ML041490094
| ML041490094 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/23/2004 |
| From: | NRC/RGN-III |
| To: | |
| References | |
| FOIA/PA-2004-0140 | |
| Download: ML041490094 (20) | |
Text
Slide 1 0350 Panel Briefing for NRC Senior Management Davis-Besse Oversight Activities Panel Restart Deliberation Briefing February 23,2004 t (
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Slide 2 I
Davs.-Base Ovenight Acavides Briefing Book Contents
- Confirmatory Action Letter
- 0350 Panel Charter
- Licensee Return to Service Plan
- NRC Restart Checklist
- 0350 Panel Process Plan
- Significant Inspection Findings/ End of Cycle Summary Report
- Public Interactions
- Briefings for Public Officials Feb "wyZL 212f99 (LIPA)
Discuss each item in the Briefing Book (Please flip to TAB B) Confirmatory Action Letter - Issued March 13, 2002 - Updated five times - 6 specific commitment areas, Quarantine, Root Cause, Extent of Condition, Repair or Replace of Head, Risk Assessment, and Meet with NRC for Restart Approval.
(Please flip to TAB C) 0350 Panel Charter - Issued in April 2002 -
Introduce each of the Panel Members (Grobe, Ruland, Lipa, Hills, Jacobson, Mendiola, Hopkins, Thomas, Sonia Burgess). Discuss breadth and depth of Regulatory experience, and continuous involvement with project.
(Please flip to TAB D) Licensee Return to Service Plan - Licensee's org chart and building blocks for their Return to Service Plan. Panel considered it a comprehensive plan. A living plan, it has been revised six times.
(Please flip to TAB E) NRC Restart Checklist - Listing of items on the checklist, categorized into seven areas. Developed using the AIT and AIT Follow-up inspection findings and the licensee's RTS plan. Used to guide our inspection and assessment activities.
(Please flip to TAB F) 0350 Panel Process Plan - Developed specifically from IMC 0350 requirements.
(Please flip to TAB G) Significant Inspection Findings - Table of colored findings identified at Davis-Besse during the extended shutdown.
(Please flip to TAB H) End of Cycle Summary Report - Used in February 2004 EOC meetings (Please flip to TABs I thru K) Reference material - Material from Public Interactions (Specifics on Public Meetings, a copy of the Monthly Public Newsletter, and sample of correspondence with the public)
(Please flip to TAB L) Briefings for Public Officials - Reference Material on Briefings for Congressional, State, and Local Officials (Please flip to TAB M) Current copy of 0350 Procedure - dated 12/31/03, some of the DB lessons-learned was provided by the Panel to enhance this procedure. Additional insight to be used in future revisions.
Slide 3 Davs-Besse Omight Acilvides 0350 Panel Formation
- March 2002 Discovery of Degradation
- Augmented Inspection Team
- Confirmatory Action Letter
- 0350 Decision
- Restart Checklist
' 23.2fl0 2
(LIPA)
Discuss each item of the Background information March 2002 Discovery of Degradation - Plant shut down on 02/16/2002.
Inspection of CRDM penetrations to be done in response to NRC Bulletin 2001-01. Degradation found on 03/06/02.
Augmented Inspection Team - Sent on 03/12/02 Confirmatory Action Letter - Issued on 03/13/02 0350 Decision - Decision to initiate 0350 panel made on 04/29/02 Restart Checklist - Panel issued on 08/16/2002, developed IAW IMC 0350. Revised as necessary as panel gained insight from inspections and licensee assessments. Last updated in July 2003.
Slide 4 I
Davis-DBa Oversight Adlides 0350 Panel Process
- Focus on Safety
- Panel Process Plan
- Restart Action Matrix
- Restart Checklist Closure
- Internal Panel Meetings
- Communications Plans - Communication Team
- Licensing Activities F.bnzv2t2OiJ 4
(LIPA/MENDIOLA)
Discuss Panel Process - SAFETY FOCUS Use of high standards, regulatory rigor to maintain our safety focus Panel Process Plan - Example - B.4 Assessment of Licensee Performance area, Quarterly evaluation by the panel of the licensee performance indicators, evaluation by the panel of inspection findings and results, all documented in panel minutes that will become publicly available.
