ML101060482

Status of Davis-Besse Lessons Learned Task Force Recommendations (Final Update): December 2009

ML101060482
Person / Time
Site:	Davis Besse
Issue date:	04/16/2010
From:	Division of Policy and Rulemaking
To:
Beaulieu, D P, NRR/DPR, 415-3243
References
Download: ML101060482 (33)

Text

1 Status of Davis-Besse Lessons Learned Task Force Recommendations (FINAL UPDATE)

December 2009Category: Stress Corrosion Cracking LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.3.1.1(1)Assemble foreign and domestic information concerning Alloy 600 (and other nickel based alloys)

nozzle cracking and boric acid corrosion. Analyze

nickel based alloy nozzle susceptibility to stress

corrosion cracking (SCC), including other susceptible

components, and boric acid corrosion of carbon steel, and propose a course of action and an implementation

schedule to address the results. HighSCCCompleteNot RequiredRES (DET) for data collection NRR (DE) for other actions STATUS: Data collection was accomplished in two phases. Colle ction of information on cracking was completed 03/31/04 (, ML040910354). A test program on boric acid corrosion was completed on 10/22/04 and was published in NUREG/CR-6875, "Boric Acid Corrosion of Lig ht Water Reactor Pressure Vessel Material" (ML050410026). The information contained in these two reports and a third report on Alloy 60 0 crackingsusceptibility (ML032461221), which was issued on 3/31/04 to address LLTF 3.1.4(1), have been compiled in NUREG-1823, "U.S. Pla nt Experience with Alloy 600 Cracking and Boric Acid Corrosion of Light-Water Reactor Pressure Vessel Materials" (ML050390139).

Based on the reports, the staff concluded that additional inspec tions are warranted for identifying leakage from primary water stress corrosion cracking (PWSCC) and for precluding boric acid corrosion as a resu lt of such through-wall leakage. The RES reports provide a c omprehensive set of information that supports and confirms the appropriatene ss of these conclusions and does not change the staff's basic pe rception of the problem. The staff concluded that definitive actions are needed to address shortcomings with the current framework for these i nspections and proposed a plan and schedule for accomplishing them. This complet ed the LLTF recommendation. Actions to implement the plan ar e being tracked through an NRR action plan that addresses stress corrosion cracking and boric acid corrosion issues.

3.2.2(1)Inspect the adequacy of PWR [pressurized-water reactor] plant boric acid corrosion control programs, including their implementation effectiveness, to

determine their acceptability for the identification of

boric acid leakage, and their acceptability to ensure

that adequate evaluations are performed for identified

boric acid leaks.HighSCCCompleteCompleteNRR (IIPB)

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.2 STATUS: The evaluation of responses to Bulletin 2002-01, which included audits of boric acid corrosion control (BACC) programs at five plants, determined that plants appeared to be complying with requirements at the programmatic level. The results of the evaluation wer e summarized in Regulatory Issues Summary (RIS) 2003-13 (ML032100653). The RIS c oncluded that existing monitoring programs may need to be enha nced to ensure early detection and prevention of leakage from the RCPB and provided suggestions for improving existing programs.

Subsequent inspections conducted at all operating reactor plant s have reviewed licensee BACC programs using new inspection guid elines. Temporary Instruction (TI) 2515/150, issued on October 18, 2002, which provides guidance for inspecting licensees' reactor pres sure vessel (RPV) head inspections pursuant to Order EA-03-009, also includes instructions for follow-up on findings of boric acid accumula tion. Inspection Procedure (IP) 71111.08, "Inservice Inspection Activi ties," was revised on 5/11/04 to add periodic inspection requir ements and guidance for BACC. Staff review of inspection results from TI 2515/150 and IP 71111.08 and feedback from Region inspectors ind icate thatlicensees' current programs are generally adequate for locating and evaluating and/or correcting boric acid leaks and the NRC i nspection guidance is adequate and effective for oversight of BACC programs.

All inspection findings have been categorized as very low s afety significance. The effectiveness of IP71111.08 will continue to be evaluated as part of annual ROP self-assessment and appropri ate improvements will be made as needed.

3.3.2(1)Develop inspection guidance for the periodic inspection of PWR plant boric acid corrosion control

programs.HighSCCCompleteNot requiredNRR (IIPB)

STATUS: Temporary Instruction (TI) 2515/150, issued in 08/

03, supports the review of licensees' RPV head and vessel head penet ration nozzle inspection activities that are implemented in accordance with t he requirements of NRC Order EA-03-009. This TI validates that a plant conforms to its inspection commitments and requirements, during refue ling outages, using procedures, equipment, and personnel that have been demonstrated to be effective in the detection and sizing of PWS CC in VHP nozzles and detection of RPV head wastage. TI 2515/15 2, issued in 11/03, provides interim inspection guidance for follow-up to Bulle tin 2003-02, which includes BACC programs. In addition, IP 7 1111.08,"Inservice Inspection Activities", was revised in 05/04 to add NRC inspection samples to observe and evaluate licensee inspecti on of PWR RPV head and VHP nozzle inspection activities on a periodic basis cons istent with the guidance in TI 2515/150. This revision also included guidance and requirements to perform a performance based inspection of licensee's boric acid program implementation.

The effectiveness of these inspection procedures will be evaluated as part of LLTF 3.2.2(1) and a separate effectiveness review is not required.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.3 3.3.4(3)Develop inspection guidance or revise existing guidance to ensure that VHP [vessel head

penetration] nozzles and the RPV head area are

periodically reviewed by the NRC during licensee

ISI [inservice inspection] activities. HighSCCCompleteNot requiredNRR (IIPB)

STATUS: TI2515/150, issued 08/03, provides interi m inspection guidance for follow-up to Order EA-03-009.

IP 71111.08, "Inservice Inspection Activities," was revised on 5/11/04 to add periodic inspection requirements and guidance for PWR vessel head penetration inspections. The effectiveness of these inspec tion procedures will be evaluated as part of LLTF 3.2.2(1) and a separate effectiveness review is not required.

3.3.4(8)Encourage ASME [American Society of Mechanical Engineers] Code requirement changes for bare metal

inspections of nickel based alloy nozzles for which the

code does not require the removal of insulation for

inspections. Also, encourage ASME Code

requirement changes for the conduct of non-visual

NDE [nondestructive examination] inspections of VHP

nozzles.Alternatively, revise 10 CFR 50.55a to address these areas. HighSCCCompleteNot requiredNRR (DCI)STATUS: On February 11, 2003, the Nuclear Regulatory Commission (NRC) issued Order EA-03-009, "Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors."

This order modified licensees' licenses to require specific insp ections of the reactor pressure vessel (RPV) upper head and associated penetration nozzles at pressurized water reactors. In response to inte rnal review and stakeholder input, the NRC issued First Revised Order EA-03-009 (Order), on February 20, 2004, which refined the inspection req uirements ofNRC Order EA-03-009 by taking into account lessons learned from inspections performed from February 2003 to January 2004.

The staff reviewed the results of reactor pressure vessel (R PV) head inspections through Temporary Instruction 2515-150, "React or Pressure Vessel Head and Vessel Head Penetration Nozzles," October 18, 2002, (ADAMS Accession Number ML022940597), and through review of requests for relaxation from the requirements of Order EA 009 and First Revised Order EA-03-009. Permanent inspection guide lines were established through the issuance of ASME Code Case N 729-1, "Alter native Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Weld sSection XI," which was incorporated into Title 10 of the Code of Federal LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.4 Regulations (10 CFR) Paragraph 50.55a. The technical basis was provided in the Federal Register notice for the proposed rule to incorpora te ASME Code Case N-729-1 into 10 CFR 50.55a (Volume 72, Number 65, pages 16731 - 16741, April 5, 2007). Use of Code Case N-729-1 , with staff conditions, became mandatory on December 31, 2008. Code Ca se N-729-1 addresses inspection requirements for nozzle integrity as well as for potential boric acid corrosion of the reactor pressure vessel upper head.

Separately, the ASME Board on Nuclear Codes and Standards approved Code Case N-722, which recommends bare metal visual examinat ionof all ASME Code Class 1 alloy 600/82/182 components at frequencies that depend on the temperature of the location. The NRC st aff reviewed the adequacy of the requirements of Code Case N-722, along with Code Case N-729-1, and determined them to be acceptable to addr ess potential boric acid corrosion. The technical basis was provided in the Federal Register notice for the proposed rule to incor porate ASME Code Cases N-722 and N 729-1 into 10 CFR 50.55a (Volume 72, Number 65, pages 16731 - 16741, April 5, 2007). The staff implemented r egulations to address potential boric acid corrosion by incorporating ASM E Code Case N-729-1 and N-722, with limitations, into 10 CFR 50.5 5a(g)(6)(ii)(D) and 10 CFR 50.55a(g)(6)(ii)(E), respectively. The requirements of 10 CFR 50.55a(g)(6)(ii)(E) became mandatory on October 10, 2 008. 3.1.4(1)Determine if it is appropriate to continue using the existing SCC models as a predictor of VHP nozzle

PWSCC [primary water SCC] susceptibility given the

apparent large uncertainties associated with the

models. Determine whether additional analysis and

testing are needed to reduce uncertainties in these

models relative to their continued application in

regulatory decision making.MediumSCCCompleteNot requiredRES (DET)

STATUS: In its current form, the model is based on time and temperature effects alone and is adequate for prioritizing reactor VHP inspections.

