ML051390321

Reactor Oversight Process Action Matrix Deviation Request for Davis-Besse Nuclear Power Station

ML051390321
Person / Time
Site:	Davis Besse
Issue date:	05/16/2005
From:	Caldwell J L Region 3 Administrator
To:	Reyes L A NRC/EDO
References
Download: ML051390321 (5)

Text

May 16, 2005MEMORANDUM TO:Luis A. ReyesExecutive Director for OperationsTHRU: James E. Dyer, Director /RA/Office of Nuclear Reactor RegulationFROM: James L. Caldwell /RA/Regional Administrator

SUBJECT:

REACTOR OVERSIGHT PROCESS ACTION MATRIX DEVIATION REQUEST FOR DAVIS-BESSE NUCLEAR POWERSTATIONThis memorandum requests your approval to deviate from the Reactor OversightProcess (ROP) actions for the Davis-Besse Nuclear Power Station to continue heightened NRC oversight for the time period of July 2005 through June 2006. This action is necessary to continue to monitor the licensee's efforts to sustain improved plant performance following resolution of the longstanding underlying problems that culminated in a Red finding associatedwith the severe wastage that was discovered on the reactor vessel head. For Davis-Besse, we have taken actions consistent with the requirements of the IMC 0350 Process. Specifically, on May 9, 2005, the Oversight Panel issued a memo recommending return of the plant to the ROP, which will occur as of July 1, 2005. On the basis of this recommendation, I haveconsulted with the Director of NRR and the Deputy Executive Director for Reactor Programsand determined that return of Davis-Besse to the ROP is warranted.The actions we propose in this memorandum are planned for Davis-Besse for the time period ofJuly 2005 through June 2006. These actions would also allow for the discontinuance of the oversight currently being provided by the IMC 0350 Process and return of the facility to theROP described in IMC 0305. This approach is consistent with the underlying concept of the recent revision to IMC 0305, in which the NRC, through its assessment process, hasrecognized that longstanding performance issues at a plant may require a more tailored, plant-specific, follow-up over an extended period of time. NRR is in the process of changing IMC0305 to include additional inspection hours for plants exiting the IMC 0350 process.BackgroundThe Davis-Besse facility entered the IMC 0350 Oversight Process as a result of the issues thatled to the wastage of the reactor vessel head, which was discovered during the 2002 refueling outage. Programmatic breakdowns in the areas of Operations, Engineering, Corrective Actions, and Safety Culture/Safety Conscious Work Environment (SCWE), contributed to the eventual wastage discovered on the reactor vessel head.

Luis A. Reyes-2-To address the programmatic issues that resulted in the reactor head degradation prior torestart of the facility, the licensee submitted its "Integrated Report to Support Restart of theDavis-Besse Nuclear Power Station and Request for Restart Approval." This report documented specific corrective actions that were taken and commitments for actions targeting sustained performance improvement at Davis-Besse. Prior to granting restart authority to the licensee, the Agency performed special inspection activities that were sufficiently comprehensive to be in excess of that required by IP 95002 and IP 95003.The NRC concluded that the licensee had taken sufficient actions to correct the deficienciesthat led to the Red finding. To ensure lasting corrective action had been taken to improve the licensee's ability to self-assess and sustain safe performance at Davis-Besse post restart, theNRC determined that a Confirmatory Order was necessary to modify their license and require,in part, annual independent assessments for five years in the areas of Operations, Engineering, Corrective Actions, and Safety Culture/SCWE. The licensee has completed the March 8, 2004, Confirmatory Order required independentassessments for CY2004 and the Cycle 14 mid-cycle (January through February, 2005) reactorpressure vessel upper/lower head bare metal inspections. The reactor pressure vessel inspections revealed no reactor coolant system pressure boundary leakage. Inspectors alsoevaluated the results of the independent assessments and determined that they were adequateto meet the requirements of the Order. The results of the independent assessments and NRCinspection activities can be summarized briefly as follows:

