ML052570798
| ML052570798 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/12/2005 |
| From: | Reynolds S Division of Nuclear Materials Safety III |
| To: | NRC/RGN-III |
| References | |
| IMC 0350 | |
| Download: ML052570798 (30) | |
Text
September 12, 2005 MEMORANDUM TO:
Davis-Besse 0350 File FROM:
Steven A. Reynolds, Chairman
/RA/
Davis-Besse 0350 Panel
SUBJECT:
DOCUMENTATION OF COMPLETED POST-RESTART PROCESS PLAN FOR TRANSITION OF DAVIS-BESSE FROM THE IMC 0350 OVERSIGHT PROCESS TO THE REACTOR OVERSIGHT PROGRAM (ROP)
The purpose of this memorandum is to document how each of the requirements of IMC 0350 was met regarding transition of the Davis-Besse Nuclear Power Plant from the 0350 process to the Reactor Oversight Process (ROP).
Davis-Besse Nuclear Power Plant has maintained an acceptable post-restart period of operation, and met all the criteria for termination of the IMC 0350 process controls as defined in the attached post-restart Panel Process Plan. The licensee has established a long-range improvement program, is sufficiently implementing its corrective action program, has demonstrated safe plant operation and overall improving performance, and has adequate controls in place to address the plant-specific issues that caused the IMC 0350 to be implemented on April 29, 2002. Following review of the licensees performance and comparing it against the requirements of IMC 0350, the Panel recommended to the Region III Regional Administrator, in a May 9, 2005, memorandum, termination of the IMC 0350 process and recommended a return to the ROP (ML051360379).
The Region III Regional Administrator consulted with the Director of NRR and the Deputy Executive Director for Reactor Programs and Preparedness on May 13, 2005. On May 19, 2005, the Regional Administrator approved the transition from the IMC 0350 process and return to the ROP for Davis-Besse, as documented in a letter to the licensee (ML051400049). In addition, the Region III Regional Administrator, in consultation with the Director of NRR, issued a deviation memorandum on May 16, 2005, requesting additional inspection hours above those specified in the ROP. The memorandum was approved by the Executive Director for Operations on May 18, 2005, (ML051390321). The Panel also conducted a survey of NRC personnel who had been involved with Davis-Besse for any concerns regarding the plants return to ROP. The results of that survey were satisfactory and are documented in a May 10, 2005, memorandum (ML051330274 - non-public).
CONTACT:
Monte Phillips 630/829-9806
DB 0350 File In addition, a Public Meeting between the NRC and licensee to discuss the transition from IMC 0350 to the ROP was held on May 24, 2005. The Public Meeting Notice (ML051310444) was posted on the NRC web page on May 11, 2005, and the meeting summary was issued on June 2, 2005, (ML051530370). The IMC 0350 Panel also produced a Communication Plan (ML051370173 - non-public), informing both internal and external stakeholders of Davis-Besses transition from IMC 0350 to the ROP, and a Press Release (ML051400258) to inform the public of this transition.
Attachment:
As stated cc w/att:
P. Habighorst, OEDO W. Macon, NRR/PD-III J. Caldwell, RIII G. Grant, RIII K. OBrien, EICS DB0350 DOCUMENT NAME: C:\\MyFiles\\Roger\\ML052570798.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
- See previous concurrence OFFICE RIII RIII NRR RIII NAME MPhillips*/sls CLipa WRuland by email SReynolds DATE 08/16/05 08/30/05 08/16/05 09/12/05 OFFICIAL RECORD COPY
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Page 1 of 28 B.1 AGENCY RESPONSE B.2 NOTIFICATIONS AND ONGOING COMMUNICATIONS B.3 ESTABLISH AND ORGANIZE THE NRC OVERSIGHT PROCESS B.4 ASSESSMENT OF LICENSEE PERFORMANCE B.5 RESTART AUTHORIZATION B.6 RESTART AUTHORIZATION NOTIFICATION The activities listed above have been accomplished and details are provided in the previous version of the Process Plan, which is publicly available in ADAMS. (ml042100422) These Section headers are provided here only for continuity purposes.