It has been used in the development of inspection requirements in Order EA-03-009 and the bulletins that preceded it. Inspecti on results to date have been consistent with model predictions and do not indicate a need for revising the model in the near term. A report by th e Office of Nuclear Regulatory Research, issued 7/21/03 (ML032461224 and ML032461221), identifi ed refinements that could be made to the model. The seimprovements are not needed to satisfy this recommendation and will require research activities that are beyond the scope of th e LLTF recommendation. The report will be issued in a NUREG together with the reports required for LLTF 3.1.1(1).

3.3.7(6)Determine whether ISI summary reports should be submitted to the NRC, and revise the ASME

submission requirement and staff guidance regarding

disposition of the reports, as appropriate. LowSCCCompleteNot RequiredNRR (DE/DLPM)

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.5 STATUS: The staff has reviewed the uses of the ISI reports and concludes that it is appropriate to continue to have the report s submitted to the NRC, so that there is no need to revise the ASME requirements.

In particular, the Regions use the ISI reports for inspection p lanning and to follow up on issues associated with inspection procedure IP 71111.08, "Inservice Inspection Activities." In addition, the Offi ce of Nuclear Regulatory Research reviews the ISI reports to trend aging effe cts and material degradation, in order to develop recommendation s for codes and standards activities.

The staff has determined, however, that the NRR practice of reviewing the ISI reports is unnecessary. In the future, the NRR s taff will not review the ISI reports; rather, since the reports should still be submi tted for other reasons, the reports will be available when it i s determined that the NRR staff should use them as references in support of the operat ing experience program. No effectiveness review is required.

6Category: Operating Experience LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.3.1.6(1)Take the following steps to address the effectiveness of programs involving the review of operating experience: (1) evaluate the agency's capability to

retain operating experience information and to perform

longer-term operating experience reviews; (2)

evaluate thresholds, criteria, and guidance for

initiating generic communications; (3) evaluate

opportunities for additional effectiveness and

efficiency gains stemming from changes in

organizational alignments (e.g., a centralized NRC operational experience "clearing house");

(4) evaluate the effectiveness of the Generic Issues

Program; and (5) evaluate the effectiveness of the

internal dissemination of operating experience to end

users.HighOpECompleteCompleteNRR(IROB) and RES STATUS: This action required the evaluation of various aspects of the agency's operating experience program. This action item became the foundation of the charter for to Operating Experience Task Fo rce (OETF) [ML031200535]. The OETF documented its evaluation of i tems (1)through (5) of the recommendation in its report dated 11/26/03 (ML033350063). The OETF made 23 recommendations for improving t he effectiveness of the agency's operating experience program that are currently being implemented in accordance with the Operatin g Experience Action Plan dated 4/29/04 (ML041180024).

3.1.6(2)Update NRC operating experience guidance documents.HighOpECompleteCompleteNRR (IROB) and RES STATUS: This LLTF recommendation is directed at the fact that Management Directive (MD) 8.5, "Analysis and Evaluation of Opera tional Data" had not been updated since the dissolution of the Analysis and Eval uation of Operational Data organization and the transfer of Operating Experience Program responsibilities to NRR and RES. However, NRR Office Instruction, LIC-401, "NRR Operating Experience Progra m," was issued in March 2003 to reflect the current practices of NRR's O perating Experience Section located in the Division of Inspecti on Program Management.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.7 As part of the Operating Experience Action Plan (ML041180024), whic h implemented the recommendations of the Operating Experienc e Task Force (ML033350063), the staff developed MD 8.7, "Reactor O perating Experience Program" (ML043570013, ML043570032) and Revision 1 to NRR Office Instruction, LIC-401 (ML043570075) as the framework for a new operating experience program.

On December 22, 2004, the Office Directors of NRR and RES authorized the staff to begin implementation of MD 8.7, in its draft form for oneyear prior to its final issuance. Also, the Director of NRR authorized implementation of NRR Office Instruction, LIC-401, Rev.

1, in draft form pending completion of final editing and administrative processing.

3.1.6(3)Enhance the effectiveness of NRC processes for the collection, review, assessment, storage, retrieval, and

dissemination of foreign operating experience.HighOpECompleteCompleteNRR (IROB) and RES STATUS: At the time of this recommendation, foreign operating experience, such as that received through the IAEA Incident Repo rting System(IRS), was only communicated and distributed in an ad hoc fashion. Today, it is a formal element of the NRC Operating Experien ce Section screening process and available on the internal web site.

NRR Office Instruction LIC-401, "NRR Operating Experience Program," was issued on 3/31/03. This office instruction incorporate s action to enhance the effectiveness and utilization of foreign operating experi ence within the Operating Experience Section. This proces s will be further enhanced upon implementation of the Operating Experience Acti on Plan (ML041180024). An overall effectiveness review will be pe rformed approximately one year following implementation of the action plan.

3.2.4(1)Assess the scope and adequacy of requirements governing licensee review of operating experience.HighOpECompleteCompleteNRR (IROB)

STATUS: This assessment was performed as part of the Operating Experience Task Force Report (ML033350063), which was issued November 26, 2003. Section 5 of this report concludes that the scope and adequacy of the requirements related to the licensee review of operating experience are currently acceptable. Inspection Pr ocedure 71152, "Identification and Resolution of Problems," is the key baseline procedure for evaluating licensee utilization of operating experienc e, and the Operating Task Force found that recent changes t o that procedure (Change Notice 03-032) enhanced NRC baseline inspection efforts.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.8 3.3.1(1)Provide training and reinforce expectations to NRC managers and staff members to address the following

areas: (1) maintaining a questioning attitude in the

conduct of inspection activities; (2) developing

inspection insights stemming from the DBNPS [Davis-

Besse Nuclear Power Station] event relative to

symptoms and indications of RCS [Reactor Coolant

System] leakage; (3) communicating expectations

regarding the inspection follow-up of the types of

problems that occurred at DBNPS; and

(4) maintaining an awareness of surroundings while

conducting inspections. Training requirements should

be evaluated to include the appropriate mix of formal

training and on-the-job training commensurate with

experience. Mechanisms should be established to

perpetuate these training requirements. HighOpECompleteCompleteNRR (IIPB)

STATUS: The focus of this recommendation is on regional sta ff. The Inspection Program Branch developed a web-based training c ourse based on the Columbia Space Shuttle Accident to (1) illustrate the importance of maintaining a questioning attitude toward safety and the potential negative consequences that can occur when such a questioning attitude is lost or compromised; (2) provide examples of how issue s concerning an organization's safety culture can lead to technological failures; (3) provide insights into investigation techniques that ca n be used to assesssafety significant issues or events; and (4) illustrate the im portance of a robust corrective action program and highlight the corrective action program weaknesses that contributed to the shuttle accident.

The Regions provided documentation that all managers and inspectors required to complete the training on the Columbia Accident had completed the training. In addition, IMC 1245, "Qualification Pr ogram for the Office of Nuclear Reactor Regulation Programs,"

was revised to include this web-based training program as an indi vidual study activity for future inspectors.

The IMC 1245 Management Steering Group and IMC 1245 Working Group annually review the effectiveness of inspector training throu gh feedback forms submitted, results of the inspector oral boards , and regional experience. Improvements and revisions are recomm ended and implemented as appropriate. In addition, the Regions encour age a questioning attitude during semiannual inspector counterpart meetings, in newsletters discussing value-added findings, and during periodic reactor oversight proce ss refresher training. The training as sociated with thisrecommendation was effectively implemented in 2003 and will be continually reviewed as part of the inspector training program r eviews and regional management attention.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.9 3.3.4(2)Strengthen inspection guidance pertaining to the periodic review of operating experience. HighOpECompleteCompleteNRR(IROB and IIPB)STATUS: The inspection guidance pertaining to the periodic review of operating experience has been strengthened through the re vision of Problem Identification and Resolution Inspection Procedure 71152 on 9/

8/03. This revision specifically requires the review, on a sampling basis, of the issues identified through the past NRC generic communicati ons. A fundamental goal of the NRC's reactor oversight proces s is to establish confidence that each licensee is detecting and correcting problems. This inspection procedure's purpose is to supple ment the other baseline inspection procedures and the performance indicators to provide assurance that licensees adequately identify and corre ct problems.

