13-Discussed, will contact Jacobson for when a brief will be provided to the Panel.

01/26/04 236 Review the Dec 31, 2003 revision of NRC Inspection Manual Chapter 0350 against current Panel Process Plan and brief Panel on results. (01/13)

D. Passehl 1/20-Discussed, review in progress and Panel will be briefed on 01/30/04.

01/30/04 238 Draft a Memo from John Grobe to Caldwell, Dyer, and Collins to accompany and discuss sensitivity of information in DRAFT Restart Comm Plan. (01/15)

A. Mendiola 1/20-Discussed, draft memo will be sent to J. Grobe by the end of the week 1/23; 1/26-Discussed, draft emailed to J. Grobe for review.

01/21/04 239 (NEW ITEM)

Coordinate with OEDO to determine what appropriate response is required for the 1/16/04 Lochbaum Email on Commission interest in Davis-Besse (01/26)

W. Ruland 02/05/04

January 26, 2004 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Number Action Item (Date generated)

Assigned to Comments Due Date 240 (NEW ITEM)

Develop recommendations for revising the Panels criteria for determining if an allegation is a restart issue to focus on safety concerns.

(1/26)

C. Lipa 02/03/04 241 (NEW ITEM)

Meet with J. Strasma and determine policy dispositioning of future letters received from special interest groups/individuals.

(1/26)

R. Baker 02/03/04 242 (NEW ITEM)

Review MC 0350 and philosophy on which documentation is required for public dissemination and which should be purged following plant restart. (1/26)

D. Passehl 02/05/04

RAM Items Approved for Closure at Panel January 26, 2004 RAM Item No. - C-23 Closed: Y Description of Issue - Review D-B response to Generic Letter 98-04 regarding sump clogging. [Note:

Document determined to be incomplete and inaccurate.]

Description of Resolution - NRC Inspection Report 50-346/03-19 documented the NRCs review and assessment of the licensees response to Generic Letter 98-04, "Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant-Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment."

As indicated in the Inspection Report, the licensee has identified several corrective actions as a result of this issue that have been completed or are planned. The corrective actions and associated condition reports are:

Update the response to Generic Letter 98-04 (Complete - CA 02-03-1718)1

Revise the UFSAR (Complete - CA 03-03-01718)

Institute a Nuclear Safety-Related Protective Coatings Program (Complete - CA 02-02-03857)

Institute an inventory of all non-Design Basis Accident (DBA) qualified coating materials (Complete - CA 04-02-02437)

Removal and re-coating of Core Flood Tanks with DBA-qualified coating material (Complete - CA 03-02-03609)

Removal and re-coating of Service Water piping with DBA-qualified coating material (Complete - CA 06-02-02108)

Removal and re-coating of Reactor Vessel Head Service Structure with DBA-qualified coating material (Complete - CA 03-02-03609) 1The licensees submitted a revised response to Generic Letter 98-04 on November 26, 2003 (ML033370836).

Reference Material - NRC Inspection Report No. 50-346/03-19 (ADAMS accession number ml040280594) and Generic Letter 98-04 response (ML033370836).

RAM Item No. - C-34 Closed: Y Description of Issue - Fuel damaged due to loss of grid straps. (Formerly listed as an LER, however, no LER will be issued for this item).

Restart Checklist Item: 5.b Description of Resolution - Based on a review of the licensees handling of this issue, the NRC inspectors identified a NCV of Criterion XVI because the licensees initial actions taken in response to the SCAQ CR did not prevent recurrence as yet another new fuel assembly spacer grid strap was damaged during the final reload of the core in May 2003. The inspectors determined that there were

issues with human performance, both in regard to causing the damage and in evaluating the consequences.

The inspectors identified a number of weaknesses in the root cause report. However, the most significant issue appeared to be not addressing human performance issues. The team noted that there were more new or lightly burned fuel assemblies damaged more severely during this outage than during RFO 11. (The team didnt have any information on RFO 12, because the evaluator failed to include it as part of the generic implications review.)

The inspectors noted despite one condition report identifying that damage had occurred during reinstallation of a fuel assembly into the spent fuel pool, the report claimed that the damage had to be previously existing. The licensee did not provide sufficient rationale to support the claim that the damage had to be previously existing and had not adequately considered or addressed whether human performance issues played a role in the damage.

The inspectors also evaluated an event which occurred during the final fuel loading in February 2003.

The licensee did an apparent cause evaluation on this failure and concluded that it was a "design" problem with the fuel. The inspectors again considered that human performance had played a significant role in the damage occurring, based on the sequence of events documented in the condition report.

The inspectors identified the following specific problems:

The fuel handlers had spent approximately two hours unsuccessfully trying to load another fuel assembly into place before deciding to load an assembly out of sequence in a potential corner to corner interaction pattern. There was no indication that anyone suggested stopping the process and evaluating the condition, before agreeing to the out of sequence loading.

Multiple problems were experienced during a three hour attempt to load the fuel assembly, including multiple overload conditions and cable oscillations. The licensee reset the overload setpoints to the least limiting condition at least twice, and even this setpoint was reached.

Again, when problems were encountered, the decision was to keep on trying to insert the assembly, rather than stopping and evaluating what was happening.