!Operations performance has improved;

!Engineering performance showed some improvement but a large backlog of workremains; !While the independent assessment concluded that the implementation of the CorrectiveAction program showed marginal improvement in most areas and was rated unsatisfactory in one area (trending), the NRC's assessment concluded that thisprogram was showing improvement, and that the independent assessment had focused on activities performed before implementation of the licensee's improvement initiatives;

and !While the independent assessment concluded that SC/SCWE was stable with decliningresponses in a few areas, the NRC's assessment concluded that subsequent to themid-cycle outage, SC/SCWE had shown improved re sponse. On April 21, 2005, the Agency issued a Notice of Violation, which included the proposedimposition of a substantial Civil Penalty, and documented the final disposition of the apparent violations associated with the Red finding that had been issued to the licensee onMay 29, 2003. All inspection activities necessary to review the licensee's corrective actions for the Red finding have been completed. The only remaining open enforcement item associated with the Red finding is the receipt of the licensee's response to the Notice of Violation and proposed imposition of Civil Penalty, and the Agency's disposition of that response.

Luis A. Reyes-3-Deviation BasisBased on current plant performance and a recent White finding associated with the EmergencyPreparedness cornerstone, the licensee will transition from IMC 0350 Process to the ROPunder the Regulatory Response column of the Action Matrix, on July 1, 2005. Although the licensee's performance has continued to improve at Davis-Besse, the region believes that Davis-Besse continues to warrant additional NRC assessment. In the case of Davis-Besse, the March 8, 2004 Confirmatory Order required, in part, that theFirstEnergy Nuclear Operating Company contract with outside organizations to conduct comprehensive assessments of Davis-Besse operations performance, organizational Safety Culture/SCWE, the corrective action program implementation, and the engineering programeffectiveness. The NRC required these additional measures to provide reasonable assurancethat long term corrective actions remain effective for those conditions that resulted in the risk-significant performance deficiencies which occurred at Davis-Besse. These independent assessments provide important confirmation of the effectiveness of the licensee's self-assessments and long-term improvement actions. Therefore, the region believes that to adequately evaluate the effectiveness of the independent assessments and the licensee'sperformance in reducing their large corrective action and maintenance backlogs, continued heightened oversight at a level above the Regulatory Response Column is appropriate for Davis-Besse for the time period of July 2005 to June 2006.Deviation RequestDavis-Besse will move from NRC oversight under the IMC 0350 Process to the RegulatoryResponse column of the Action Matrix on July 1, 2005. The region requests your approval to deviate from the ROP Action Matrix to provide the following additional oversight of Davis-Besse for the time period of July 2005 to June 2006:a.Additional inspection resources for IP 93812, "Special Inspections," specificallyfor the evaluation of the Confirmatory Order Required independent assessments for CY2005 conducted in the four areas described in the Order. These four areas are Operations, Engineering, Corrective Actions, and Safety Culture/SCWE. Inspection activities associated with the performance of each Independent Assessment would include: a review of each independent assessment plan prior to the start of each assessment; an evaluation of the in-process assessment activities; and a review of each final Independent Assessment Report and the associated action plans to resolve any areas for improvement detailed in the Report. The estimated additional inspection resources required to perform these inspections would be approximately 400 additional inspection hours. Results of the inspections would be documented in the Davis-Besse resident integrated inspection reports.b.The performance of an additional Problem Identification and Resolution teaminspection (IP 71152) during CY2005. This additional inspection is necessary to monitor the licensee's performance in the areas of self assessment, problem identification, trending, and progress toward effectively reducing their large backlog of maintenance and corrective action items. In addition, the inspection Luis A. Reyes-4-would focus on follow up to the licensee's commitments and action plans thatresult from the Independent Assessments required by the Confirmatory Order.