Issues identified through operating experience are an integral part of that assessment.

The effectiveness of the changes to IP 71152 was reviewed by ve rifying that: (1) the planned procedure revisions were issued an d distributed to inspectors, (2) the latest version of the inspection procedur e was being used, (3) the inspection guidance pertaining to the pe riodic review of operating experience was strengthened, and (4) there were no uni ntended consequences. The staff reviewed 30 inspection reports that documented the results of completing IP 71152 inspections (fi fteen reports each from 2004 and 2005 with a mix from each of the four regions).

The review determined that the four criteria were met. In addition, a pilot inspection program conducted in 2005 resulted in e nhancements to the procedures for inspecting licensee use of operating experience in the design and engineering areas. The staff concluded that t he changes were effectively implemented and the inspection guidance pertaining to the periodic review of operating experience has been strength ened. IP 71152 will continue to be evaluated on an ongoing basis as part of the annual ROP self-assessment process.

3.3.5(1)Maintain expertise in the subject areas by ensuring that NRC inspector training includes: (1) boric acid

corrosion effects and control; and (2) PWSCC of

nickel based alloy nozzles. HighOpECompleteCompleteNRR (IIPB)

STATUS: Training modules on these topics have been included in the web-based training described under 3.3.1(1). The training focuses on the current NRC understanding and approach to monitoring boric acid corrosion and shows photographs of the Davis-Besse head and a c utaway drawing of the degradation.

A training module on the "Effects of Corrosion," which includes bot h PWSCC and BACC, was completed by all current inspectors.

Also, Inspection Manual Chapter (IMC) 1245, "Qualification Program fo r the Office Of Nuclear Reactor Regulation Programs," Appendix B , "General Proficiency-Level Training and Qualificat ion Journal" (ML041820014), was revised to incl ude an individual study activity requir ing all qualifying inspectors to review the technical subject web-based training, which includes the training on PWSCC and BACC, as well as future web-based training items.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.10 This action was effectively implemented in 2004 and the Regions documented that all appropriate managers and inspectors complet ed the training. In the long term, the training was added to the IMC 1245 requirements. In addition, during 2005, the Inspection Pro gram Branch will work with the Materials Engineering Branch of the Division of E ngineering Technology in the Office of Nuclear Regulatory Resear ch to update the training material. The training associated with this recommendation will be continually reviewed as part of the inspector training program reviews and regional management attention.

3.1.2(1)Revise NRC processes to require short-term and long-term follow-on verification of licensee actions to

address significant generic communications (i.e.,

bulletins and GLs).MediumOpECompleteCompleteNRR (IROB)

STATUS: NRR Office Instruction LIC-503, "Generic Communications Affecting Nuclear Reactor Licensees," was revised on 7/23/04.

This revision incorporates actions to address the requirement fo r short-term and long-term follow-on verification of licensee action s to address significant generic communications. As part of the development of a bulletin or generic letter, LIC-503 requires the staff to determine whatactions will be necessary for closure of the issue.

3.1.2(2)Establish review guidance for accepting owners group and industry resolutions for generic communications

and generic issues. Guidance should include

provisions for verifying implementation of activities by

individual owners groups and licensees.MediumOpEComplete CompleteNRR (DLPM, DE, DSSA)STATUS: NRR Office Instruction LIC-503, "Generic Communications Affecting Nuclear Reactor Licensees," was revised in July 2004 to include guidance regarding review of owners group and industry resolution to generic communications. Guidance for acceptance review wa s added to the sections addressing origin and closeout of generic communicati ons. The revision requires the staff to establish review gui dance for accepting owners group and industry proposals during the preparation of a generic communication and to establish criteria for a ccepting ownersgroup and industry resolutions during closeout. NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licen sees to the NRC," was revised in August 2004 to include guidance on accepting regulatory commitments made by third parties such as owners g roups.

With regard to verification, LIC-503 requires an assessment of the method to be used for verifying licensee responses during th e development of a generic communication. One method is by use of a temporary instruction (TI) and guidance for the preparation of a TI is prov ided. An alternative to a TI is verification of licensee responses thr ough DLPM Project Managers' audits of regulatory commitments, cond ucted in accordance with LIC-105. LIC-105 provides detailed guidance fo r conducting the audits. LIC-105 also directs lead PMs for gene ric communications to provide guidance for verification of owners group or industry commitments in conducting periodic audits, if t hey were accepted in response to the generic communication, and directs PM s to review generic communication guidance in the selection of the audit LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.11 sample. The "Commitment Management Program," section of the DLPM Handbook provides an overview of DLPM management expectations and NRR staff guidance for handling regulatory commitments made by licensees for commercial nuclear reactors, and provides a link to LI C-105.The target date for the effectiveness review was extended to allow a full year of experience with the new procedures before sta rting the review.

3.1.2(5)Conduct follow-on verification of licensee actions associated with a sample of other significant generic

communications, with emphasis on those involving

generic communication actions that are primarily

programmatic in nature.MediumOpECompleteNot RequiredNRR (IROB, IIPB)STATUS: A task force performed a screening process of candidate generic communications in 07/03 using criteria approved by man agement. Selection of generic communications and focus areas was comple ted in 11/03 following management review and input on priorities.

Verificationplan was presented to NRR LT in 12/03 and revised to address comments. Five focus areas were initially identified. All but on e (Service Water) were being addressed by other initiatives. Through TI 2515/159 (i ssued 7/29/04) a sample review of three plants in each region was conducted to verify licensee actions in response to GL 89-13, "Service Wa ter Problems Affecting Safety-Related Equipment." In addition, a follow-up toRIS 2004-05, "Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power," was conducted through TI 251 5/156 to determine if the RIS accomplished its purpose of raising industr y awareness of the potential impacts of grid operation on nucle ar power plants.

The staff concluded that GL 89-13 was generally effective in addr essing issues associated with service water systems, although some isolated deficiencies exist and licensees continue to address operational iss ues. The staff believes that the effectiveness of this GL was enhanced by the comprehensive follow-on NRC inspections after the issuance of the GL and by the ongoing inspection program oversight. Additionally, TI2515/159 was an effective method for assessing GL 89-13 effectiveness.

The staff concluded that RIS 2004-05 was effective in informing licensees of NRC expectations in the area of offsite power in a timely manner.

Additionally, TI 2515/156 was an effective method of collecting additional operational data.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.12 3.1.3(2)Conduct follow-on verification of licensee actions pertaining to a sample of resolved GIs.MediumOpECompleteNot RequiredNRR (DLPM, IIPB)STATUS: The staff obtained a list of all resolved GIs, which i ndicated that 20 GIs have been resolved since 1983. All but thr ee of these were resolved by issuance of generic communications (GCs). One rema ining issue was resolved by plant-specific backfits, and two wer e closed without further action. Thus, a follow-on verification of re solved GIs would essentially require a verification of GCs.

However, a follow-on verification of GCs was conducted separately in response to LLTF Item 3.1.2(5), which selected GCs for review by a screening process of all GCs that considered safety significanc e, risk significance, functional area and other factors, and inc luded input from theNRR, RES and Region Offices in establishing priority for follow-up. Only two of the 19 GCs used to resolve GIs matched those i n the final priority list determined for LLTF Item 3.1.2(5), and one of these is the subject of one of the TIs being used to close out LLTF 3.1.2(5). It was concluded that the response to LLTF 3.1.3(2) would be effectivel y implemented by the completion of LLTF 3.1.2(5) and a separate sampling activity was unnecessary.

3.2.3(1)Review a sample of NRC safety evaluations ofowners' group submissions to identify whether

intended actions that supported the bases of the NRC's conclusions were effectively implemented.MediumOpECompleteNot RequiredNRR (DLPM, IIPB)STATUS: The basis for this recommendation was a 1993 request from the NRC to pressurized-water reactor owners groups to provid e a safety evaluation (SE) documenting why no unreviewed safety question exis ted for Alloy 600 nozzle cracking. The Babcock & Wilcox (B&W) Owners Group provided a report that included a statement that B&W plant s had developed plans to visually inspect control rod drive noz zles for boric acid deposits. The applicable commitment was not effectively incorporated at Davis-Besse.

In general, the NRC staff does not accept owners' group commi tments on behalf of licensees, and it appears that the particular example cited as the basis for Davis-Besse LLTF recommendation 3.2.3(1) was unique.

The DLPM lead project managers for each of the owners' grou ps, through individual research and discussion with their respective vendors, were unable to identify any other NRC SEs of owners g roup submissions related to a generic issue that required an action to be implemented by industry. The NRR technical staff also sta ted that they did not know of any documentation of this nature.Therefore, after a thorough search by the owners group lead pr oject managers, vendors, and NRR technical staff, it was conclude d that other SEs similar to the one described in the recommendation are not available, and LLTF 3.2.3(1) was closed.

