ML051810467
| ML051810467 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/30/2005 |
| From: | Reynolds S NRC/RGN-III |
| To: | NRC/RGN-III |
| References | |
| IMC 0350 | |
| Download: ML051810467 (21) | |
Text
June 30, 2005 MEMORANDUM TO:
Davis-Besse Oversight Panel FROM:
Steven A. Reynolds, 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 October 27, 2004.
Attached for your information are the revised minutes from the internal meeting of the Davis-Besse Oversight Panel and the Open Action Items List. The minutes were revised to modify Attachment 1.
Attachments: As stated cc w/att:
U. Shoop, OEDO J. Caldwell, RIII G. Grant, RIII M. Satorius, DRP B. Clayton, EICS DB0350 See Previous Concurrences DOCUMENT NAME: C:\\MyFiles\\Roger\\ML051810467.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 NAME FRamirez CLipa SReynolds DATE 06/28/05 06/28/05 06/30/05 OFFICIAL RECORD COPY
MEETING MINUTES:
Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE:
October 27, 2004 TIME:
1:00 p.m. Central ATTENDEES:
C. Thomas C. Lipa W. Ruland J. Lara J. Hopkins G. Suh D. Passehl Agenda Items:
1.
Discuss/Approve Todays Agenda The Panel approved the agenda. THE APPROVED AGENDA REFLECTS THE ORDER LISTED IN THESE MINUTES.
2.
Discuss Plant Status and Inspector Insights and Emergent Issues List C. Thomas discussed the current plant status. Throughout this week, the plant was at or near full power with no significant issues to report.
3.
Discuss PI&R Inspection Plan D. Passehl led a discussion of the PI&R Inspection Plan. The Panel approved the inspection plan with minor comments. THE APPROVED PI&R INSPECTION PLAN IS ATTACHED TO THESE MINUTES.
4.
Discuss Lessons Learned Document D. Passehl led a discussion of the IMC 0350 lessons learned memorandum.
Section 0350-03 of IMC 0350 requires that a memorandum be provided containing lessons learned to be considered for incorporation into the next revision of IMC 0350.
The Panel provided comments that D. Passehl took action to incorporate.
5.
Discuss Update on DRS Activities J. Lara led a discussion of DRS activities. Topics discussed included dissemination of generic information regarding high pressure injection pump fiber matting; an electrical TS license amendment submittal; a SSDI clarification letter; service water licensing basis; CATI response; and a TSP Information Notice.
6.
Discuss New Allegations D. Passehl reported that there were no new allegations received this week.
7.
Discuss New/Potential Licensing Issues
J. Hopkins discussed no new/potential licensing issues. J. Hopkins mentioned that a communication plan is being developed for upcoming approval of a license amendment request regarding boron precipitation.
8.
Discuss Communications Status C. Lipa discussed an incoming 10/25/04 email regarding topics for the 11/16/04 public meeting. C. Lipa also discussed a letter to the Ohio Citizens Action Group that was signed out on 10/21/04 (ML043010225).
10.
Discuss Panel Process Plan D. Passehl led a brief discussion of the Panel process plan.
11.
Discuss Action Items The Panel closed Action Item 253, "Publicly release promptly all documents that need to go public as specified in IMC 0350." Per a 10/20/04 email from ADAMSSIM, the documents have been released publically.
The Panel closed Action Item 263, "Draft a memorandum to J. Caldwell and J. Dyer discussing the 0350 process termination criteria. Draft a second memorandum requesting approval to extend the 0350 process beyond two quarters past restart. The first item, "Draft a memorandum to J. Caldwell and J. Dyer.. " was closed with issuance of the memo on August 23 (ML042380480). The second item, "Draft a second memorandum requesting approval..." was closed with issuance of the memo on ML042960575.
The Panel closed Action Item 276, "Follow up on late changes to siren PI reporting by Licensee." The inspection notification letter was issued on 10/21/04 (ML042950159).
The Panel closed Action Item 281, "B. Berson to review reorganization to monitor position of responsibility." AITS Item R04-0172(jk) was initiated on August 18, 2004.
This item is in the Regional Administrator Action Item Tracking System with a special instruction to be re-issued every 6 months - new due date will be 6 months from completion (closed) date of this AITS.