This would also include the licensee's self-assessment results compared with the Independent Assessment results in the four areas of Operations, Engineering, Corrective Actions, and Safety Culture/SCWE. The additional inspection resources required to perform this additional inspection would be approximately 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of direct inspection. IMC 0305, Section 06.05.b.4, recognizes that up to 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of direct inspection may berequired for licensees which have been in the multiple/repetitive cornerstone column of the Action Matrix and that this additional inspection time does not constitute a deviation from the Action Matrix. Additionally, section 06.06.j, allows for one additional Problem Identification and Resolution inspection during the two year period following the quarter in which a facility reachesthe Degraded Cornerstone Column of the Action Matrix. There are no similar provisions for additional inspection resources outlined in IMC 0305 for facilities which are transitioning out ofthe IMC 0350 process at this time. However, NRR is in the process of changing IMC 0305 toinclude additional inspection hours for plants exiting the IMC 0350 process. Region III requestsa Reactor Oversight Process Action Matrix Deviation to conduct the additional inspections as described above.Approval: ________/RA/_____________ Luis A. Reyes 05/18/2005cc:B. Borchardt, NRRB. Boger, NRR C. Carpenter, NRR S. Richards, NRR R. Pascarelli, NRR G. Grant, DRA, RIII M. Satorious, DRP, RIII C. Pederson, DRS, RIII C. Thomas, SRI, RIII May 16, 2005MEMORANDUM TO:Luis A. ReyesExecutive Director for OperationsTHRU: James E. Dyer, Director /RA/Office of Nuclear Reactor RegulationFROM: James L. Caldwell /RA/Regional Administrator

SUBJECT:

REACTOR OVERSIGHT PROCESS ACTION MATRIX DEVIATION REQUEST FOR DAVIS-BESSE NUCLEAR POWERSTATIONThis memorandum requests your approval to deviate from the Reactor OversightProcess (ROP) actions for the Davis-Besse Nuclear Power Station to continue heightened NRC oversight for the time period of July 2005 through June 2006. This action is necessary to continue to monitor the licensee's efforts to sustain improved plant performance following resolution of the longstanding underlying problems that culminated in a Red finding associatedwith the severe wastage that was discovered on the reactor vessel head. For Davis-Besse, we have taken actions consistent with the requirements of the IMC 0350 Process. Specifically, on May 9, 2005, the Oversight Panel issued a memo recommending return of the plant to the ROP, which will occur as of July 1, 2005. On the basis of this recommendation, I haveconsulted with the Director of NRR and the Deputy Executive Director for Reactor Programsand determined that return of Davis-Besse to the ROP is warranted.The actions we propose in this memorandum are planned for Davis-Besse for the time period ofJuly 2005 through June 2006. These actions would also allow for the discontinuance of the oversight currently being provided by the IMC 0350 Process and return of the facility to theROP described in IMC 0305. This approach is consistent with the underlying concept of the recent revision to IMC 0305, in which the NRC, through its assessment process, hasrecognized that longstanding performance issues at a plant may require a more tailored, plant-specific, follow-up over an extended period of time. NRR is in the process of changing IMC0305 to include additional inspection hours for plants exiting the IMC 0350 process.BackgroundThe Davis-Besse facility entered the IMC 0350 Oversight Process as a result of the issues thatled to the wastage of the reactor vessel head, which was discovered during the 2002 refueling outage. Programmatic breakdowns in the areas of Operations, Engineering, Corrective Actions, and Safety Culture/Safety Conscious Work Environment (SCWE), contributed to the eventual wastage discovered on the reactor vessel head. ADAMS: Yes G No Initials: __wcw___ Publicly Available Non-Publicly Available Sensitive Non-SensitiveE:\Filenet\ML051390321.wpd*See previous concurrenceRIIIRIIIRIIINRR:DIPM:IIPB lERIIIMPhillips/slsCLipaSReynoldsJAnderson forSRichardsJCaldwell5/09/055/13/055/13/05 & 5/16/054/29/05 & 5/16/0605/16/05OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax