ML041460489

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Minutes of Internal Meeting of Davis-Besse Oversight Panel
ML041460489
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 05/21/2004
From: Grobe J
NRC/RGN-III
To:
NRC/RGN-III
References
Download: ML041460489 (18)


Text

May 21, 2004 MEMORANDUM TO: Davis-Besse Oversight Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel /RA/

SUBJECT:

MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL The implementation of the IMC 0350 process for the Davis-Besse Nuclear Power Station was announced on April 29, 2002. An internal panel meeting was held on November 4, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel, the approved RAM Closure Forms, the Closure Basis Document to Support Closure of Restart Checklist Item 5.a, the Closure Basis Document to Support Closure of Restart Checklist Item 3.i, and the Open Action Items List.

Attachments: As stated cc w/att: D. Weaver, OEDO J. Caldwell, RIII G. Grant, RIII S. Reynolds, DRP B. Clayton, EICS DB0350 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML041460489.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII RIII NAME RBaker/dtp DPassehl CLipa JGrobe DATE 05/17/04 05/20/04 05/21/04 05/21/04 OFFICIAL RECORD COPY

MEETING MINUTES: Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE: November 4, 2003 TIME: 12:30 p.m. Central ATTENDEES:

J. Grobe W. Ruland J. Stang C. Lipa A. Mendiola S. Thomas D. Passehl J. Hopkins R. Baker M. Phillips D. Hills A. Dunlop Agenda Items:

1. Discuss/Approve Todays Agenda The Panel approved the agenda, but modified the order of presentations. THE APPROVED AGENDA REFLECTS THE ORDER LISTED IN THESE MINUTES.
2. Discuss Plant Status and Inspector Insights and Emergent Issues List S. Thomas led a discussion of plant status and inspector insights and emergent issues.

High Pressure Injection pump #1 should arrive onsite next Monday, November 11, 2003.

The licensee desires to have High Pressure Injection pump #2 testing complete before the public meeting on November 12, 2004, and have both pumps operable by November 18, 2003. The licensee is still completing the Engineering Design packages.

Both Component Cooling Water coolers #4 and #5, in ECCS Room #1, have leaks.

Obtaining replacement coolers onsite may be the limiting Mode change items.

Barry Allen is onsite and is the Deputy of Operations reporting to Mark Bezilla until after restart. After restart, Barry Allen will be the Plant Manager.

3. Discuss Licensees Recent Submittal, LER 2003-010-00, Potential Inoperability of Decay Heat/Low Pressure Injection System Due to Loss of Valve Disc Pins C. Lipa led a discussion of the licensees LER 2003-010-00 submittal. This is not a Part 21 issue or a restart concern, and will be closed out in resident Inspection Report 50-346/03-22.
4. Discuss New/Potential Licensing Issues J. Hopkins reported that there are no new or potential licensing issues to report. The Panel decided that the TIA for the High Pressure Injection pumps needs to be reviewed again. J. Hopkins will send a copy of the Safety Evaluation to the Region so that a final comparison may be made to ensure all the questions have been addressed.
5. Discuss Allegations: 1) New; 2) Determine If Required to Be Resolved Prior to Restart; and 3) Requested Extensions D. Passehl discussed the status of outstanding allegations. The is one allegation which impacts restart, concerning Emergency Diesel Generator relays. R. Daley is working with the licensee to develop a time frame for resolution of this issue. D. Passehl reported that all open allegations were all on track for meeting timeliness goals.
6. Discuss RAM Closure Forms M. Phillips led a review of RAM closure items. THE RESTART ACTION MATRIX ITEMS THAT THE PANEL APPROVED FOR CLOSURE ARE ATTACHED TO THESE MINUTES.
7. Decision on Closure of Restart Checklist Item 5.a, "Review of Licensees Restart Action Plan," based on Licensees Return to Service Plan, Revision 6, Dated March 31, 2003 C. Lipa led a discussion on closure of Restart Checklist Item 5.a, based on review of inspection results and the licensees Return to Service Plan, Revision 6. The Panel discussed the fact that the Restart Checklist items focus inspection activities to address areas of concerns presented in the licensees Restart Action Plan, which are given in the Return to Service Plan. The Panel reviewed the philosophy for closure of Restart Checklist Item 5.a and the completed inspection activities to date. The Panel approved closure of Restart Checklist Item 5.a., and closure will be documented in resident inspection report 50-346/03-22. THE APPROVED CLOSURE BASIS DOCUMENT IS ATTACHED TO THESE MINUTES.
8. Brief the Panel on Maintenance Rule Inspection Preliminary Results A. Dunlop briefed the Panel on the preliminary results of the Maintenance Rule Inspection. There were no significant findings with a few observations of note. Need to clearly define the limited scope of the Maintenance Rule Inspection. The Maintenance Rule Inspection focuses on failures and subsequent actions vice actions leading to degradation. The Maintenance Rule Inspection also focuses on past, not present, events. The licensee performed actions for failure determination, looking at common causes and effects on similar equipment. The Maintenance Rule Inspection compares averages or common actions to other plants. The licensee has shifted in some areas to more of a Condition Monitoring approach than strict availability and reliability tracking.