THE UPDATED ACTION ITEMS LIST IS ATTACHED TO THESE MINUTES.
12.
Discuss/Update Milestones and Commitments The Panel discussed upcoming milestones and commitments.
DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item No.
Action Item (Date generated)
Assigned to Comments Due Date 265 Brief the Panel on the status of developing a document which captures Lessons Learned to date from the Davis-Besse 0350 Oversight process.
(4/13)
Suh 4/13-Discussed, development of the drafts should include a brain-storming session which includes comments and feedback from external stakeholders. NRR suggested to dedicate a special Panel meeting to this focused topic and will take the lead for obtaining input from external stakeholders.
J. Grobe mentioned that examples of processes that went well should also be addressed, such as the Panel's review of safety culture and the Panel's communication efforts with internal/external stakeholders; 4/27-Discussed, draft document emailed to the region. 9/2 - With Director of Communications.
TBD 266 Brief the Panel on the status of drafting the memorandum from the Panel to NRR addressing the Lessons Learned to be considered for the next revision to IMC 0350.
(4/13)
Lipa/Suh 4/13-Discussed, comments should be forwarded to C. Lipa/A.
Mendiola; 4/27-Discussed, need to base draft on specific line items from the Process Plan. 10/14-Discussed, comments provided to D. Passehl for incorporation into memo.
11/05/04 267 Contact Ellis Merschoff in early December 2004 to schedule a site visit during DB mid-cycle outage.
(6/17)
Lipa Outage currently scheduled for 1/17-2/08 2005.
12/10/04 269 Set up call with Licensee to discuss their response letters to CATI (4-5-04)and SSDI.
Lara J. Lara will be on site the week of 9/13/04 and will discuss with Licensee 9/16/04. 10/14-Discussed, Julio to follow-up with licensee next week.
10/29/04
DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item No.
Action Item (Date generated)
Assigned to Comments Due Date 270 Set up next meeting with county commissioners once date for the next 0350 Panel public meeting is set. (7/15/04)
Lickus Roland contacted Jere Witt informed him of the next meeting, J. Witt doesn't see a need for a separate meeting with the Commissioners. He will discuss it with them and if they desire a meeting, he will let Roland know.
Roland indicated he would follow up in November for a possible quarterly meeting. (9/7). 10/14-Discussed, Conduct meeting with County Commissioners in the afternoon of Dec 6 to coincide with 0350 Public Meeting.
12/06/04 271 Include Davis-Besse Status and LLTF status at next briefing for the county, NRR rep.
(7/15/04)
Thomas Action items described in the Ottawa County commissioner meeting summary which is attached to 7/15/04 Panel meeting minutes. 10/14-Discussed, Conduct meeting with County Commissioners in the afternoon of Dec 6 to coincide with 0350 Public Meeting.
12/06/04 278 Include pressurizer penetration TI in the special inspection plan for mid-cycle outage.
(08/12/04)
Holmberg/
Jacobson Mid-cycle Outage areas for inspection:
- 1) Order related Activities
- 2) Pzr inspection
- 3) ISI ? (not required but should it be done)
- 4) SG Inspection 12/16/04 279 Develop recommendation for Panel consideration of a chilling effect letter for safety conscious work environment concerns.
(8/12/04)
Lipa
/Passehl 10/14-Discussed, Monte Phillips did a prior analysis determine whether is still valid, integrate with OE and discuss with Lisa Jariel.
This is a separate issue from the cafeteria worker enforcement followup.
11/05/04 280 Define Criteria when PIs become valid and provide sufficient insight to Panel.
(9/2/04)
Lipa 11/15/04
Page 1 of 15 INSPECTION PLAN FOR DAVIS-BESSE NUCLEAR POWER PLANT IDENTIFICATION AND RESOLUTION OF PROBLEMS Report 05000346/2004017(DRP)
Inspection Objectives This inspection fulfills the baseline inspection program requirements for the biannual focused Problem Identification and Resolution (PI & R) inspection. This plan also fulfills that part of the post-restart inspection approach approved by the Manual Chapter 0350 Panel to review and assess Davis-Besse's corrective action program improvement initiatives.