B.7 POST RESTART OVERSIGHT "After the NRC has granted approval for the licensee to resume reactor operations, the Panel should remain involved in an oversight capacity for at least one quarter following plant restart. The Panel should assess whether a longer period of time is warranted based on licensee performance. The length of time of post-restart oversight may vary, depending on a case-by-case basis and evaluation. If post-restart oversight beyond two quarters is warranted, then a recommendation to the Regional Administrator and the Director of NRR to continue the oversight activities should be made.
At the end of each quarter, the Panel should evaluate the performance data and any inspection findings and make subsequent step adjustments in the appropriate level of NRC oversight activity."
Task Description Responsibility Planned Comp Date Actual Comp Date Comments B.7.1 ASSESS PERFORMANCE
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 2 of 28 B.7.1.1 Monitor licensee performance to assess whether corrective actions implemented since startup were effective to prevent recurrence of the problem.
This review will be conducted at least quarterly and will include quarterly PIs and inspection findings.
Determine if adjustments are needed to the level of required inspection oversight on a quarterly basis. Use the Action Matrix to aid in the determination of required inspections. Update the inspection plan when necessary.
Panel/Lipa 05/11/04 06/03/04 1st Quarter CY2004 Review of PIs and Inspection Results Panel Minutes 6/03/04 (ml041890575) 07/29/04 08/06/04 08/11/04 09/07/04 07/29/04 08/06/04 08/11/04 09/07/04 2nd Quarter CY2004 Review of PIs and Inspection Results Panel Minutes 08/06/04 (ml042260111)
Midcycle Review in Region III per MC 0305 (ml042260111 - non-public)
Inspection Schedule Update (ml042570044)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 3 of 28 12/02/04 12/02/04 3rd Quarter Cy2004 Review of PIs and Inspection Results Panel Minutes 12/02/04 (ml050410165) 02/25/05 02/08/05 02/25/05 02/08/05 4th Quarter CY2004 Review of PIs and Inspection Results, minutes from meeting (ml0508403610)
End of Cycle internal review per IMC 0305
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 4 of 28 B.7.1.2 Assess the results of special inspections to confirm licensee actions required by the Confirmatory Order and licensee commitments as stated in the integrated restart report. Assess any changes in scope or schedule of implementation of commitments, including LERs and licensee self-assessments.
Thomas/Lipa Operations Assessment 05/17/04 06/30/04 08/05/04 08/25/04 10/07/04 12/20/04 12/22/04 03/15/05 05/17/04 06/30/04 08/05/04 08/25/04 10/08/04 12/20/04 12/22/04 03/15/05 Submit original and revised letter to NRC, scope of independent assessment plans - ml041400440(5/17),
ml042040380(6/30), & ml042300211(8/5)
August 16 to 25, 2004 - Conduct independent assessment October 8, 2004 - Submit results for independent assessment (ml042860326 & ml042860474)
Request licensee to have the Independent Assessment Team revise report to include an overall assessment. (Request made in IR2004015)
Revision of report by licensee submitted 12/22/04 (ml043630476)
Plan for 2005 assessment submitted 3/15/05 (ml050750301)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 5 of 28 Passehl/Lipa Corrective Action Program Assessment 06/01/04 07/02/04 10/01/04 11/15/04 04/12/05 06/15/04 07/02/04 08/13/04 10/01/04 11/15/04 04/12/05 Submit original (6/15/04 - ml041680329 resubmitted 7/2/04 - ml041890483) and revised (8/13/04 -
ml042300159) letter to NRC, scope of independent assessment plans September 12 - 21 and September 27 -
October 1, 2004 - Conduct independent assessment November 15, 2004 - Submitted assessment results for independent assessment (ml043280134)
Plan for 2005 assessment submitted 4/12/05 (ml051030011)
Jacobson/
Stone Engineering Program Assessment 07/08/04 10/22/04 12/06/04 07/12/04 10/22/04 12/06/04 Submit letter to NRC, scope of independent assessment plans ml042040376 (7/12)
October 11 - 22, 2004 - Conduct independent assessment December 6, 2004 - Report issued 12/6/04 ml043420360
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 6 of 28 Wright/Lipa Safety Culture Assessment 08/05/04 12/21/04 02/04/05 03/04/05 08/04/04 12/21/04 02/04/05 03/04/05 Submit letter to NRC, scope of independent assessment plans ml042300286 and ml042450416 (8/4)
November 8 - 16, 2004 - Conduct independent assessment - Exit 12/21/04 February 4, 2005 - Submit assessment results for independent assessment (ml050380539 non-public)
March 4, 2005 - (REDACTED) Submit assessment results for independent assessment (ml050660425 public)
B.7.1.3 Review docketed correspondence, performance improvement plan changes, long-term corrective actions, and licensee self-assessments for those issues not implemented before restart.