Restart Action Matrix - Example - over 325 items dispositioned, each one evaluated and documented and brought to panel for approval closure.
Additionally, the Panel polled the NRC staff for restart concerns and dispositioned all concerns and documented into the RAM. Incorporated all inspection attributes for Inspection procedures 95002 and 95003 into inspection activities, tracked by the RAM.
Restart Checklist Closure - Each inspection team developed specific Inspection Plans using existing inspection modules and additional details from the RAM. Each one was brought to Panel for approval.
Internal Panel Meetings - Met on average two to three times at week, detailed panel meeting minutes to be made public.
Communications Plans - Communication Team - Example - use of communication matrix and a communication disposition rules to consistently approach communications. (GET COPY)
Licensing Activities - Example - Use of the Restart Checklist to inform the panel and track restart licensing actions (such as Code Relief Requests) to completion.
Slide 5 fI Davis.Besse Oversight Advides Licensee's Assessment of Root Causes
- Reactor Pressure Vessel Head degradation caused by PWSCC and Boric Acid Corrosion
- Lack of Nuclear Safety Focus Led to Acceptance of Degraded Plant Conditions
- Other Deficiencies Determined in Corrective Action Programs, Engineering Analyses, Procedure Compliance, Quality Assurance Oversight, Operations Leadership and Safety Focus of Company Nuclear Review Board Febncoy 218 2f (MENDIOLA)
Licensee's Assessment of Root Causes Licensee's RPV degradation RC issued in April 2002 and updated in Sept 2002. NRC staff evaluated it as a plausible scenario. Uncertainties with aspects of the root cause preclude a definitive conclusion.
Licensee's Management and Human Performance RC issued in August 2002, the first of seven assessments performed from 2002 to early 2003 on Organizational Issues. The NRC has evaluated all of these seven assessments and found them to be 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.
Slide 6 Davis.Bezse verlghtActivldes NRC's Most Challenging Areas
- Corrective Action Program
- Engineering Analyses
- Operations Performance
- Safety Culture - Management and Human Performance
- Ongoing Investigation Status
- Public Access and Stakeholder Involvement
- hbsiry.2Xft0 (MENDIOLA)
NRC's Most Challenging Areas (This is a lead-in slide for the next six slides. Details will discussed during those slides).
Corrective Action Program Engineering Analyses Operations Performance Safety Culture - Management and Human Performance Above Licensee Programs found acceptable with the need for an Order to provide for lasting improvements Ongoing Investigation Status Public Access and Stakeholder Involvement
Slide 7 Davis-Base Oversight Actities Corrective Action Program
- Licensee Found Deficiencies in the Implementation of their Corrective Action Program
- 2002 SSDI inspection found numerous system design issues which were placed in CAP
- Licensee's Program Review and Enhancements
- Corrective Action Team Inspection of Licensee's Resolution of SSDI findings and RAM Items Vcbnry 23.2W0 7
(LIPA)
Licensee found deficiencies in the implementation of the program thru their root cause evaluation for the RPV Head degradation.
2002 SSDI inspection found numerous system design issues which were placed in CAP (30 URIs and NCVs)
NRC Inspected the Licensee's Program Review and Enhancements and found the program to be acceptable, but Panel left the Restart Checklist item open until implementation of the problem evaluated by the CATI Corrective Action Team Inspection of Licensee's Resolution of SSDI findings and RAM Items (95003 Attributes). Team found concerns with engineering analyses and resolution of design issues (Myopia of apparent cause assessments and trending program). More that 25 Violations, low significance (engineering quality, calculations and analyses).
CATI team concluded that licensee's program is acceptable for restart.
Significant 0350 Panel interaction with CATI.