This inspection is intended to:
C Provide for early warning of potential performance issues; C
Determine whether Davis-Besse is complying with NRC regulations regarding its corrective action program; C
Evaluate a sample of the Davis-Besse's post-outage improvement commitments; C
Followup previously identified compliance issues (e.g. NCVs); and C
Evaluate the potential for existence of cross-cutting issues.
Inspection Dates:
November 29 - December 17, 2004 Entrance:
November 29, 2004 Exit:
December 16, 2004 Applicable Inspection Procedures IP 71152B Identification and Resolution of Problems Prepared by:
Dave Passehl, Project Engineer Reactor Projects Branch 4 Reviewed by:
Christine A. Lipa, Chief Reactor Projects Branch 4 Approved by:
John A. Grobe, Chairman Davis-Besse Oversight Panel
Page 2 of 15 INSPECTION PLAN DETAILS I
Inspectors:
David Passehl, Team Leader, Project Engineer, DRP
- John Jacobson, Senior Metallurgical Engineer, DRS Benny Jose, Reactor Engineer, DRS John Rutkowski, Resident Inspector, Davis-Besse Richard Smith, Reactor Engineer, DRP
- December 13 - 16, 2004 II Detailed Inspection Schedule Inspection Preparation:
November 22 - 24, and 26, 2004 Onsite Inspection:
November 29 - December 16, 2004 In-Office Review:
December 6 - 10, 2004 Entrance:
November 29, 2004 Pre-Exit Debrief:
December 15, 2004 Exit Meeting:
December 16, 2004 Preparation of Inspection Report:
Input Due to Team Leader:
December 23, 2004 Draft Completed:
January 7, 2005 Report Due Date:
January 14, 2005 III Specific Inspection Activities Information Collection As part of the inspection preparation, the team leader will contact the licensee to request information shown at the back of this plan. If additional information is determined to be necessary then the team leader will convey this to the licensee as expeditiously as possible.
Preparation Week During November 22 - 24, and 26, 2004, the team will review the materials provided by the licensee, Inspection Procedure 71152, Cycle 14 Operational Improvement Plan Commitments, NRC inspection reports that were issued since the corrective action team inspection report (IR 03-10), and recently issued PI&R reports for other plants. The following should be included in the review:
Page 3 of 15 1.
Review licensee administrative procedures that control the identification, evaluation, and resolution of problems.
2.
Review NRC inspection reports issued since the corrective action team inspection report (IR 03-10) inspection and:
a.
Determine the extent to which cornerstones have been sampled by routine reviews of licensee PI&R activities and determine if additional PI&R samples are warranted in any cornerstone(s).
b.
Determine the extent to which licensee responses to NCVs have been sampled by routine reviews of licensee PI&R activities.
c.
Identify trends or patterns in corrective action program issues or performance which may warrant additional sampling to confirm. See Section X of this inspection plan, which contains guidance from a resolved ROP feedback form related to this area.
3.
Identify a sample of licensee corrective actions for review. The samples chosen for review should include a range of issues including (items in bold are mandatory per IP 71152). (Note: Specific corrective action samples to be inspected are included in Section VIII of this inspection plan.)
Licensee identified issues (including issues identified during audits or self assessments) including a sample of the highest significance level licensee corrective action items. The licensees root cause analyses associated with these high significance level corrective action items should be assessed using the inspection guidance contained in IP 95001 as an aid.
NRC identified issues during routine, team, and special inspections. Discuss such issues with respective NRC inspectors and management as part of inspection preparations (e.g., CRs generated from NRC inspections).
Issues related to NCVs (mandatory to review response to a sample of NCVs unless no NCVs were issued in the cornerstone)
Issues identified through NRC generic communications Issues identified through industry operating experience exchange mechanisms (including Part 21 reports, NSSS vendor reports, EPRI reports, operating experience reports from similar facilities, LERs)
Specific or cross cutting issues identified by safety review committees or other management oversight mechanisms Collective Significance Assessments of the Corrective Action Program
Page 4 of 15 Inspection Weeks While performing the inspection and developing comments, observations, weaknesses, issues, etc. try to bin the issues in one of the following 7 major categories: Problem Identification, Prioritization of Issues, Evaluation of Issues, Effectiveness of Corrective Actions, Effectiveness of Self-Assessments, and Effectiveness of Post-Outage Commitment Implementation.