Thomas/Lipa Ongoing 03/24/05 Panel updated on 12/02/04 & 03/24/05 Passehl/Lipa Ongoing 03/24/05 Panel updated on 1/24/05 & 03/24/05 Jacobson/
Stone Ongoing 03/24/05 Panel updated on 1/6/05 & 03/24/05 Wright/Lipa Ongoing 03/24/05 Panel updated on 12/15/04 & 03/24/05
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 7 of 28 B.7.2 PLAN AND COORDINATE WORK B.7.2.1 Issue an inspection plan for the next 6 months, even if the post-restart oversight period is less. Include inspections in areas not covered by the PIs and that are beyond the normal baseline inspection program. Update as required on 6 month intervals.
Panel/Passehl 03/08/04 08/30/04 09/03/04 03/02/05 05/20/05 03/08/04 08/30/04 09/07/04 03/02/05 05/19/05 Issued to licensee (ml040690829)
Security Inspection plan (ml042440589 - non-public)
Inspection Schedule Update (ml042570044) issued after 2004 Mid-Cycle review, but no Mid-Cycle assessment letter Physical Protection Inspection Plan (ml050620055 -
non-public)
Inspection Schedule Update issued after CY2004 End of Cycle review and as part of transition letter out of 0350 oversight per B.8.4 below (ml051400049)
B.7.2.2 Conduct internal panel meetings to periodically discuss significant technical and performance issues, regulatory approach, and inspection and licensing resources and priorities.
Panel/Lipa Bi-monthly/
As Required 03/09/04 to 04/21/05 Reference ADAMS Package ml040920411 for issued minutes from March 9, 2004, and forward.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 8 of 28 B.7.2.3 Issue Charter Revisions as Appropriate Panel/Lipa As Required 01/14/05 Charter Revision 8 (Replaced Grobe with Reynolds) issued on 01/14/05 (ml050180425).
B.7.3 ALLEGATIONS AND INVESTIGATIONS B.7.3.1 Maintain an overview of open allegations, including DOJ activities, pertaining to Davis-Besse.
Panel Ongoing 05/19/05 See Updates Below - Function transferred to DRP Branch 4 during transition from Panel to ROP.
B.7.3.1.a DOJ Activities NRR Ongoing 02/23/04 04/29/04 05/18/04 06/30/04 09/07/04 09/28/04 12/01/04 02/07/05 03/23/05 02/23/04 04/29/04 05/18/04 07/12/04 09/07/04 09/28/04 12/01/04 02/07/05 03/23/05 Updates will be provided on a bi-monthly basis.
2/23/04; no safety significant issues identified.
4/29/04; no safety significant issues identified.
5/18/04; no safety significant issues identified.
7/12/04; no safety significant issues identified.
9/07/04; no safety significant issues identified.
9/28/04; no safety significant issues identified.
12/01/04; no safety significant issues identified.
02/07/05; no safety significant issues identified.
03/23/05; no safety significant issues identified.
B.7.3.1.b Open Allegations RIII/Passehl/
Lipa Ongoing 05/19/05 Ongoing, per Allegation process MD 8.8. Function transferred to DRP Branch 4 during transition from Panel to ROP.
B.7.4 INTERNAL COMMUNICATIONS
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 9 of 28 B.7.4.1 Support Senior Manager Site Visits RIII/NRR As Required 04/08/04 05/13/04 06/16/04 07/13/04 07/19/04 07/19/04 09/08/04 09/08/04 09/17/04 09/28/04 10/07/04 11/16/04 12/07/04 12/15/04 12/16/04 01/25/05 02/22/05 04/06/05 05/24/05 04/08/04 05/13/04 06/16/04 07/13/04 07/19/04 07/19/04 09/08/04 09/08/04 09/17/04 09/28/04 10/07/04 11/16/04 12/07/04 12/15/04 12/16/04 01/25/05 02/22/05 04/06/05 05/24/05 See List of Senior Manager Site Visits Below.