Slide 8
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Dads Besse Ovezsight Activiaus Engineering Analyses
- Replacement of the Reactor Pressure Vessel Head
- CATI Identified Weaknesses in Resolution of Design Issues and Engineering Analyses Idvnau 2J2l.
(MENDIOLA)
Replacement of the Reactor Pressure Vessel Head To the NRC this was Unique, complex, first of its kind evaluation, involving an onsite inspection of head, and placement thru containment and removal and storage of old head. - NRC found licensee resolutions effectively planned and implemented.
High Pressure Injection pumps, Emergency Sump, and Containment Coatings Complex engineering evaluations performed, NRC reviewers found them to be complete and well performed. Extensive NRC interactions with dedicated technical reviewers on HPI pump and Emergency Sump work, including interfacing with Licensee Consultants and Vendors, visiting testing laboratories, and performing onsite reviews.
CATI identified weaknesses in design engineering, resolution of design issues, and engineering analyses as evidenced by 25+ low significance violations in the CATI report
Slide 9 D Yis4-Be Ovetsight Acdvides Operations Performance
- September 2003 NOP Test
- December 2003 RRATI Results
- Late December Operational Challenges
- January 2004 Corrective Actions and Management Changes
- February 2004 RRATI Follow-up rehmyiU2Mf (LIPA)
Operations Performance September 20,2003 NOP Test - Heat up Operational Performance issues (Core Flood Tank and Cool Down Reactor Trip)
December 2003 RRATI Results - Inconsistent understanding and implementation of Operational standards and expectations Late December Operational Challenges - Technical Specification Violation and Tagout of Valves (Missed LCO)
January 2004 Corrective Actions and Management Changes - Peer Observers, improved pre-job briefs, put Operations in charge for the plan February 2004 RRATI Follow-up - Found improvements, actions successful implemented, no concerns for restart
Slide 10 D2vIs.Be&se OverIght AcvWldes Safety Culture - Management and Human Performance
- Review of Licensee Root Cause
- Review of Licensee's Corrective Actions
- Review of Effectiveness of Corrective Actions
- November 2003 Survey Results Vebwar 23 10 (LIPA)
Why a challenge - not a specific NRC area of Inspection, used Criterion XVI of Appendix B Review of Licensee's Root Cause Use of experienced team of Inspectors - Phase 1 of M&HP inspection -
concluded that the licensee actions to be of appropriate depth and breadth to correct and prevent recurrence of the management and human performance deficiencies associated with the reactor head degradation.
Review of Licensee's Corrective Actions Phase 2 - Based on review of selected corrective actions, the team concluded that corrective actions if properly implemented and monitored would address the licensee's root causes.
Review of Effectiveness of Corrective Actions Phase 3 - Concluded that the tools that licensee was using to monitor safety culture and SCWE were appropriate and provided valuable information in theses areas.
November 2003 Survey Results There were additional negative responses (in area of Production over Quality) in a number of key organizations as compared to the March 2003 Survey. M&HP team concluded that the licensee's assessment of the causes for the increased negative responses and the licensee's corrective actions was appropriate.
LEAD IN TO JACK's COMMENTS
Slide 12 Davis-Bese OverSight Acdvides Public Access and Stakeholder Involvement
- Over 70 Public Meetings
- More than 50 briefings for Federal, State, and Local Officials
- Davis-Besse Public Web Site
- Several Thousand Letters and E-Malls
- Three 10 CFR 2.206 Petitions
- Demonstrated our Public Availability and our Focus on Safety f'tern 23 2l4 (MENDIOLA)
Over 70 Public Meetings More than 50 briefings for Federal, State, and Local Officials Davis-Besse Public Web Site Several Thousand Letters and E-Mails Three 10 CFR 2.206 Petitions Demonstrated our Public Availability and our Focus on Safety, enhancing public confidence in the NRC
Slide 13
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DatIs-Besse Overisght Acetives Panel Recommends Confirmatory Order at Restart
- Ensure Performance Improvements are Lasting
- Requires Independent Outside Assessment
- Areas Include Safety Culture, Engineering, Corrective Actions, and Operations
- Mid-cycle Outage Related Activities rcbqZ3 2. 2nJ U
(MENDIOLA)
Issue a Confirmatory Order to Ensure performance improvements are lasting
- Two Conditions of the immediate effective order are to provide to the NRC reasonable assurance that the long-term corrective actions remain lasting and effective for those conditions that resulted in risk-significant performance deficiencies.