3.2.3(2)Develop general inspection guidance for the periodicMediumOpECompleteCompleteNRR LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.13 verification of the implementation of owners groups' commitments made on behalf of their members.(DLPM, IIPB)STATUS: NRR Office Instruction LIC-503, "Generic Communications Affecting Nuclear Reactor Licensees," was revised in July 2004 to include guidance regarding review of owners group and industry resolution to generic communications. Guidance for acceptance review wa s added to the sections addressing origin and closeout of generic communicati ons. The revision requires the staff to establish review gui dance for accepting owners group and industry proposals during the preparation of a generic communication and to establish criteria for a ccepting ownersgroup and industry resolutions during closeout. NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licen sees to the NRC," was revised in August 2004 to include guidance on accepting regulatory commitments made by third parties such as owners g roups.

With regard to verification, LIC-503 requires an assessment of the method to be used for verifying licensee responses during th e development of a generic communication. One method is by use of a temporary instruction (TI) and guidance for the preparation of a TI is prov ided. An alternative to a TI is verification of licensee responses thr ough DLPM Project Managers' audits of regulatory commitments, cond ucted in accordance with LIC-105. LIC-105 provides detailed guidance fo r conducting the audits. LIC-105 also directs lead PMs for gene ric communications to provide guidance for verification of owners group or industry commitments in conducting periodic audits, if t hey were accepted in response to the generic communication, and directs PM s to review generic communication guidance in the selection of the audit sample. The "Commitment Management Program," section of the DLPM Handbook provides an overview of DLPM management expectations and NRR staff guidance for handling regulatory commitments made by licensees for commercial nuclear reactors, and provides a link to LI C-105.The target date for the effectiveness review was extended to allow a full year of experience with the new procedures before sta rting the review.

3.1.2(3)Establish process guidance to ensure that generic requirements or guidance are not inappropriately

affected when making unrelated changes to

processes, guidance, etc. (e.g., deleting inspection

procedures that were developed in response to a

generic issue).LowOpECompleteCompleteNRR (IIPB)

STATUS: Language was added to IMC 0040, "Preparing, Revising and I ssuing Documents for the NRC Inspection Manual" to ensure th at inspection requirements are not removed that were previously inserted to emphasize licensee performance in areas identified in a Generic Letteror Nuclear Regulatory Commission (NRC) Bulletin (IMC 0040, Change Notice 04-003, ADAMS Accession # ML040690184, dated 2/2/04).

This is a permanent modification to the NRC Inspection Manual, applicable to all changes.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.14 The revised Manual Chapter requires that the previous four (4) years of changes be reviewed. An effectiveness review determine d that this is a sufficient period of time to consider.

3.1.3(1)Evaluate, and revise as necessary, the guidance for proposing candidate GIs.LowOpECompleteCompleteRES STATUS: The staff has completed an evaluation of the guidance for proposing candidate Generic Issues (GIs) in Management Direc tive (MD)6.4, "Generic Issues Program." A revision of the Handbook 6.4 to address the DBLLTF recommendation to enhance and simplify the processwas completed by 10/04 and inter-office/regional review and comments were obtained in accordance with MD 1.1, "NRC Management D irective System." That action met the intent of DBLLTF recommendation and closed out this task.

3.3.4(7)Reassess the basis for the cancellation of the inspection procedures that were deleted by Inspection

Manual Chapter, Change Notice 01-017 to determine

whether there are deleted inspection procedures that

have continuing applicability. Reactivate such

procedures, as appropriate.LowOpECompleteNot requiredNRR (IIPB)

STATUS: A review of 80 procedures deleted by Change Notice CN 01-017 was conducted to determine if there were any deleted inspe ctionprocedures that have continuing applicability. Four inspection procedures were determined to have continuing applicability and were reactivated. These were IP56700, "Calibration," IP82201, "Eme rgency Detection and Classification," IP82202, "Protective Action Decision Making," and IP90700, "Feedback of Operating Experience Information at Operating Power Reactors." This action was essentially an effectiveness review of the previous decision and no additional e ffectiveness review is required. The procedures will be evalu ated as part of the annual ROP self-assessment.

15Category: Inspection Programs LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.3.2.5(2)Revise inspection guidance to provide assessments of: (1) the safety implications of long-standing, unresolved problems; (2) corrective actions phased in

over several years or refueling outages; and

(3) deferred modifications.HighInspCompleteCompleteNRR (IIPB)

STATUS: Inspection Procedure (IP) 71152, "Identification and Resolu tion of Problems," was revised to require the resident insp ector to perform a screening review of each item entered into the corrective action pr ogram. The intent of this review is to be alert to condit ions such as repetitive equipment failures or human performance issues that might warr ant additional follow-up through other baseline inspection proced ures. IP 71152 was also revised to require a semi-annual review to identify trends that might indicate the existence of a more significant saf ety issue. Included within the scope of this review are repetitive or closely re lated issues that may have been documented by the licensee outside the normal corrective action program, such as in trend reports or perform ance indicators, major equipment problem lists, repetitive and/or reworkmaintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, maintenance rule assessments, or corrective action backlog lists.

To address the issue of deferred modifications, the staff revised IP 71111.15, "Operability Evaluations." The objective of thi s procedure is toreview operability evaluations affecting mitigating systems and barrier integrity to ensure that operability is properly justif ied and the component or system remains available, such that no unrecognized increas e in risk has occurred. The procedure was revised to include def erred modifications as one of the areas an inspector can assess to ensure that structures, systems, and components are capable of per forming their design function.

The effectiveness of the changes to IP 71152 was discussed during a problem identification and resolution focus group meeting h eld on March 11, 2005. The consensus of the group members was t hat the changes have resulted in no unintended consequences, have rein forced expectations that inspectors have a questioning attitude, and prov ide a method for highlighting i ssues that might be indicative of a more significant problem. In addition, semiannual trend reviews have successfully identified negative equipment trends. In some ca ses, these negative trends may not have been documented if the inspection guidance had not been changed. There has been some feedback fro m inspectors requesting additional guidance on how to conduct the semiannual trend reviews. The inspection guidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issues that might not fit well else where in the inspection program. Overall, the changes were effectively implemented and addressed the recommendations. IP 71152 will contin ue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.16 3.3.5(4)Develop guidance to address the impacts of IMC 0350 implementation on the regional organizational

alignment and resource allocation.HighInspCompleteCompleteNRR (IIPB)

STATUS: The Inspection Program Branch completed an evaluation of the IMC 0350, "Oversight of Operating Reactor Facilities in a Shutdown Condition with Performance Problems," process in June 2003, (ML031890873). It identified the need for specifically budgeting r esources for IMC 0350 inspections and providing prescriptive inspection guideli nes for the process. The budget estimate was increased for F Y2005 and beyond (ML033010385) to account for one IMC 0350 plant per year. IMC 0350 was revised in December 2003, to provide additional inspection guidelines.

Davis-Besse remained the only plant under the IMC 0350 process duri ng CY 2004. At the time of the effectiveness review, no add itional plants had been considered for IMC 0350 oversight since the implementation of the DBLLTF recommendations. However, feedback from the Davis-Besse Oversight Panel and other stakeholders indicated that the procedural and budgetary changes have been generally effective in addressing the concerns noted by the DBLLTF, particularly in the allocati on of resources and implementation of the comprehensive inspectio n and oversight guidance. In addition, in accordance with the guidance in IMC 0350, the Davis-Besse Oversight Panel is developing a report of recommended improvements to the process based on additional lessons learned. Accordingly, the staff will revise IMC 0350 in CY 2005 to add ress these recommendations and further improve the process. The IMC 0350 process, including these procedural and budgetary changes, will also continue to be evaluated for efficiency and effectiveness as part of the annual ROP self-assessment process.

3.3.7(2)Establish guidance to ensure that decisions to allow deviations from agency guidelines and

recommendations issued in generic communications

are adequately documented.

HighInspCompleteCompleteNRR (DLPM)STATUS: Guidance on documenting decision making and a training pa ckage containing applicable reference material were issued th rough a DLPM Handbook update and placed on the Project Managers web site in 02/03. In 04/03, the NRR Director distributed the training package toother NRR divisions by e-mail, and the Deputy EDO for Reactor Programs forwarded it by memorandum (ML030300106) to other office s and the regions.

Office Instruction LIC-503, "Generic Communications Affecting Nu clear Reactor Licensees," iss ued in 06/03, contains guidance on documenting review and closeout of generic communications. A revision in 07/04 added the specific requirement for documenting the basis fo r allowing deviations from generic communications.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.17 The intent of the LLTF 3.3.7(2) was met by the above actions.