Jack Grobe and Bill Ruland Site Visit Jack Grobe Site Visit DEDO Ellis Merschoff Site Visit Jack Grobe Site Visit Commissioner Merrifield Site Visit EDO Luis Reyes Site Visit Jim Caldwell OL Presentation Jim Caldwell & Steve Reynolds Site Visit Cindy Pederson Triennial Fire Prot Insp Exit J. Grobe, S. Reynolds, and Bill Ruland Site Visit Jack Grobe Site Visit Geoff Grant and Steve Reynolds Site Visit (FENOC Fleetwide Meetings)
Steve Reynolds Site Visit Steve Reynolds Site Visit Cindy Pederson ISI Activities Inspection Steve Reynolds Site Visit Steve Reynolds Site Visit RIII EDO Coordinator Undine Shoop Site Visit Steve Reynolds Site Visit
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 10 of 28 B.7.4.2 Ensure assessments, decisions, and recommendations are communicated to appropriate NRC management in a timely manner. Periodically provide NRC management and the Commission, if requested, briefings and updates on the status of the licensees progress, briefings and updates on corrective actions, and overviews of licensee performance.
RA Weekly Updates - Lipa NRR Updates -
Ruland Ongoing as needed 05/26/04 06/28/04 02/10/05 April, +05 April -
May, +05 05/26/04 06/28/04 02/10/05 April, +05 May, +05 Brief to Regional Administrator to support FENOC visit and tour on June 1, 2004 Briefing for Reyes/Merschoff/Dyer Briefing for Commissioner Lyons and briefing for Voinovich Briefing on Davis-Besse Enforcement issued 4/21/05 Briefings to prepare for May 4, 2005 AARM meeting and May 25, 2005 commission meeting.
B.7.4.3 Conduct Commissioner/
Commissioner assistants' briefings, when requested.
Panel As Requested 03/26/04 05/17/05 03/26/04 05/17/05 RES/DET Provided TA Briefing on the Updated Davis-Besse RPV Head Evaluation Final Memo - (ml0412501120)
Panel Chairman provided TA Briefing on the transition from 0350 Oversight to ROP
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 11 of 28 B.7.5 EXTERNAL COMMUNICATIONS B.7.5.1 Issue Morning Reports and Preliminary Notification Occurrence, when Appropriate RIII MR. No.
04-0015 04-0016 04-0017 04-0018 04-0019 04-0020 04-0021 04-0022 04-0023 04-0024 04-0025 04-0026 04-0027 04-0028 04-0032 04-0033 04-0034 PNO No.04-008 03/09/04 03/10/04 03/11/04 03/12/04 03/15/04 03/16/04 03/18/04 03/19/04 03/25/04 03/26/04 03/29/04 04/05/04 04/06/04 04/08/04 06/25/04 07/02/04 07/27/04 08/04/04 ml040690300 (Restart Approval) ml040700429 (Plant Status Update) ml040710362 (Plant Status Update) ml040720268 (Plant Status Update) ml040750288 (Plant Status Update) ml040760447 (Plant Status Update) ml040780225 (Plant Status Update) ml040790227 (Plant Status Update) ml040850288 (Plant Status Update) ml040460241 (Plant Achieved Criticality) ml040890636 (Plant Synchronized to Grid) ml040960501 (Plant Attained Full Power) ml040970333 (Plant Status Update) ml040990306 (Plant Status Update) ml041770575 (Reorganization) ml041840245 (Unplanned Release) ml042090298 (Management Change) ml042170476 (Automatic Reactor Shutdown)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 12 of 28 B.7.5.2 As appropriate, conduct public meetings with the licensee to discuss performance improvements. Meetings with the public should also be considered. Include discussion of progress in completing items in the Confirmatory Order and commitments described in the licensee's integrated restart report.
Panel -
Ongoing 04/08/04 04/08/04 05/13/04 7/13/04 7/13/04 09/28/04 11/16/04 12/06/04 12/06/04 02/22/05 05/24/05 05/24/05 04/08/04 04/08/04 05/13/04 7/13/04 7/13/04 09/28/04 11/16/04 12/06/04 12/06/04 02/22/05 05/24/05 05/24/05 1:00-4:00p.m. EDT with licensee - Oak Harbor High School (OHHS) 6:00-8:00p.m. EDT public only - OHHS (Meeting Summary ml041180174) 3:00-5:00p.m. EDT with licensee and public at the Ottawa County Courthouse (Meeting Summary ml041400533) 2:00- 4:00 p.m. with County Officials at the Ottawa County Courthouse 6:30-8:30p.m. EDT with licensee and public at the OHHS (Meeting Summary ml042030152) 6:00-9:00p.m. EDT with licensee and public at the OHHS (Meeting Summary ml042820319) 6:00-8:00 p.m. Joint FENOC at Quail Hollow (Meeting Summary ml043480296) 2:00 p.m. with County Officials at the Ottawa County Courthouse 6:00-9:00 p.m. with licensee and public at licensee Admin Bldg. (Meeting Summary ml043550129) 2:00-5:00 p.m. with licensee and public at the DBAB (Meeting Summary ml050610270)
Breakfast meeting with Ottawa County Commissioners at Camp Perry 6:00 - 9:00 p.m. Meeting with licensee and the public at Camp Perry Clubhouse (Meeting Summary ml051530370)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 13 of 28 B.7.5.3 Provide appropriate briefings to external stakeholders using communication plans.
NOTE: Communication Plans are not publicly released.
Panel 04/27/04 05/07/04 08/20/04 11/04/04 06/17/04 11/04/04 02/18/05 04/19/05 05/19/05 04/27/04 05/07/04 09/16/04 11/04/04 08/23/04 11/04/04 02/18/05 04/19/05 05/12/05 RES Memo on Updated RPV Head Failure Analysis Issued - Comm Plan Comm Plan - 50.9 Enforcement Action ASP Comm Plan (ml042610337)
Transition Comm Plan (ml042960257)
Exit Strategy Memorandum (ml042380480)
Post-Restart Communication Plan, Revision 3 (ml043090587)
Combined FENOC Enforcement Communication Plan (ml050530178)
Davis-Besse Enforcement Communication Plan (ml051180459) 0350 Panel Termination Communication Plan (ml051370173)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 14 of 28 B.7.5.4 Provide appropriate briefings with State and local officials.
RIII Panel Roland 03/08/04 Quarterly Quarterly (will be a phone call 1Q2005) 03/08/04 05/24/05 04/11/05 04/21/05 05/20/05 Ohio Governors Office notified by telephone call from RA Jim Caldwell when restart approval granted.
- County Commissioners quarterly July 13, 2004 - provided brief September 28, 2004 - none requested December 6, 2004 - provided brief May 24, 2005 - met to discuss transition
- State of Ohio Utility Radiological Safety Board
- 04/12/04 - R. Lickus not available
- 06/12/04 - R. Lickus not available
- 10/12/04 - R. Lickus attended
- 01/10/05 - R. Lickus attended
- 04/11/05 - R. Lickus attended Ohio Governors Office notified by telephone call from RA Jim Caldwell when escalated enforcement action for RPV head issued.
Ohio Governors Office notified by telephone call from RA Jim Caldwell when 0350 termination letter issued to licensee.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 15 of 28 B.7.5.5 Provide Periodic Updates to Congress (monthly reports to Congress prior to restart
- semi-annual thereafter).
RIII/NRR Nov 2003 Dec 2003 Jan 2004 Feb 2004 Mar 2004 Sep 2004 Mar 2005 Ongoing 03/09/04 03/09/04 03/09/04 03/30/04 04/28/04 10/29/04 03/30/05 ml040500810 ml040500810 ml040500810 ml040700896 ml041030275 ml042890247 ml051020066 tracked by AITS R03-0101
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 16 of 28 B.7.5.6 Have ongoing dialogue with various congressional offices.
Panel/
OCA -
R. Shane 03/04/04 04/15/04 05/20/04 06/21/04 06/22/04 06/24/04 10/27/04 04/20/05 05/20/05 03/04/04 04/15/04 05/20/04 06/21/04 06/22/04 06/24/04 10/27/04 04/20/05 05/20/05 NRR Director Jim Dyer briefed Brian Mormino and Marty Hall of the Senate Environment and Public Works Committee on the status of NRC's Oversight of restart consideration of Davis-Besse.
J. Grobe and C. Lipa brief Senator Voinovichs Sub-committee on NRC Oversight.
Commissioners brief Senator Voinovichs Sub-committee on NRC Oversight, which included Davis-Besse issues.
Following Davis-Besse restart, Marty Hall and Brian Mormino want quarterly briefings on how Davis-Besse is doing.