- The two conditions are (1) annual independent assessments for five years in the areas of operations, engineering, corrective actions, and safety culture and (2) inspection and evaluation of the RCS pressure boundary during a mid-cycle outage.
Requires Independent Outside Assessment Areas include Safety Culture, Engineering, Corrective Actions, and Operations Mid-cycle Outage Related Activities
Slide 14 rM)
Davis.Bese OvenicghtAcivide Oversight Should Restart Be Authorized
- Around-the-clock Inspection of Start-up Activities
- Inspections to Confirm Licensee Actions Related to the Order
- Enhanced Inspections Related to NRC Performance Indicators
- Resident Inspection Staff has been Augmented
- Davis-Besse Oversight Panel will Continue to Assess Licensee's Performance and Guide NRC actions FehxryM23a 14 14 (LIPA)
Around-the-clock Inspection of Start-up Activities - Upon licensee consent to the order and before Low Power Physics testing Inspections to Confirm Licensee Actions Related to the Order Enhanced Inspections Related to NRC Performance Indicators are not Currently Informative Resident Inspection Staff has been Augmented Davis-Besse Oversight Panel will Continue to Assess Licensee's Performance and Guide NRC actions Panel Membership to be adjusted as appropriate Support post-restart oversight and inspection plans Panel has prepared and approved an inspection schedule update letter to the licensee An NRC Lead Engineering Inspector (based in Region III) will be assisting with the inspections and evaluations Special inspections to be added to verify license actions related to the order Expanded baseline inspections thru March 2005 to regularly assess effectiveness of CA program
Enhanced inspections planned to gain perspective in areas monitored by NRC performance indicators to gain sufficient insight into plant performance.
Slide 15 M)
Davisl-Besse Overslght Activides 0350 Panel Outcomes
- 0350 Panel Focused Agency Resources on Safety
- Used Methodical Regulatory Processes
- Effectively Monitored and Assessed Licensee Improvement Efforts
- Enhanced Public Confidence
- Achieved the Agency's Mission and Goals I'ebnar2.1.2j4 IS (MEINDIOLA) 0350 Panel Focused Agency Resources on Safety Used Methodical Regulatory Processes Effectively Assessed and Monitored Licensee Improvement Efforts Enhanced Public Confidence through Extensive Interactions with the Public - Based on high communication standards, regulatory rigor, and numerous effective public interactions.
Achieved the Agency's Mission (protect public health and safety) and Goals (Unnecessary Regulatory Burden, Increase Public Confidence, Maintain Safety, Effective, Efficient and Realistic)
Slide 16 NVDSsiseBeSM Oye"Clht AcvIdes Panel Conclusions and Recommendations
- Licensee Performance is Adequate for Safe Restart and Operation
- Authorize Davis-Besse to Restart
- Issue a Confirmatory Order to Ensure Performance Improvement is Lasting
- Implement Post-Restart Panel Oversight and Inspection Plans Fcbrury 2. 200I (LIPA)
Licensee Performance is Adequate for Safe Restart and Operation Concluded that the facility and the licensee's staff performance is adequate to support safe restart and operation Authorize Davis-Besse to restart Issue a Confirmatory Order to ensure performance improvements are lt S
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An NRC Lead Engineering Inspector (based in Region III) will be assisting with the inspections and evaluations Special inspections to be added to verify license actions related to the order Expanded baseline inspections thru March 2005 to regularly assess effectiveness of CA program Enhanced inspections planned to gain perspective in areas monitored by NRC performance indicators to gain sufficient insight into plant performance.