An effectiveness review of distributing the guidance indicated a need for refresher training for licensing Project Managers. This was conducted at DLPM staff meetings in 06/04 and 03/05. The guidance has also been included in the Project Manager qualification program, so all new PMs will be made aware of the requirements. An effectiveness review f or generic communication closeout recommended more specific guidanc e in LIC-503, which was added in the 07/04 revision.

3.2.5(1)Develop inspection guidance to assess scheduler influences on outage work scope.MediumInspCompleteCompleteNRR (IIPB)STATUS: Operability of plant structures, systems, and components was considered to be the fundamental operative regulatory req uirement.Therefore, Inspection Procedure (IP) 71111.15, "Operability Eval uations," was modified (IP 71111.15, Change Notice 04-003, ML040690184, dated 2/2/04) to include deferred modifications (potentially def erred due to outage scheduler pressure as well as other reasons) as part of thepopulation of items from which to sample for the adequacy of a licensee's process for ensuring operability of all plant systems by surveillance and continuous monitoring. In addition, existing IP 71111.20, "Refueling and Other Outage Activities" assesses the adequacy of the licensee's actions to mitigate and control the changes in plant risk during outage activities. The effectiveness of the regional implemen tation of these inspection procedures are evaluated annually and the results are doc umented in the annual Reactor Oversight Process self assess ment SECY paper.The staff's review of inspection results and region feedback regar ding implementation of these changes did not identify any imp lementation issues or findings resulting from the IP revisions.

IPs 71111.15 and 71111.20 will continue to be evaluated on an ongoing basi s as part of the annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 0801, "Reactor Oversight Pro cess Feedback Program."

3.3.1(2)Develop inspection guidance to assess repetitive or multiple TS action statement entries, as well as, the

radiation dose implications associated with repetitive

tasks.MediumInspCompleteCompleteNRR (IIPB)

STATUS: IMC 2515, Appendix D, Plant Status, was revised in 05/

04 to evaluate licensee actions when operating with multiple or repetitive or unplanned Technical Specification (TS) action statements, and in cluded inspection guidance for assessing radiation dose implica tions associated with repetitive tasks. These procedure changes were reviewed and commented on by the regional staff and approved fo r implementation.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.18 The staff's review of inspection results and feedback from each Region regarding the implementation of these changes indicates that the licensees were neither operating with excessive repetitive or mult iple TS action statement entries nor causing any significant radiation dose to workers as a result of repetitive tasks. The licensees' actions were consistent with TS requirements and occupational radiatio n exposure guidance. No implementation issues or findings were identif ied in this area. IMC 2515 will continue to be evaluated on an ong oing basis as part of the annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 0801.

3.3.3(1)As an additional level of assurance, identify alternative mechanisms to independently assess plant

performance as a means of self-assessing NRC

processes. Once identified, the feasibility of such

mechanisms should be determined.MediumInspCompleteCompleteNRR (IIPB)

STATUS: The staff researched plant assessments performed by i ndependent parties and identified two (Institute of Nuclear Power Operations(INPO) and International Atomic Energy Agency (IAEA) that c ould be used as a means of self-assessing the NRC inspection and pla nt performance assessment process. Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program," was revised on December 21, 2004 (ML043560249), to include consideration of t hese independent assessments during the mid-cycle and end-of-cycl e assessment preparations. During the assessment preparations, t he staff will determine if there are possible plant performance deficiencies notidentified by the NRC, and if so, make a determination if base line inspection resources should be directed to evaluate the poss ible deficiencies.

In addition, this information will be assessed during the annual reactor oversight process self-assessment to determine if any process changes are warranted.

3.3.4(1)Review inspection guidance pertaining to refueling outage activities to determine whether the level of

inspection effort and guidance are sufficient given the

typically high level of licensee activity during relatively

short outage periods. The impact of extended

operating cycles on the opportunity to inspect inside

containment and the lack of inspection focus on

passive components should be reviewed. This review

should also determine whether the guidance and level

of effort are sufficient for inspecting other plant areas

which are difficult to access or where access is

routinely restricted.MediumInspCompleteCompleteNRR (IIPB)

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.19 STATUS: Inspection Procedure (IP) 71111.20 "Refueling and Other Ou tage Activities" was revised to include containment walkdown s and consideration of walkdowns in other restricted areas (IP 71111.20, Change Notice 04-011, ADAMS Accession #ML041280018, dated 5/

6/04). In addition, the inspection of passive component integrity is being increased in response to DBLLTF items 3.3.2(1) and 3.3.4(3), w hich enhanced inspection of licensee inservice inspection ac tivities, including boric acid corrosion control. The effectiveness of the regio nal implementation of these inspection procedures are evaluated annually as part of the annual Reactor Oversight Process self assessment.

Region feedback identified a need to expand on the IP 71111.20 guidanc e to ensure proper focus during outages on structures, sy stems, and components that are inaccessible during power operations. Howeve r, prior to the 5/6/04 revision, the Regions had used outage p eriods as opportunities to inspect plant areas that are only accessible dur ing outages. This includes inspections under other IPs in the ROP. ALARA and environmental conditions (i.e., high temperature) were identified as limiting factors for containment walkdowns in several boil ing water reactors, which indicates that containment type should be factored into c ontainment walkdown guidance. This is being evaluated as a pote ntial IP 71111.20 revision. IP 71111.20 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 0801.

3.3.4(4)Revise IMC 0350 to permit implementation of IMC 0350 without first having established that a significant

performance problem exists, as defined by the ROP.MediumInspCompleteCompleteNRR (IIPB)

STATUS: IMC 0350 was revised 12/31/03 to state that a plant can be considered for oversight under the IMC 0350 process when a significant operational event has occurred. The next revision to IMC 0350 will revise the title to reflect this change.

Davis-Besse remained the only plant under the IMC 0350 process duri ng CY 2004. At the time of the effectiveness review, no add itional plants had been considered for IMC 0350 oversight since this change was made in December 2003. However, feedback from the Davis-Besse

Oversight Panel and other stakeholders indicates that this change and those noted under DBLLTF item number 3.3.5(4) have been e ffective in addressing the concerns noted by the DBLLTF, particularly in t he allocation of resources and implementation of the comprehensiv e inspection and oversight guidance. The IMC 0350 process, including this particular change, will continue to be evaluated for efficiency a nd effectiveness as part of the ROP self-assessment process on an annual basis.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.20 3.3.4(5)Review the range of NRC baseline inspections and plant assessment processes, as well as other NRC

programs, to determine whether sufficient programs

and processes are in place to identify and

appropriately disposition the types of problems

experienced at DBNPS. Additionally, provide more

structured and focused inspections to assess licensee

employee concerns programs and safety conscious

work environment (SCWE). MediumInspCompleteNot RequiredNRR (IIPB)

STATUS: The Inspection Program Branch (IIPB) reviewed the NRC baseline inspection program and plant assessment processes as pa rt of the annual Reactor Oversight Process (ROP) self-assessment in April 2004, and also reviewed completed DBLLTF items related to the R OP. Based on these reviews, the staff has enhanced the baseline ins pection program by (1) requiring the screening of all licensee c orrective action items, (2) performing a semi-annual trend review focused on recu rring equipment issues, (3) requi ring containment walkdowns dur ing outages, (4) reviewing deferred modifications, and (5) evaluating licens ee actions when operating with multiple, repetitive, or unplanne d technical specification action statements. The staff has enhanced the plant assessment process by (1) strengthening the oversight of pla nts in extended shutdowns, (2) requiring more complete documentation of import ant staff decisions, and (3) budgeting resources for Inspection M anual Chapter 0350 plants. The staff has also enhanced the ROP by (1) requiri ng training on boric acid corrosion, stress corrosion cracking, and the importance of a questioning attitude, and (2) requiring annual refres her training on different aspects of the ROP. Based on th ese actions, the first half of this DBLLTF action item is complete.

Regarding the second half of this item, on August 30, 2004, the Commission issued a Staff Requirements Memorandum (SRM) that di sapproved an option to develop an inspection process to systematically asse ss safety culture. Instead the SRM requires the staff to enha nce the ROP treatment of cross-cutting issues to more fully address safety culture. The SRM noted that the staff should rely on inspector observations andother indicators already available to the NRC, should develop tools that allow inspectors to rely on more objective findings, s hould consider including enhanced problem identification and resolution initiatives, and should ensure that the inspectors are properly traine d in the area ofsafety culture. Based on this direction from the Commission, the staff will work with the appropriate stakeholders to provide more structured inspection and guidance in the area of safety culture, which encom passes SCWE. As a result of the Commission's direction, the DBLLTF itemto provide more focused inspections on employee conc erns programs and SCWE has been superseded and expanded upon and will be tr acked separately in response to the SRM. Therefore, the second half of this recommendation is complete. The effectiveness of any ch anges made to the ROP will be evaluated as part of the annual ROP self-assessment.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.21 3.3.7(1)Reinforce expectations for the implementation of guidance in the PM handbook for PM site visits, coordination between PMs and resident inspectors, and PM assignment duration. Reinforce expectations

provided to PMs and their supervisors regarding the

questioning of information involving plant operation

and conditions. Also, strengthen the guidance related

to the license amendment review process to

emphasize the need to consider current system

conditions, reliability, and performance data in SERs.