The inspectors questioned whether schedule pressure to complete the job (especially as it was close to the end of the shift) may have played into the decision making process. Although the licensee personnel did not agree that schedule pressure contributed in any way, the inspectors noted that the fuel handlers spent over five hours trying to insert a fuel assembly which ended up being damaged.

The inspectors evaluated the acceptability of this issue for restart. The inspectors concluded that the fuel for Cycle 14 was loaded into the core, such that no recurrences of the event could occur until the next refueling outage. The inspectors also noted that the Phase 1 SDP worksheet stated that all fuel barrier damage should be screened as Green. Therefore, the issue screened out as having very low safety significance or Green and the inspectors thus concluded that this issue was ready for restart.

Reference Material - NRC Report No. 50-346/03-010 and licensee condition reports (CRs) 02-05645, 02-05895, 02-05896, 02-06178, 02-06343, and 02-09829, and associated root cause reports.

RAM Item No. - C-36 Closed: Y Description of Issue - Requests for Issues: Adequacy of cyclone separator to support HPI operability.

Description of Resolution - The NRR Project Manager reviewed the associated condition report (03-05186) and corrective actions relative to the cyclone separators for the Davis-Besse HPI pumps. The concern was that post-LOCA recirculation fibrous debris could clog a separator. The licensee tested for separator clogging at Wyle labs. and found that debris flow did not clog Model 20 cyclone separators (John Crane Co.), but could clog the inlet/outlet orifice ports. They also found that installing a spacer between the swagelok fitting and the inlet/outlet orifice ports solved the problem and plugging did not then occur. As a result, the licensee replaced the cyclone separators with larger Model 20 separators, and installed spacers between the swagelok fittings and the inlet/outlet orifice ports. In addition, most of the fibrous insulation has been removed from containment. Based on the corrective actions completed, NRR staff concluded that the licensee has adequately addressed the issue.

Reference Material - Licensee CR No. 03-05186.

RAM Item No. - LER-05 Closed: Y Description of Issue - Review and Evaluate Containment Sump LER and supplement. See also Condition Reports 02-3859 & 02-5461 Description of Resolution - On July 3, 2003, a Significance and Enforcement Review Panel meeting was held regarding the significance of the failure to effectively implement corrective actions for design control deficiencies regarding containment coatings, uncontrolled fibrous material and other debris inside containment. This deficiency resulted in the inability of the emergency core cooling system sump to perform its safety function under certain accident scenarios due to clogging of the sump screen. The NRC staff determined that several combinations of factors found lead to core damage frequency increases in the 10-4 (Yellow) range.

NRC Inspection Report No. 50-346/03-15, issued on July 30, 2003, discussed this LER in detail and included issuance of a Preliminary Yellow Finding and Apparent Violation (AV) 50-346/03-015-05 for the licensees failure to effectively implement corrective actions for design control issues related to deficient containment coatings, uncontrolled fibrous material and other debris. The failure to effectively implement the corrective actions resulted in the inability of the emergency core cooling system sump to perform its safety function under certain accident scenarios due to clogging of the sump screen. The Apparent Violation was issued pending determination of the findings final safety significance.

FirstEnergy provided a written response dated August 29, 2003, acknowledging the performance deficiency. FirstEnergy did not contest the Finding. FirstEnergy's response provided no new information to change the NRC's preliminary conclusion. On October 7, 2003, the NRC issued the Yellow Final Significance Determination, which included a violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," for the failure to promptly identify and correct significant conditions adverse to quality involving the potential to clog the emergency core cooling and containment spray system sump with debris following a loss of coolant accident.

As corrective actions, FirstEnergy performed extensive modifications during the current outage on the sump. FirstEnergy replaced the previous emergency sump strainer with a much larger strainer. The unqualified coatings and other debris, including fibrous insulation remaining in containment, have been walked down, verified, and documented. Debris generation, transport, strainer head loss, and strainer integrity analyses were performed for the emergency sump to return the emergency sump to full qualification and operability. The NRC inspected FirstEnergy's new sump, which is documented in

Inspection Report 50-346/03-06. The NRC concluded that the containment emergency sump design modification was consistent with the design and licensing basis requirements and based on field walkdowns the modification installation was adequately implemented consistent with the design. This issue is adequately resolved for restart and the LER will be closed in a future inspection report.

Reference Material - NRC Inspection Report Nos. 50-346/03-15 (ADAMS Accession Number ml032120360), 50-346/03-06 (ADAMS Accession Number ml031710897), and Generic Letter 98-04 response (ML033370836).

RAM Item No. - URI-45 Closed: Y Description of Issue - Failure to Effectively Implement Corrective Actions for Design Control Issues Related to Deficient Containment Coatings, Uncontrolled Fibrous Material and Other Debris (see LER-02-05).

Description of Resolution - This item is based on the followup results of inspection into the licensees event report 02-05, which is documented as a Yellow finding in Inspection Report 50-346/03-15. The writeup closing this item is identical to that closing the associated LER RAM item, LER-05.

Reference Material - NRC Inspection Report Nos. 50-346/03-15 (ADAMS Accession Number ml032120360), 50-346/03-06 (ADAMS Accession Number ml031710897), and Generic Letter 98-04 response (ML033370836).