This inspection will also review the results of the licensee's independent assessment of the corrective action area and compare those findings to the licensee's own self-assessment findings from earlier in the year.
In assessing the licensees corrective action program, we will use the Performance attributes listed in Inspection Procedure 71152 Section 03.03.c. In assessing Root Cause Evaluations, we will use the supplementary information provided by Inspection Procedure 95001.
In addition, we will focus on the following areas:
C Are CAs lacking in depth or yet to be acted on? Is there an owner assigned to the CR?
C Are CRs needing operability reviews being directed to the designated senior reactor operator and are correct determinations being made?
C Are WRs being inappropriately being used in lieu of CRs?
C Are WRs on TS-related components receiving adequate operability assessments?
C Assess completed CA effectiveness reviews, if determined to be ineffective, then determine why the corrective actions were ineffective. This will help characterize the effectiveness of the corrective action program.
C Verify completion of CAs by either plant walkdowns, or verifying procedure/policy changes were made and are still in effect (i.e., not inadvertently deleted with future revisions).
C Look for trends associated with configuration control.
C Focus on the adequacy of their plans to fix the trending process, both at the department level and at the site level.
C During the reviews, ensure that corrective actions address the cause and ensure that human performance issues are also addressed. Also, look for cases where the CRs or action tracking items were closed before the corrective actions were completed (a.k.a., "rollovers") and for cases where CRs or action tracking items were extended excessively. Review the coding of CRs to ensure that they are coded in accordance with the corrective action procedure. Incorrect/inconsistent
Page 5 of 15 coding could provide insight into the trending program for similar cause issues.
C Assess the use of risk in the licensees prioritization of work including the completion of corrective actions.
C Assess the consistency between departments (and between crews/shifts) of the threshold for writing CRs C
Assess the adequacy of the immediate corrective actions (including quarantine of equipment) and the adequacy of the extent of condition reviews including the impact of potential common mode failure issues.
C Insights regarding the effectiveness of the corporate CAP organization.
C For Root Cause evaluations is the root cause correct, are the Corrective Actions to Prevent Recurrence adequate? For Apparent Cause evaluations is the condition evaluation correct and do the corrective actions correct the issue (remember 10 CFR 50, Appendix B, Criterion XVI, states that only in cases of significant conditions adverse to quality that measures shall be taken to preclude repetition)?
Note: Rejection of any cause evaluation by the CARB requires remediation of the evaluator per NOP-LP-2001, CR Process. The remediation requirements and completion are supposed to be documented.
Each team member should choose as many examples as warranted for the areas they are assessing to complement the routine PI&R inspections and ensure a sufficient basis for evaluating the effectiveness of the licensee's PI&R program for those areas. In the inspector assignments Ive assigned a target goal number for items such as Root Cause Evaluations, but we can adjust those numbers. An effort should however be made to maintain the total hours expended in completing this procedure to within the estimated level of resources. (212 to 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> of direct inspection effort)
Risk Significant Systems at Davis-Besse The Initiators and System Dependency Table included in this inspection plan at Section IX identifies the most risk-significant systems at Davis-Besse and shows the major dependencies between frontline-and support-systems, and identifies their involvement in different types of initiating events. Footnotes are provided to explain design characteristics and considerations. This table will be used to identify any SDP worksheets that need to be evaluated, corresponding to inspection findings on systems and components.
Inspection Conclusions
Page 6 of 15 As we develop comments/observations findings we need to bin them in the following categories which will each be individual inspection report sections:
Problem Identification Prioritization of Issues Evaluation of Issues Effectiveness of Corrective Actions Effectiveness of Self-Assessments Effectiveness of Post-Outage Commitment Implementation By reviewing a sufficient number and breadth of samples, the inspection team should be able to develop insights into the effectiveness of the licensee's corrective action program. Compare the result of the team's review of corrective action issues with licensee performance reviews, including specific licensee reviews of the corrective action program. Determine whether licensee reviews are consistent with the NRC review of corrective action issues (from baseline inspection reports).