In order to improve the licensing decision-making

process, the NRC should strengthen its guidance

regarding the verification of information provided by

licensees.MediumInspCompleteCompleteNRR (DLPM)STATUS: Several of these recommendations are addressed, at least in part, by existing procedures.

The "Site Visits" section of the DLPM Handbook provides guidance to PMs on activities to be conducted during site visits. The "Morning Calls" section discusses interactions with Region personnel. Office In struction LIC-100, Rev. 1 (issued 01/04) provides guidance on c onsidering current conditions during licensing action reviews. Office Inst ruction LIC-101 provides guidance on the amendment review proce ss and use of Requests for Additional Information (RAI)for obtaining information. IP 71005 (issued 08/03) provides a mechanism for PMs to ob tain resident inspector (RI) support in obtaining plant information. In addition, a memo from the DLPM Director to the DLPM staff (6/25/04) provided clarification of management expectations for PM site visits, coordination between PMs and resident inspectors, PM assignment du ration, questioning of information, and verifying information provided by licensees. This also has been discussed at division and mana gement meetings. The DLPM handbook and appropriate Office Instru ctions were updated to include this additional guidance .

The effectiveness review determined that this recommendation was successfully implemented. In general, PMs visited their sites consistent with the expectation, although travel and budget constraints, special a ssignments such as the security plan review team, and other r esource issues resulted in some PMs not visiting their sites.

With regard to PM assignment duration, a review of 34 PM reassignments that occurred between May 2004 and June 2005 revealed th at 16 were due to medical reasons, retirements, resignations, permanent rotations to other divisions, and temporary rotations to spec ial task groups.

Of the 18 remaining transfers, the average time the previous PM was assigned to the plant was 3.44 years. PM assignment durati on (that was less than the desired length but within the control of the office) was documented in memos from Project Directors.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.22 Most PMs include the Region and RI during the licensing review and when drafting the safety evaluation. Verification of inform ation submitted by licensees is being accomplished, as evidenced by the identific ation of deficiencies with licensee submittals on a few occasi ons. Prompt action and attentiveness by several PMs resolved complicated issues by supplying plant operational information to the technical staff before sending the licensee an RAI. Communications between the PM, RI and t he technical staff took various forms. Sharing of informa tion between the Resident and the PM led to many successful reviews and the captur ing of potential safety issues. Some examples are: PM an d RI cooperation on heavy loads accident analysis; an RI provided operational information that the licensee's foreign material exclu sion (FME) program had deficiencies and the licensee took steps to correct t hose issues prior to approval of an amendment that relied on i ts FME program; and, an RI provided information on the lack of margin for the ultimate heat sink and an emergency TS change was denied. These examples demonstrate that the PMs work with RIs and the region to consi der current plant conditions, question and verify data provided b y licensee, and improve the licensing decision-making process.

APP. F Conduct an effectiveness review of the actions taken in response to past lessons-learned reviews.MediumInspCompleteNot RequiredNRR(IIPB)

STATUS: A task force conducted the recommended review and issued its report on 8/2/04 (ML042110287). This completed the scope of work required by this LLTF recommendation and, since the Appendix F e ffort was itself an effectiveness review, an additional effecti veness review is not required. However, the report findings and recommendations are being addressed.

The task force found that, while previous lessons learned re views were thorough and produced good recommendations, they were not always effectively implemented. It recommended development of an agency-wide corrective action program. This recommendation was acce pted by management and endorsed by the Commission in its 12/15/04 SRM (ML043500639). The EDO formed a team to develop a corrective act ion program that addresses the task force report and the SRM. The team is developing a program that will address lessons learned s elected for special attention from high-level, multi-office or agency level lessons that stem from organizational failures. The program wi ll be implementedthrough a phased approach. Program definition and draft documentation will be developed by December 31, 2005. Following a pil ot programand staff training, the base program will be implemented by June 2006.

The team's activities are being tracked and reported se parately from the Davis-Besse LLTF recommendations.

Specific items from the previous lessons learned reports t hat were identified for additional follow-up have been entered into t he NRR correctiveaction program and will be tracked to completion by that process.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.23 3.3.2(2)Revise the overall PI&R inspection approach such that issues similar to those experienced at DBNPS are

reviewed and assessed. Enhance the guidance for

these inspections to prescribe the format of

information that is screened when determining which

specific problems will be reviewed. LowInspCompleteCompleteNRR (IIPB)

STATUS: The Inspection Program Branch issued a revision in 09/03 to Inspection Procedure (IP) 71152, "Identification and Resol ution of Problems," to include an inspection requirement to perform a semi-annual review to identify trends that might indicate the exis tence of a more significant safety issue. Training to inform the inspection staff of this change to IP 71152 was conducted using web-based tra ining and follow up conference calls between the regions and the program office. The training was documented as complete in May 2004.

The effectiveness of the changes to IP 71152 addressing the DBLL TF recommendations was discussed during a problem identificatio n and resolution focus group meeting held on March 11, 2005. The consens us of the group members was that the changes have resulted i n no unintended consequences, have reinforced expectations that inspecto rs have a questioning attitude, and provide a method for hig hlighting issues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conjun ction with the NRR program office, have highlighted and communicated semiannual tr end reviews that have been successful at identifying negative eq uipment trends. In some cases, these negative trends may not hav e been documented if the inspection guidance had not been changed. Th ere has been some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. The inspecti on guidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issues that might not fit well elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommendations. IP 71152 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.2(3)Provide enhanced Inspection Manual Chapter guidance to pursue issues and problems identified

during plant status reviews.

LowInspCompleteCompleteNRR (IIPB)

STATUS: IP 71152, "Problem Identification and Resolution," was re vised in 09/03 to require the resident inspector to perform a screening review of each item entered into the corrective action program. T he intent of this review is to be alert to conditions such as repetitive equipment failures or human performance issues that might warrant addi tional follow-up through other baseline inspection procedures.

The effectiveness of the changes to IP 71152 addressing the DBLL TF recommendations was discussed during a problem identificatio n and LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.24 resolution focus group meeting held on March 11, 2005. The consens us of the group members was that the changes have resulted i n no unintended consequences, have reinforced expectations that inspecto rs have a questioning attitude, and provide a method for hig hlighting issues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conjun ction with the NRR program office, have highlighted and communicated semiannual tr end reviews that have been successful at identifying negative eq uipment trends. In some cases, these negative trends may not hav e been documented if the inspection guidance had not been changed. Th ere has been some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. The inspecti on guidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issues that might not fit well elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommendations. IP 71152 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.2(4)Revise inspection guidance to provide for the longer-term follow-up of issues that have not

progressed to a finding.LowInspCompleteCompleteNRR (IIPB)

STATUS: IP 71152, "Problem Identification and Resolution,"

was revised in 09/03 and includes enhanced requirements regarding r outine PI&R reviews conducted by the resident inspectors, biennial review s of longstanding issues, and biennial reviews of licensees' opera ting experience issues. The effectiveness of the changes to IP 71152 addressing the DBLL TF recommendations was discussed during a problem identificatio n and resolution focus group meeting held on March 11, 2005. The consens us of the group members was that the changes have resulted i n no unintended consequences, have reinforced expectations that inspecto rs have a questioning attitude, and provide a method for hig hlighting issues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conjun ction with the NRR program office, have highlighted and communicated semiannual tr end reviews that have been successful at identifying negative eq uipment trends. In some cases, these negative trends may not hav e been documented if the inspection guidance had not been changed. Th ere has been some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. The inspecti on guidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issues that might not fit well elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommendations. IP 71152 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.25 3.3.3(2)Perform a sample review of the plant assessments conducted under the interim PPR [Plant Performance

Review] assessment process (1998-2000) to

determine whether there are plant safety issues that

have not been adequately assessed.LowInspCompleteNot RequiredNRR (IIPB)

STATUS: An audit of eight PPRs (2 PPR per Region) was comple ted in 06/04. It did not identify any issues that had not been ad equately addressed. No additional follow-up is necessary.

3.3.4(6)Provide ROP refresher training to managers and staff members.LowInspCompleteCompleteNRR (IIPB)

STATUS: Based on the Davis Besse LLTF Report, ROP Refresher Tr aining was provided at each of the Regional Inspector Counterpar t Meetings in 05/04. The topic of the ROP Refresher Training session was an individual's role in developing and maintaining a qu estioning attitude. The slide presentation can be found at ADAMS (ML041320101).