The inspection results will be documented in resident Inspection Report 50-346/03-22, focused on Section A-3 of the Maintenance Rule.

9. Discuss Closure of Restart Checklist Item 3.i, "Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC," Based on Completeness and Accuracy Inspection Results D. Passehl led a discussion on closure of Restart Checklist Item 3.i, based on review of the Completeness and Accuracy inspection results. The Completeness and Accuracy inspection team reviewed the licensees closure packages for Restart Checklist Item 3.i.

Review of two of the LERs (LER 99-003 & 97-004) caused an extensive expansion of the licensees review. The Panel approved closure of Restart Checklist 3.1, and THE APPROVED CLOSURE BASIS DOCUMENT IS ATTACHED TO THESE MINUTES.

10. Discuss October 0350 Input - Monthly Update to Congress D. Passehl led a review of the draft input for the monthly report to congress. The Panel provided several comments which D. Passehl took action to incorporate. The revised draft will be presented at the next Panel meeting.
11. Discuss Communication Status J. Stang provided an update on the communication status. The Panel decided that the Communication Team Tracking Matrix and Email Disposition List should be updated each Friday and sent out the next Monday for review at the following Panel meeting each week.

The Panel also decided to set up a conference call this week between J. Strasma, J. Grobe, C. Lipa, A. Mendiola, and J. Stang to discuss and finalize the list of Restart Q&As. The final list will then be sent to the Regional Administrator and EDO for comments.

12. Discuss Punchlist C. Lipa led a review of the Punchlist. The Panel provided several comments and updates. More updates will be available following the weekly call with the licensee.

R. Baker took the action to update the Punchlist for the next Panel meeting.

13. Discuss Items for Licensee Weekly Calls C. Lipa led a discussion of specific issues to address with the licensee during the weekly call with the licensee. The major topics include:

a) When will NRR receive the Final HPI pump Design Modification Package?

b) What is the plan for repair/replacement of the leaking Component Cooling Water coolers, and is a Cause Analysis in progress to determine why the coolers are leaking?

c) When will the Design Package for the Breaker Modifications be completed?

d) Is the date for delivery of the draft Integrated Readiness to Support Restart Report on track? When will the final version be available?

e) Does the week of December 15 still look good for a possible Public Restart meeting?

f) Any pertinent comments from the Corporate Nuclear Review Board meeting?

14. Discuss Process Plan D. Passehl led a review of the process plan, and R. Baker took the action to incorporate the Panels comments.
15. Discuss Action Items The Panel discussed the list of open action items. No new action item were added and one open action item was closed. THE UPDATED ACTION ITEMS LIST IS ATTACHED TO THESE MINUTES.
16. Discuss/Update Milestones and Commitments The Panel reviewed and discussed upcoming milestones and commitments.
17. Discuss Draft Management and Human Performance Phase III Plan The Panel discussed the plan for the next phase of the Management and Human Performance inspection. J. Grobe will fax the specifics to NRR for budgeting.