At the completion of inspection activities, the team should develop a clear and concise discussion of the results of their review. This discussion should be supported by the inspection activities conducted over the assessment cycle including both routine and annual inspection of PI&R activities.
IV.
Starfire and Time Charge Information The 71152 inspection module calls for 250 +/- 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> of direct inspection effort for problem identification and resolution. The direct inspection hours do not include time spent in travel, entrance or exit meetings, debriefing the residents, checking on e-mail, or keeping track of hours to correctly credit them. However, it does include time spent in team meetings and in preparing for team meetings. All time is to be charged to IP "71152B" with an IPE of "BI."
The hours of direct inspection effort equate to about 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> each for Passehl, Jose, Rutkowski, and Smith (240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> total). The hours of direct inspection effort should equate to about 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for Jacobson. Because it's recognized that activities other than just direct inspection will occur, the team leader will request authorization of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of overtime for each onsite week. If it appears that the scope of the inspection cannot be met within the allotted hours, inform the team leader so that RIII management can be notified to obtain authorization for additional hours.
V.
Findings Any findings resulting from the inspection will be reviewed using the Significance Determination Process (SDP).
VI.
Documentation
Page 7 of 15 The report will be prepared in accordance with the guidance in MC 0612 and with Appendix D to MC 0612. The report format will be modeled after recently issued PI&R inspection reports that were generated with the Appendix D format. Issues which the team deems meet the criteria for report writeups shall be discussed with the team leader prior to preparing an input.
Documents only critically reviewed shall be included in the document list. This would be any condition report or document we looked at and inspected from beginning to end, not just cursory reviews. (We will not included items reviewed as background or for information.) Each individual inspector shall maintain a list of documents reviewed (including appropriate titles, revision numbers etc.) Corrective action documents generated as a result of our questions will be input into an individual section of the list of documents reviewed. A goal is to be able to list the number of items reviewed in a given area and the number of issues noted to give a better assessment of the program. Also, ensure that concerns are compared to a standard (if possible) and are backed up by facts to better support our conclusions.
The team leader will have a disk which will contain only the "List of Documents Reviewed" section for the final inspection report. My suggestion is that at the end of the day or every other day we take the time necessary to input the items we critically reviewed into the file so this does not become a burden at the end of the inspection.
The list of documents reviewed will be broken into the following categories: Root Cause Evaluations; Apparent Cause Evaluations; Collective Significance Reports; Other Condition Reports; Self-Assessment Reports; Industry and NRC Documents; Davis-Besse Procedures and Other Administrative Documents; NRC-Identified Issues; and Miscellaneous. There may be other categories of documents for which another title is appropriate and this will be discussed during the inspection.
VII.
Interface and Coordination Meetings Team Meetings Informal team meetings will be held daily in the evening prior to departing the site for the day. The meetings will run no longer than 1/2 hour, unless there are significant issues to discuss. The intent is to allow each team member to discuss their status and determine if the focus needs to be shifted. If you have any significant issues dont wait until the evening to discuss them.
Meetings with the Licensee An entrance meeting will be held on November 29, 2004, with possibly a brief presentation by the Station on their Program and how they believe it is working.
Daily debriefings with the licensee will start on or about Tuesday of the first week time to be determined. These daily meetings normally will be between the team leader and the
Page 8 of 15 licensee unless there is an issue, than an individual team member will present their issue or observations.
The exit meeting will be held on December 16 time to be determined. All team members should be present and anyone who has issues or findings from the inspection should present them at the exit meeting; however, we will discuss this more as the inspection is started and the team assembled at the site. On Wednesday of the second onsite week will stop the inspection and put our thoughts together in a cohesive and structured manner, so that we can deliver a clear message to the licensee at the exit.
VIII.
Specific Inspection Assignments The following initial assignments are intended as an initial road map to the success of our inspection and we will adjust them as a team when necessary. (Note: Items with a
- are from Revision 5 of the Davis-Besse Nuclear Power Station Operational Improvement Plan Operating Cycle 14, June 21, 2004. The items in parentheses correspond to the commitment number.)