The IMC1245, "Qualification Program For the Office of Nuclear Reactor Regulation Programs" (ML04180012), was revised to include a requirement for annual ROP Refresher Training. IMC 1245 requires that topics for ROP refresher training will be solicited duri ng the Spring Regional Inspector Counterpart Meetings. The IMC 1245 Management Steering Group will select the topic(s), determine the method of training, and determine the timing of the training. The NRR Inspection Pr ogram Branch will be responsible for ensuring the training is d eveloped and implemented during the fall of each year.

This action was effectively implemented in 2004. The Inspecti on Program Branch provided the initial ROP refresher training dur ing the spring regional inspector counterpart meetings. The training focused on maintaining a questioning attitude. In the long term, IMC 12 45 was revised to include a requirement for annual ROP refresher training.

The IMC 1245 Management Steering Group and IMC 1245 Working Group annually review the effectiveness of inspector training throu gh feedback forms submitted, results of the inspector oral boards , and regional experience. Improvements and revisions are recomm ended and implemented as appropriate. In addition, the Regions discuss curr ent ROP issues during inspector counterpart meetings and in n ewsletters discussing value-added findings. Further, the IMC 1245 Management St eering Group, comprised of Regional Division/Deputy Divisi on LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.26 Directors, discusses potential ROP refresher training topics and chooses the topic to be discussed during formal training. In summary, the training associated with this recommendation was effectively implemented and will be continually reviewed as pa rt of the inspector training program reviews and regional management attention.

3.3.5(2)Reinforce IMC 0102 expectations regarding regional manager visits to reactor sites.LowInspCompleteCompleteNRR (IIPB)

STATUS: During the July 2003 Regional Division Director Counterpar t Meeting, the Inspection Program Branch reinforced the IMC 0102 expectations for site visits. During a general discussion of r eactor oversight process topics, a hand out was distributed whic h outlined the site visit responsibilities for the senior resident and resident ins pectors, each line manager, Division of Reactor Project (DRP) ma nagers, the Operator Licensing manager, the DRP Division Director or Deputy, and the Regional Administrator or Deputy Regional Administrato

r. The sitevisit responsibilities were discussed and are outlined in detail in IMC 0102,"Oversight and Objectivity of Inspectors and Exami ners at Reactor Facilities,"

This action was effectively implemented in 2003. The traini ng was provided during the August 2003 regional Division Directors counterpart meeting and focused on the requirements of IMC 0102. In addition, as part of regional efforts to improve consistency and commu nicate value-added inspection activities, IMC 0102 is being revised to improv e the expectations and requirements for regional managers regar ding reactorsite visits. In summary, the training associated with this recommendation was effectively implemented and will be continually reviewed as part of the inspector training program reviews and regional management attention.

3.3.5(3)Establish measurements for resident inspector staffing, including the establishment of program

expectations to satisfy minimum staffing levels.

LowInspCompleteCompleteNRR (IIPB)

STATUS: A "Site Staffing" metric (ML032410588) was developed in 12/

03, with regional input, to monitor gaps in permanent resid ent and senior resident inspector staffing at reactor sites. This metric was pilot tested in calendar year 2004, adjustments have been made b ased on the results of the pilot, and a revised metric was issued to the regions in 12/04. A criterion of maintaining at least 90% staffing progra m-wide has beenestablished for this metric. In addition, any single site that falls below 90% will be specifically evaluated as part of the R eactor Oversight Process self-assessment process. This new metric will be used as an input to the annual Reactor Oversight Process self-assessment proc ess. Since the effectiveness review for this change will be an ongoing assessment of usefulness as the metric is used as an input to the p rocess, no additional effectiveness review is required.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.27 3.3.7(5)Fully implement Office Letter 900, "ManagingCommitments Made by Licensees to the NRC," or

revise the guidance if it is determined that the audit of licensee's programs is not required.

Further, determine whether the periodic report on

commitment changes submitted by licensees to the

NRC should continue to be submitted and reviewed.LowInspCompleteCompleteNRR (DLPM)STATUS: Office Letter 900 was revised and incorporated into NRR Office Instruction LIC-105, "Managing Commitments Made by Licen sees to the NRC," which was issued on 05/27/03. LIC-105 requires periodic audits (every 3 years) by the DLPM Project Managers (PMs) th at consist of two major parts. The first is a verification of the licensee's implementation of NRC commitments by reviewing a sample of comm itments. LIC-105 provides criteria for selection of the sample. The second is a verification of the licensee's program for managing cha nges to commitments. Program controls will be verified to be consistent with industry guidelines in Nuclear Energy Institute document NEI 99-04, whichhas been found by the NRC (SECY-00-045, dated 2/22/00) to provide acceptable guidance for managing regulatory commitments. NEI 99-04 also directs licensees to submit periodic reports of changes to commitments. This part of the audit will be done through additi onal samples of changes to commitments. It also includes a sample to confirm that the licensee's program ensures commitments are maintained fo llowing initial implementation. The results of the audit will be documented in a report from the PM.

In the discussion of the basis for this recommendation, the LL TF also noted that the DLPM handbook did not reference the office letter or discuss requirements for periodic audits of licensees' commitment management programs. The DLPM Handbook has been revised and the sections on "Site Visits" and "Commitment Management Program" rein force the requirement for the periodic audits by PMs, and pro vides a link to LIC-105.

The intent of the LLTF recommendation has been met by the issuanc e of the guidance documents in 2004. An effectiveness review in 2005 found that, consistent with the guidance and management expectations, one-third of the reviews were completed during the first year. Some PMs suggested that having the resident inspectors perform the audi ts as part of 10 CFR 50.59 reviews would retain the benefit o f the audit, improve efficiency, and reduce travel costs. Most PMs were in agreement that the audit documentation requirements should be re duced. These items will be considered and the staff will determine whether changes to the audit procedures are needed when audits have been performed at all sites.

In the course of the audits, PMs generally gained confidence that the licensees' commitment management programs are robust and reliable.

Some items identified for future consideration include : (1) So me licensee do not have a dedicated system to track regulatory c ommitments and, instead, rely on several plant tracking subsystems to manage r egulatory commitments, which results in the licensee not having a comprehensive listing and current status of all regulatory commitments, (2) En forcement of commitments can be difficult since commitments can be eliminated in LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.28a 50.59 review, (3) Licensees typically do not formally identify regulatory commitments in submittals to the NRC.

The commitments to evaluate the efficiency of the audit proc ess and the need for procedure changes have been entered into the N RR corrective action program and will be tracked through that process.

29Category: Barrier Integrity LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.3.1.5(1)Determine whether PWR plants should install on-line enhanced leakage detection systems on critical plant

components, which would be capable of detecting

leakage rates of significantly less than 1 gpm.HighBICompleteNot requiredRES (DET) for research report

NRR/RES for

remaining actions STATUS: This recommendation focuses on determining if improvem ents can be made in leakage detection requirements. To accompli sh this, a comprehensive review and evaluation of pl ant experiences and current leakage detecti on systems was performed by updating a simi lar studythat was performed by Argonne National Laboratory (ANL) in the late 1980's. There are three main tasks associated with this ef fort. The first task is an assessment of the leakage associated with the degradati on of various reactor coolant pressure boundary components.

The second task is a review of leakage operating exper ience by developing a database of leakage event

s. The third task is an evaluation o f the capabilitiesof various leakage detection systems. ANL submitted a draft r eport in 05/04. The RES and NRR staffs reviewed this draft repor t and provided comments to ANL. The final report was published as NUREG/CR-6861 in12/04.

A working group consisting of members of the NRR and RES staff was formed to address this recommendation.

In evaluating the need for additional requirements pertaining to leakage detection, the staff considered past operating experie nce related to reactor coolant system integrity and the performance deficiencies that led to the degradation that occurred at Davis-Besse. Th e staff identified techniques that could improve localized leak detection and on-line monitoring and several areas of possible improvements to lea kage detection requirements that could provide increased confidence that plant s are not operated at power with reactor coolant pressure bounda ry leakage.

However, implementing these increased capabilities would most likely result in a very modest reduction in loss-of-coolant accid ent frequencies.

As a result, the staff concluded that the associated risk reducti on that may be realized would not justify the costs associated with the installation and maintenance of such equipment (i.e., the cost-benefit criteria associated with implementation of the backfit rule [10 CFR 5 0.109] could not be satisfied). Issuance of the working group report complet ed the recommendation and, since no further action was proposed, an effectiveness review is not required.

3.2.1(1)Improve the requirements pertaining to RCS unidentified leakage and RCPB leakage to ensure that

they are sufficient to: (1) provide the ability to

discriminate between RCS unidentified leakage and

RCPB leakage; and (2) provide reasonable assurance

that plants are not operated at power with RCPB

leakage.HighBICompleteNot requiredRES (DET) for research report NRR/RES for remaining actions LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.30 STATUS: This item was implemented in conjunction with LLTF 3.1.5(1) above.