RAM Items Approved for Closure at Panel November 4, 2003 RAM Item No. - L-76 Closed: Y Date of Letter - 11/21/02 (G-14)

Author - Gurdziel Description of Issue - Is there another leaking source of the rust trails at the bottom of the vessel rather than assuming cavity seal leakage?

Restart Checklist Item: 2.c.

Description of Resolution - In its July 30, 2003, submittal to the NRC, the licensee stated that based on evidence to date, there were four potential sources of the rust trails at the bottom of the vessel. While one of these potential sources was refueling cavity seal leakage, the others related to leakage from the refueling canal through the reactor pressure vessel (RPV) nozzle access covers, leakage from cracks found in the RPV flange O-rings monitor lines, and effluent from RPV upper-head decontamination and cleaning activities during the past Davis-Besse outages. The NRCs Office of Nuclear Reactor Regulation reviewed the licensees submittal and concluded that (1) the results of the chemical analysis do not provide conclusive evidence that the deposits observed at Davis-Besse were from IMI nozzles, and (2) the deposits observed at Davis-Besse were characteristic of deposits left by washdown from higher elevation sources. This conclusion was confirmed by the observations made by the licensee and NRC inspection of the lower vessel head after the conclusion of the NOP test, which was completed in early October 2003.

Reference Material - Licensee submittal to NRC dated July 30, 2003, (ADAMS Accession No. ML032160384) and NRC Inspection Report No. 50-346/03-23.

RAM Item No. - C-8 Closed: Y Description of Issue - Bulletins 2002-01, Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs, and 2002-02, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity, response and acceptance.

Description of Resolution - Bulletin 2002-02 was superceded by Order EA-03-009. The licensee responded to the bulletin by letters dated March 25 and 31, 2003. The NRC staff reviewed the licensees response letters and concluded that the licensees response was acceptable. Acceptability of the licensees response was documented in a letter to the licensee dated June 25, 2003.

Reference Material - Letter to licensee dated June 25, 2003 (ADAMS Accession No. ML031640072).

RAM Item No. - C-16 Closed: Y Description of Issue - Evaluate Adequacy of Lower Incore Guide Tube Penetrations - Review the licensee completed corrective actions for the as-found condition of the reactor vessel (e.g.,

boron deposits, corrosion stains, and potential for leakage at the in-core penetration tubes).

Ref. CR 02-07059 and CR 02-02498.

Description of Resolution - The licensee completed its 7-day pressure test at normal operating pressure. Inspections performed subsequent to completion of the test did not identify any boric acid leakage from any of the lower nozzles. Staff from NRR did not object to the testing methodology, which was reviewed by NRR prior to performance of the test. An NRC inspection of the licensees examination of the lower nozzles and review of the licensees results determined that there was no evidence of lower nozzle leakage. To monitor leakage while operating, the licensee has installed an online local leak monitoring system (Flü ) in the area of the lower RPV head, and perform a mid-cycle inspection of the lower head for evidence of leakage that will help to assure prompt identification of any significant RCS pressure boundary leakage should it develop.

Reference Material - Davis-Besse Unit 1 Incore Monitoring Nozzle Inspections (ADAMS Accession No. ML032510339) and NRC Inspection Report No. 50-346/03-23.

RAM Item No. - C-17 Closed: Y Description of Issue - Reactor Bottom Head - A public meeting is scheduled for November 26, 2003, in headquarters to discuss the Framatome analysis and the licensees plans are to perform a test during normal operating pressure and temperature (NOP/NOT) conditions.

Evaluate acceptability of licensees test.