J. Grobe briefed the staffs of Representatives Kaptur, Kucinich, and LaTourette.
J. Grobe briefed the staff of Sen. Voinovich.
Brian Mormino Senate Committee on EV&PW Davis-Besse and Safety Culture Update Jack Grobe.
RIII. R. Shane, OCA.
Chairman briefed Sen. Voinovich & Committee chairs on issuance of Davis-Besse RPV Head enforcement.
Brief Senator Voinovich and Committee chairs on termination of 0350 Panel. R. Shane, OCA and Chairman.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 17 of 28 B.7.5.7 Maintain Cognizance of Ongoing Reviews of 2.206 Petitions.
Panel/Mendiola Ongoing 05/14/04 06/25/04 Donna Skay (HQ)
On 05/14/04 the NRC received a 2.206 petition from Greenpeace, NIRS, and UCS (Lochbaum) which is related to the recent denial of a 2.206 petition on Davis-Besse.
On 06/17/04, Petition Review Board determined that no action on this petition was required, letter issued on 06/25/04 (ml041730220).
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 18 of 28 B.7.5.8 Maintain Cognizance of Ongoing Hearing Proceedings.
Panel/Hopkins 03/29/04 04/15/04 05/03/04 06/02/04 06/14/04 06/24/04 08/17/04 03/29/04 04/15/04 05/13/04 06/02/04 06/14/04 06/24/04 08/17/04 Received new hearing request from T. Lodge (ml041110943).
ASLB Initial Prehearing Order issued to licensee (ml041100539).
ASLB Extension granted on submittal of Prehearing Order responses (ml041550181).
ASLB Issued Ruling to Deny the hearing petition, since petition request is outside the scope of sustaining the March 2004 Confirmatory Order (ml041550167).
Lodge appealed decision (ml041750319).
NRC Response to the Petitioner appeal (ml041800157).
Commission affirmed ASLB Order denying the Petition (ml0423001832).
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 19 of 28 B.7.5.9 Other external communications 06/01/04 incoming 08/13/04 12/14/04 02/22/05 11/30/04 03/23/05 04/21/05 04/21/05 04/21/05 05/20/05 06/01/04 outgoing 10/21/04 12/14/04 02/22/05 11/30/04 03/23/05 04/21/05 04/21/05 04/21/05 05/20/05 FENOC visit and tour with RA Letter from Ohio Citizens Action (ml042610175)
Letter to Ohio Citizens Action (ml043010225)
FENOC Drop-in with EDO, Chairman, and Commissioner Merrifield FENOC Drop-in with RA (Perry Issues)
Ltr from OCA and UCS about RCPs inspections during the Mid-Cycle Outage (ml043420127)
RIII Responses to OCA and UCS (ml050900164 OCA, ml050970098 UCS)
Letter to A. Siemaszko regarding enforcement action (ml051090537)
Letter to FirstEnergy regarding enforcement action (ml051090552)
Press release regarding enforcement action (ml051110336)
Press release regarding 0350 termination (ml051400258)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 20 of 28 B.7.6 DOCUMENTATION B.7.6.1 Ensure a comprehensive record is developed that documents NRC decisions and actions related to IMC 0350 activities. Meeting minutes for all internal meetings will be prepared and maintained in ADAMS.
Meeting minutes will be released publically at the appropriate time per Panel decision.
Panel 06/30/05 06/30/05 Reference ADAMS Package ml051800241 for issued minutes from March 9, 2004, through the last Panel meeting on April 21, 2005. Panel minutes will be released publicly prior to time facility begins in Reactor Oversight Process, which is July 1, 2005.
B.7.6.2 Prepare IMC 0350 Lessons Learned Memo.
Panel 06/30/05 07/27/05 Memo issued to NRR (ml052080555).