In evaluating the need for additional requirements pertaining to leakage detection, the staff considered past operating experie nce related to reactor coolant system integrity and the performance deficiencies that led to the degradation that occurred at Davis-Besse. Th e staff identified techniques that could improve localized leak detection and on-line monitoring and several areas of possible improvements to lea kage detection requirements that could provide increased confidence that plant s are not operated at power with reactor coolant pressure bounda ry leakage.

However, implementing these increased capabilities would most likely result in a very modest reduction in loss-of-coolant accid ent frequencies.

As a result, the staff concluded that the associated risk reducti on that may be realized would not justify the costs associated with the installation and maintenance of such equipment (i.e., the cost-benefit criteria associated with implementation of the backfit rule [10 CFR 5 0.109] could not be satisfied). Since no changes were recommended, an effectiveness review is not required.

3.2.1(2)Develop inspection guidance pertaining to RCS unidentified leakage that includes action levels to

trigger increasing levels of NRC interaction with

licensees in order to assess licensee actions in

response to increasing levels of unidentified RCS

leakage. The action level criteria should identify

adverse trends in RCS unidentified leakage that could

indicate RCPB degradation.HighBICompleteCompleteNRR (IIPB)

STATUS: IMC 2515, Appendix D, "Plant Status," was revised in 05/04 to require inspectors to trend leak rates and monitor unide ntified leakage for adverse trends, and, if any are noted, to inform licensee management and regional management. The guidance also requires i nspectors to review licensee procedures and action plans to identify source(s) of RCS unidentified leakages when RCS leakages are suspected and to review licensee procedures for action steps, as unidentified leakage approac hes licensee administrative limits or technical specificat ions allowed values. IMC 2515, Appendix D, was revised again in 01/05 to provide gui dance and techniques necessary for assessing potential adverse t rends and action levels in response to increasing levels of RCS unidentifi ed leakage. The effectiveness review was deferred to provide a n adequate period of time to use the new guidance.

LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.31 3.2.1(3)Inspect plant alarm response procedure requirements for leakage monitoring systems to assess whether

they provide adequate guidance for the identification

of RCPB leakage.HighBICompleteCompleteNRR (IIPB)

STATUS: To address this recommendation, inspection guidance has been revised to verify that licensees have programs and proces ses in place to (1) monitor plant-specific instrumentation that could indicate potential RCS leakage, (2) meet existing requirements r elated to degraded or inoperable leakage detection instruments, (3) use an inventor y balance check when there is unidentified leakage (4) take app ropriate corrective action for adverse trends in unidentified leak rates, and (5) pay particular attention to changes in unidentified le akage. The revised procedures include Inspection Manual Chapter 2515 Appendix D (Plant Status Review), Inspection Procedure 71111.22, and Inspecti on Procedure 71111.08. These revisions were i ssued in 05/04 and inspections have commenced.

The assessment of the adequacy of licensee procedure requirements was completed as part of the annual ROP self assessment proce ss. The staff's review of inspection results and feedback from each Regi on regarding the implementation of these changes indicated that the licensees' alarm response procedures and operating procedures provide adequat e guidance for the identification and corrective actions for reactor coolant system boundary leakage. No implementation issues or findings were identified in this area. IPs 71111.22 and 71111.08, and IM C 2515 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 0801.

3.3.3(3)Continue ongoing efforts to review and improve the usefulness of the barrier integrity PIs [Performance

Indicators]. These review efforts should evaluate the

feasibility of establishing a PI which tracks the

number, duration, and rate of primary system leaks

that have been identified but not corrected.HighBICompleteNot RequiredNRR(DIPM)

STATUS: The review and improvement of PIs is on ongoing process, which is performed by a working group that includes NRC and i ndustry representatives. The PI program is a voluntary program for t he industry in that there are no regulatory requirements associate d with theprogram. Changes to the program generally require consensus between the NRC staff and industry. The first part of LLTF 3.3.3(3) is satisfied by the continuation of this ongoing process. The second part of the recommendation requires a feasibility eval uation of establishing an additional PI for tracking number, d uration and rate of LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.32 primary system leaks. The existing Reactor Coolant System (RCS) Leakage PI already monitors identified leakage as a percentage of the plant technical specifications limit. The intent of the PI is to call attention to those plants that have identified primary system leaks but have not corrected them in a timely manner. Only five plants have cross ed the green-white threshold (greater than 50 percent of TS limit) in five years. The industry and NRC staff established a subgroup composed of NRC staff and industry representatives to assess the feasibility of creating a PI to track the number, duration, and rate of primary system lea ks that have been identified but not corrected. The group conclud ed that it is not feasible at present due, in part, to the difficulty licensees have in determining small leak rates accurately, and, in part, to the quarterly data reporting, which makes it difficult for the staff to determine t he number of leaks, the rate, and the duration. However, the s taff will continue tofollow progress in leak detection capability and industry efforts in this area.

As part of the continuing effort to improve usefulness of the barrier integrity PIs and the Reactor Oversight Process, the staf f/industry working group agreed to have the subgroup explore possible improvements to the RCS leakage PI. The subgroup has met on a number of occ asions and is currently interacting with the Westinghouse Owners Group to understand the efforts being undertaken by that group.In summary, the staff has assessed the feasibility of establishing the PI which tracks the number, duration, and rate of primary system leaks that have been identified but not corrected and has determined that it is not feasible at this time. As part of the ongoing efforts to improve the Reactor Oversight Process and PI Program, the staff is working with its external stakeholders and has established an NRC staff/

industry subgroup to explore and possibly improve the RCS Leakage PI. Since this is a continuing process and no specific changes were m ade, there is no need for an effectiveness review.

3.3.4(9)Review PWR plant technical specifications to identify plants that have non-standard RCPB leakage

requirements.

Pursue changes to those technical specifications to make them consistent among all plants.HighBICompleteNot RequiredNRR (IROB)

STATUS: Plants with nonstandard RCPB technical specifications (TSs) were identified in a 07/03 study (ML031980277). The study indicated that only one plant did not have TSs for RC PB leakage. Subsequently, this plant submi tted a technical specification change req uest that will bring it into alignment with the standard TSs. This change wa s approved on 5/7/04. Now all PWR TSs have RCPB leakage limits c onsistent with standard TSs. The requirements for shutdown, if leakage exis ts, are not identical, but all plants require appropriate cons ervative action to place the plant in cold shutdown within the time frame of the standard TSs.

3.3.7(3)Evaluate the adequacy of analysis methods involvingMediumBICompleteCompleteRES LLTF No.LLTF RecommendationPriorityCategory Target Date Effectiveness Review Lead Org.33 the assessment of risk associated with passive component degradation, including the integration of

the results of such analyses into the regulatory

decision-making process.

STATUS: A working group consisting of members of the NRR and RES staff addressed this recommendation. In general, the working group found that the methods used to assess risk are adequate; however, in most cases there is insufficient data to use those methods to produce robust results. Also, an understanding of the results of any ri sk assessment, as well as its limitations and uncertainties, is paramount for responsible risk-informed regulatory decision making. The wo rking group report, dated March 31, 2005, found that the available risk assessment models alone are usually inadequate to provide strong support for many types of decisions. The portions of the risk models tha t predict degradation rates and structural integrity effects, and the limit ed information about plant-specific conditions often make it d ifficult to make reliable predictions very far beyond the latest available measurements.

However, the working group concluded that decisions made on the basis of a proper combination of inspection results and predictive modeli ng can be successfully used to adequately control the risk to the public. The steam generator tube integrity program that has recently been dev eloped in cooperation with industry, is suggested as a model f or success in other portions of the pressure boundary components that are important to safety.

The Division Directors agree that the methods used to assess risk are adequate and data limitations need to be well understood.

An understanding of the limitations and uncertainties is necessary to make the appropriate decision. Degradation issues are not u nique with respect to the need for decision makers to carefully consider t he degree of uncertainty of and the level of confidence in the a vailable information and analytical results. But, it is more difficult than usual to do so for degradation issues, because of the greater reliance on predictive models inplace of empirical reliability data. Based on the working group findings, the evaluation recommended by DBLLTF 3.3.7(3) is con sidered complete.The Division Directors generally endorsed the working group reco mmendations and noted that the implementation of the recommenda tionsshould be consistent with the NRR/DSSA effort to assess the May 2004 GAO report on the Davis-Besse shutdown. NRR and RES will develop a strategy to implement the training identified by the worki ng group for incorporating the risk assessment results in regulator y decision-making.

The overall training and other items required to implement thes e recommendations, and the effectiveness review are projected to be completed by September 2006.