David Passehl - Inspect and assess the following:
Quality Assurance / Self Assessments of the corrective action program (do this first and report out to team members significant problems)
C 50.9 NCV followup from IR 04-09 Davis-Besse Triennial Fire Protection Inspection C
Review NRC identified issues or NCVs for adequacy of evaluation and corrective actions that have been closed by the licensee - target 2-3 randomly C
Attend CR Screening Meetings (after the management alignment and ownership meeting) and Corrective Action Review Board Meetings C
- Evaluate implementation of the licensee's apparent cause improvement plan (Item 9.1)
This item consists of:
C Corrective Action Review Board review of apparent cause evaluations until the licensee's standards are consistently met (Item 9.1.b)
C Company Nuclear Review Board (CNRB) review of selected apparent cause evaluations (Item 9.1.g)
C
- Evaluate the workload for condition report evaluations and corrective actions and the licensee's plans to reduce the backlogs to appropriate levels (Item 9.2)
C
- Evaluate the focused self-assessment of implementation of the corrective action program (Item 9.3)
Page 9 of 15 C
- Evaluate the corrective action program trending process (Item 9.4)
C
- Evaluate the licensee's assessment activities of the corrective action program to evaluate effectiveness of corrective actions taken to improve implementation and improve trend evaluation (Item 10.8)
C
- Evaluate implementation of the licensee's apparent cause improvement plan (Item 9.1)
This item consists of:
C Procedural requirements for apparent cause evaluations, including analytical methods to be used (Item 9.1.a)
C Identification of apparent cause evaluators (Item 9.1.c)
C Development of a training program and expectations and provide training to the apparent cause evaluators (initial evaluator classes and additional classes in 2004) (Item 9.1.d)
C Qualification of apparent cause evaluators and use of the systematic approach to training (Item 9.1.e)
C Interim rotation of apparent cause evaluators to Support Services (Item 9.1.f)
Benny Jose - Inspect and assess the following:
C Underground cable failure assessment - last Spring the 13.8 kV A bus feeder breaker for the #1 circulating water pump motor and the feeder breaker which supplies power to the high side of the two 13.8 kV/480V [AE4 and AE6]
transformers which supply power to the non-vital busses E4 and E6 tripped. The licensee found two problems: one was a phase to ground fault in the #1 circulating water pump motor, and the other was a phase to ground fault in the underground cable supplying the AE4 transformer.
C Understand the relationship, if any, between the two grounds C
Determine if corrective actions were proper for the underground cable supplying the AE4 transformer and assess the licensee's efforts to evaluate the extent of condition.
C Assess the licensee's corrective actions for a NCV (Green) of 10 CFR Part 50, Appendix B, Criterion XVI from Report IR 03-18. A NCV was identified for the failure of the licensee to address all significant causal factors related to the configuration control aspects associated with the installation of unqualified relays in the SFAS system.
C Review 1-2 Completed Root Cause Evaluations on significant systems listed in
Page 10 of 15 Section IX.
C Assess the Licensee's Use of Industry Experience in the Electrical Area.
Jack Rutkowski - Inspect and assess the following:
C Review and Evaluate a sample of condition reports and work requests/orders written since January 2004, pertaining to Auxiliary Feedwater. Are issues that affect equipment availability being captured for inclusion in PI and maintenance rule data? Compare work order lists to Corrective action lists to determine appropriate CR generation threshold, or if there was an operability issue and a CR was not written C
Assess the Licensee's Use of Industry Experience in the Operations Area.
C Assess the backlog of corrective maintenance items.
C Followup on 3-5 Random T.S. Surveillance failures C
Assess the licensee's corrective actions for a Finding (Green) identified for inadequate preparations for the onset of frazil ice conditions prior to January 6, 2004. Lack of coordination between licensee departments resulted in incomplete preparations prior to the onset of frazil ice conditions. (IR 04-02)
Richard Smith - Inspect and assess the following:
C Evaluate 4-5 operability evaluations on significant systems from Section IX.
C Evaluate 4-5 Apparent Cause Evaluations on significant systems from Section IX.
C Evaluate 3+ Root Cause Evaluations from significant systems from Section IX.
John Jacobson - Inspect and assess the following:
C Followup on a 2-3 Random T.S. Surveillance failures related to engineering type issues from systems in Section IX.
C Followup and Close, if appropriate, LER 2002-008-00 and -01, "Containment Air Coolers Collective Significance of Degraded Conditions."
C Assess the licensee's corrective actions for a NCV (Green) of 10 CFR Part 50, Appendix B, Criterion XVI from Report IR 03-23. A NCV was identified for failure of the licensee staff to identify an active steam leak through a seal weld on a pressurizer level transmitter source valve.
Page 11 of 15 IX.
INITIATORS AND SYSTEM DEPENDENCY FOR DAVIS-BESSE (1)
Affected Systems Major Components Support Systems Initiating Event Scenarios AC Power System (AC) (2)
AC Power Distribution and AC Instrument Power DC, Room Cooling All DC Power System (DC) (3)
Buses, Battery Chargers and Batteries (11,12)
AC, Room cooling All AFW 2 AFWTDPs, DC, main steam, Steam Feedwater Rupture Control System (SFRCS), SW (alternate suction)
All except MLOCA and LLOCA 1 AFWMDP, 1 startup feedwater pump (SUFP)
DC, AC, main steam, Steam, TPCW (for SUFP only), SW (alternate suction)
All except MLOCA,
LLOCA, ATWS, and LEAC HPI 2 Pumps each with 500 gpm at 1300 psig AC, DC, SFAS, CCW, room cooling, BWST (4)
All except LLOCA, ATWS, LCCW, and LSW LPI/DHR 2 Pumps and 2 Heat Exchangers (11)
AC, DC, CCW, SFAS, room cooling, BWST All except ATWS, LCCW, and LSW Makeup Pumps 2 Pumps (11) each with 150 gpm at 2500 psig AC, DC, CCW, room cooling All except MLOCA, LLOCA, LCCW, and LSW Borated Water Storage Tanks Makeup (BWSTMU) 2 Clean Waste Receiver Tanks (CWRT)
AC, DC SGTR EDG 2 EDGs (5) and 1 SBODG (6)
AC, DC, CCW, room cooling LOOP, LEAC CCW(14) 3 pumps in 2 loops (7)
AC, DC, SW, SFAS All Service Water System (SW)(15) 3 pumps (11) in 2 trains, back-up pump (12)
AC, DC, SFAS, room cooling All
Affected Systems Major Components Support Systems Initiating Event Scenarios Page 12 of 15 Instrument Air/Station Air (IA) 2 station air compressors (SACs) and 1 emergency instrument air compressor (EIAC)
LIA Power Conversion System (11) 2 TDMFW pumps and 3 condensate pumps Offsite power, IA, TPCW, CW (Circulating Water),
DC TRANS, TPCS, SLOCA, SORV, L4KVBUS, LDCD2P, SGTR, ATWS, LCCW, LSW AVVs (SG PORV),
MSIVs Per steam line: 1 AVV (11),
3 TBVs, and 1 MSIVs AC, DC, IA All MSSV (main steam safety valves)
Per steam line: 9 MSSVs None Same as AFW PORV (8,9) 1 PORV (10, 11) with block valve (11)
TRANS, SLOCA, SORV, SGTR, L4KVBUS, LDCD2P, TPCS, MSLB, LDCD1P, LOOP, LEAC, ATWS, LIA PSV (8) 2 PSVs (10, 11)
None TRANS, SLOCA, SORV, SGTR, L4KVBUS, LDCD2P, TPCS, MSLB, LDCD1P, LOOP, LEAC, ATWS, LIA RCP Seals (BJ -9000)
CCW for thermal barrier cooling, makeup pumps for seal injection SLOCA Room Cooling Fans, cooling coils SW, AC, DC All except LSW Turbine Plant Cooling Water (TPCW) (11) 3 Pumps, 3 Heat Exchangers AC, DC, SW, CW See Note 16
Affected Systems Major Components Support Systems Initiating Event Scenarios Page 13 of 15 Containment Air Coolers (CACs)
Three fan and coolers (11) in 2 trains 480 VAC, SW, SFAS All except LLOCA, ATWS, LCCW, and LSW Containment Spray (CS)
Two pumps in 2 trains AC, DC, room cooling, SFAS see footnote 13 Accumulators two accumulators direct vessel injection None LLOCA Notes:
Withheld from the public in accordance with 10 CFR 2.390 l
Page 14 of 15 X.