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 21 of 28 B.8 TERMINATION OF THE IMC 0350 PROCESS After an acceptable post-restart period of operation of the plant, and upon determination that the criteria for termination of the IMC 0350 process controls as defined in the Panel Process Plan have been met, the Panel may recommend termination of the IMC 0350 process and a return to the Routine Oversight Process. Although it is expected that at least one or two quarters of operation is required, the Panel may recommend continuing the oversight activities, provided the Panel provides adequate justification and documentation. The criteria for termination of the IMC 0350 process should include verification that the licensee has established an effective long-range improvement program, is sufficiently implementing the corrective program, has demonstrated safe plant operation and overall improving performance, and has adequate controls in place to address the plant-specific issues that caused IMC 0350 to be implemented. The Panel should send a final letter documenting the results of its post-restart review and oversight efforts to the Regional Administrator. The letter should give the basis for the Panels recommendation to terminate its oversight activities and return the plant to Routine Oversight Process oversight. The letter should address the resolution for each of the plant-specific criteria for termination of the IMC 0350 process as defined in the Panel Process Plan. On the basis of the recommendations of the Panel, the Regional Administrator, in consultation with the Director of NRR and the Deputy Executive Director for Reactor Programs, will decide whether a return to the Routine Oversight Process is warranted. Once the decision is made to terminate the IMC 0350 process, a letter should be sent to the licensee informing it of the staffs position, including pertinent information such as the Panels summary assessment of the resolution of the Restart Checklist issues, the basis for the decision to return the plant to the Routine Oversight Process, and the expected termination date."
B.8.1 Develop exit criteria for returning Davis-Besse to the routine Reactor Oversight Process using the guidance in IMC 0350.
Panel-Lipa/Mendiola 06/17/04 08/23/04 Exit Strategy Memorandum (ml042380480)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 22 of 28 B8.1.1 Develop exit criteria/approach to ensure above criteria have been met.
Phillips/Hopkins and Thomas 03/01/05 03/01/05 Criteria for exiting 0350 are spelled out in Sections B8.1.1.1 thru B8.1.1.5.
B8.1.1.1 Determine that licensee has established and is implementing an effective long-range improvement program.
- Jacobson, Wright, and 0350 Panel 04/20/05 04/21/05 Independent assessments performed per March 8, 2004, Confirmatory Order (EA-03-214) identified no findings of significant weaknesses; NRC inspections of engineering, corrective action program, and operations independent assessments and licensee action plans confirmed no significant weaknesses; maintenance backlog has been reduced and remains a focus of licensee initiatives; and control room deficiencies and operator work-arounds were worked off during mid-cycle outage.
Reviewed the Independent Safety Culture Assessment with onsite inspection the week of 4/11/05; and reviewed some areas of decline in the licensees October 2004 SCWE survey results.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 23 of 28 B8.1.1.2 Determine that licensee has demonstrated safe plant operation and overall improving performance.
Thomas/
Passehl/Wright/
Jacobson 02/11/05 02/11/05 Operations independent assessment found no significant weaknesses; NRC inspection of Operations has found overall performance to be satisfactory; minor Operations personnel errors have been reduced in number and frequency and have not created significant safety issues and are taken seriously by plant staff, e.g., condition reports written to document and initiate corrective actions; no significant cross-cutting issue exist; NRC performance indicators have been determined to now be a valid representation of plant performance, as documented in IR 04-16 and all are Green, except for White in ANS. Except for a White performance deficiency associated with ANS sirens, there have been no findings greater than Green since plant restart in March 2004. Licensee has developed a performance monitoring program with a process to address declining or poor performance.
Inspection Report 04-16 discusses operations performance. This item has been determined to have been adequately addressed by the licensee.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 24 of 28 B8.1.1.3 Determine that licensee continues to comply with Confirmatory Order and has established an effective self-assessment program.
Thomas/Wright Jacobson/
Rutkowski 05/15/05 04/21/05 Licensee has completed the four CY2004 independent assessments required by Order and is planning the CY2005 independent assessments, and has completed the mid-cycle inspections required by Order. NRC has inspected the Engineering assessment (IR 04-14 and 04-15), the Operations assessment (IR 04-08, 04-15, and 04-16) the corrective action program assessment (IR 04-17)
Independent assessment and NRC inspection has found licensees self-assessment program to be effective. The Safety Culture assessment was received, and reviewed in detail with on-site inspection the week of 4/11/05. The NRC inspection reviewed the results of the Assessment and the adequacy of the Action Plans to address issues. Results were documented in IR 05-06.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 25 of 28 B8.1.1.4 Confirm that licensee has found no reactor coolant pressure boundary leakage during mid-cycle outage.
Licensee letter submitted 2/3/05 (ml050350194)
Holmberg 02/12/05 03/23/05 Licensee inspections required by the March 8, 2004, Confirmatory Order (lower vessel head, upper vessel head, reactor coolant system boric acid inspection) were completed and no pressure boundary leakage was found; Licensee performed inspection for NRC Bulletin 2004-01, pressurizer penetrations, and no pressure boundary leakage was found; Licensee performed steam generator tube inspections.
Inspection sample was expanded appropriately based on indications that were found; actions were taken to evaluate and either repair or plug tubes, as appropriate. NRC inspected licensees activities.
Inspection completed with results documented in IR 05-003 issued 03/23/05. No reactor coolant pressure boundary leakage was detected.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 26 of 28 B8.1.1.5 Determine that the licensee has adequate controls in place to prevent the issues that led to the significant degradation in the reactor vessel head.
Thomas/Wright Jacobson/
Rutkowski 05/15/05 04/21/05 Independent assessment found corrective action program adequate and PI&R inspection found corrective action program adequate (IR 04-17). No greater that Green findings or performance indicators have occurred as the result of a corrective action failure.
Safety culture independent assessment identified that the safety culture responses in some departments had worsened, while other departments remained the same. On-site inspection the week of 4/11/05 determined that organizational behaviors were addressed and appear to have had some positive effects on the organization as a result of the mid-cycle outage where emergent issues were conservatively addressed.
B8.1.1.6 Solicit limited NRC staff to determine if there are any objections to returning Davis-Besse to the ROP process.
0350 Panel 04/22/05 05/10/05 NRR/Research: bottom head - J. Hopkins RIII: inspectors - A. Stone Memo dated 5/10/05 documents results (ml051330274
- non-public)
B.8.2 Issue Panel Extension memo to document basis for keeping plant in 0350 process beyond three quarters after restart.
0350 Panel/
Lipa 08/23/04 03/30/05 08/23/04 10/07/04 10/21/04 03/30/05 Panel Extension Memo > Three Quarters (ml042380423); (ml042960575)
Approved by J. E. Dyer Approved by Jim Caldwell Continuation Memo issued and approved thru May 31, 2005 (ml050890430)
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 27 of 28 B.8.2.1 Provide a written recommendation to the Regional Administrator and the Director of NRR to return the plant to the Routine Oversight Process.
Panel-05/03/05 05/09/05 Memo issued (ml051360379)
B.8.3 Consult with Director of Office of Nuclear Reactor Regulation and Deputy Executive Director for Reactor and Preparedness Program and approve return to the Routine Oversight Process and terminate the IMC 0350 oversight process.
Regional Administrator 05/13/05 05/13/05 Consultation completed with J. Dyer, Director NRR, and W. Kane, DEDO, via telecon by RA on 5/13/05.
Approval documented in letter to licensee, which is Item B.8.4 below.
B8.3.1 Determine what deviations are needed to ROP Action Matrix to place back in 0305 program, and into which column.
0350 Panel 05/03/05 issued 05/12/05; approved 05/18/05 Deviation memo issued and approved (ml051390321) requesting additional PIR in CY2005 and extra insp hours for f/u on Confirmatory Order.
B8.3.2 Determine additional inspection needs to ensure compliance with the Confirmatory Order over the next four years.
0350 Panel 05/09/05 05/12/05 As authorized by the deviation memo that was approved on 5/18/05, a detailed inspection schedule was attached to the letter to the licensee (B.8.4). The Panel determined that additional inspection needs would be determined each year at the End-of-Cycle review.
Davis-Besse IMC 0350 Last Updated - June 22, 2005 Panel Process Plan Task Description Responsibility Planned Comp Date Actual Comp Date Comments Page 28 of 28 B8.3.3 Hold meeting with the licensee and the public to announce decision, bases and additional NRC activities beyond Baseline.
0350 Panel 05/24/05 05/24/05 Meeting held between 6:00 and 9:00 p.m. at Camp Perry Clubhouse. (Meeting Summary - ml051530370)
B.8.4 Provide a written letter notifying the licensee that the plant has returned to the Routine Oversight Process, including into which column the plant is placed, deviations to be implemented from the Action Matrix, and revisions to the baseline inspection program to address compliance with the Confirmatory Order.
Regional Administrator 05/13/05 05/19/05 The letter to the licensee (ml051400049) was issued on May 19, 2005, notifying the licensee of transition to Column II of the ROP, effective July 1, 2005.