PI&R Trend Review Guidance from a March 30, 2004, PI&R feedback form l
The following is the relevant excerpts from the form:
This feedback forms raises several issues associated with the new IP 71152 inspection requirements to review all corrective action entries and to perform a semi-annual trend review. Subsequent to the initiation of this feedback form, many of the issues were discussed with the NRR program office at each of the four regional counterpart meetings held in December 2003. In addition, two teleconferences were held with Region III inspectors to discuss these issues in more detail. The below guidance, which is provided in question and answer format, was provided to inspectors.
- 1. Why was the change made? What do we hope to accomplish by it?
The change was made in response to the DBLLTF recommendations, specifically those recommendations pertaining to the identification and follow-up of longstanding equipment issues.
1a. The inspection basis describes that we screen ALL corrective action program issues: depending on the intent of the change does that mean just the new CRs written
- or does it also mean the corrective actions and the possibly WR/WOs?
The inspection requirement is to screen all items entered into the corrective action program only. However, to the extent practical, inspectors should be alert to equipment issues being dealt with outside the corrective action program and should not ignore such issues if identified during associated activities.
- 2. The licensee's CR process is looked at during our 10 percent reviews and also during maintenance effectiveness. Based on the guidance in Section 02.01 of the PI&R procedure - it describes several items to assess, items in addition to the those contained in the CAP, for possible trends. Is it the expectations that all of the specified items are reviewed to try and identified trends and then compare any potential trends to what the licensee has in their corrective action program?
The guidance lists several places that equipment issues may have been identified outside of the corrective action program. Some licensees are more susceptible to this than others due to the structure of their corrective action program or to the way they are implementing the program. It is not an expectation that inspectors review all items on these lists. The intent is that inspectors be cognizant of the vulnerabilities in this area and focus on those areas their particular licensee may be vulnerable.
2a. What is a "trend"?
For the purpose of this review, a trend can be defined as more than one instance of a problem for which the licensee has not taken adequate corrective actions. We should only be documenting those trends to which the NRC inspector has provided added value. For example, if the licensee has identified a trend and is taking what appears to be effective corrective actions, we should not document the trend. If we identified a trend that was not previously recognized by the licensee or if we believe the specified
Page 15 of 15 corrective actions to a licensee identified trend are inadequate we would document the trend.
- 3. Should we be doing something different than we did before? We don't have a tool to systematically look for trends - if we are not systematic we will be ineffective and inefficient. As shown by biennial PI&R inspections, it is difficult for the licensee to do an adequate job of trending even with a staff dedicated to that effort, and their reviews rarely go outside the CAP to look for trends. The concern is if someone thinks that these new requirements are going to be the barrier that is going to prevent another D-B, without more guidance on what is expected (and possibly resources to accomplish it) it is unlikely we can assure that the barrier will be effective.
Clearly this trend review, by itself, will not prevent another DB nor is it meant to replace what the licensee does. Some licensees have extensive equipment trending programs that go beyond the maintenance rule, while others rely on ad hoc programs run by system engineers. For the licensees with extensive equipment trending programs it is unlikely we would be able to identify additional trends, so the focus should be on assessing corrective actions to the trends that the licensee has identified. For licensees with less extensive equipment trending programs, more effort should be spent on identifying trends they might have missed.
Hopefully, if done correctly, the trend review will provide a place for inspectors to clearly document and communicate both internally and externally, concerns about inadequate licensee corrective actions to issues that might otherwise have been overlooked. At each site, it would be my expectation that the resident inspectors are aware of what equipment is causing the licensee problems, and what equipment problems appear to be repetitive.
- 4. What will be the NRC follow-up actions to identified trends? How will the identification of a trend be integrated with the ROP assessment process?
While not a prerequisite, it is anticipated that all NRC identified trends would be considered licensee performance issues, and as such, should be classified as a green (or greater) inspection finding with or without an associated Appendix B, Criterion XVI violation. In addition, the trend may meet the criteria contained in IMC 0305 for a cross cutting issue.