Description of Resolution - In its July 30, 2003, submittal to the NRC, the licensee stated that based on evidence to date, there were four potential sources of the rust trails at the bottom of the vessel. While one of these potential sources was refueling cavity seal leakage, the others related to leakage from the refueling canal through the reactor pressure vessel (RPV) nozzle access covers, leakage from cracks found in the RPV flange O-rings monitor lines, and effluent from RPV upper-head decontamination and cleaning activities during the past Davis-Besse outages. The NRCs Office of Nuclear Reactor Regulation reviewed the licensees submittal and concluded that (1) the results of the chemical analysis do not provide conclusive evidence that the deposits observed at Davis-Besse were from IMI nozzles, and (2) the deposits observed at Davis-Besse were characteristic of deposits left by washdown from higher elevation sources. This conclusion was confirmed by the observations made by the licensee and NRC inspection of the lower vessel head after the conclusion of the NOP test, which was completed in early October 2003. The NRR staff also concluded that the licensees proposed NOP test was acceptable, in conjunction with other planned activities (installing an online local leak monitoring system (Flü ) in the area of the lower RPV head, and performing a mid-cycle inspection of the lower head for evidence of leakage), to ensure the prompt detection of any pressure boundary leakage from the lower head region.

Reference Material - Davis-Besse Unit 1 Incore Monitoring Nozzle Inspections (ADAMS Accession No. ML032510339) and NRC Inspection Report No. 50-346/03-23.

RAM Item No. - SUP-38 Closed: Y Description of Issue - Assessment of Performance in the Reactor Safety Strategic Performance Area: Key Attribute - Human Performance: Review specific problem areas and

issues identified by inspections to determine if concerns exist in Control of Overtime and Fatigue.

Description of Resolution - The inspectors reviewed approximately 24 CRs, 130 overtime deviation requests, and had discussions with representatives from Nuclear Quality Assessment and senior Davis-Besse management. Based on the information evaluated, the inspectors concluded that the licensee was meeting regulatory requirements in regard to the control of overtime for personnel during an extended outage. The inspectors found a number of issues where management expectations, which were also described in the inspection report, were not being met regarding the control of overtime or the implementation of the overtime deviation process. However, the inspectors did not identify any significant issues that involved personnel performing safety-related functions.

Reference Material - Inspection Report No. 50-346/03-17 (ADAMS Accession No. ML032721592).

RAM Item No. - LER-18 Closed: Y Description of Issue - Loss of offsite power due to grid disturbances.

Description of Resolution - As a result of the loss of power, the diesels started and restored station vital loads. However, as a result of stopping and automatic restarting of the Service Water Pumps, a pressure transient was experienced in the Service Water System which caused a gasket leak on a Component Cooling Water (CCW) Heat Exchanger and distortion of Containment Air Coolers (CAC) expansion bellows. The licensee attributed the distortion of the CAC Service Water piping expansion bellows to an inadequate hydrodynamic transient analysis which under-predicted the peak pressures that would occur for a loss of offsite power condition.

The Service Water system leakage from the end bell of the CCW Heat Exchanger 3 was attributed to the inadequate thickness dimensions of the gasket material installed during the current extended outage. Corrective actions implemented included the replacement of the expansion bellows for all three CACs and the installation of the appropriately sized gasket on CCW Heat Exchanger 3. In addition, the licensee modified the valving to the CACs to significantly reduce the potential for water hammer in the service water supply to the CACs.

These issues have been entered into the licensees corrective action program as CRs 03-06590, 03-06597 and 03-06651.

Reference Material - Inspection Report No. 50-346/03-22.

RAM Item No. - NCV-18 Closed: Y Description of Issue - Failure to Properly Implement Work Instructions During the Reinstallation of Electrical Conduit and the Electrical Termination of Operating Power and Indication Power to RC4608A and RC4608B (loop 1 reactor coolant system high point vent valves). Closed in same report.

Description of Resolution - The performance deficiency associated with this event was the failure to correctly implement procedures which directed maintenance activities which removed/installed electrical power to safety related equipment. The inspectors reviewed the corrective actions implemented associated with condition report (CR) 03-03427, RC4608A and RC4608B Are Not Wired Properly. The inspectors determined that the corrective actions

associated with this CR had been implemented and appropriately addressed the causes of the performance deficiency. The inspectors also reviewed the outstanding corrective action and determined the due date assigned to this action was appropriate.

Reference Material - CR 03-03427, RC4608A and RC4608B Are Not Wired Properly.

RAM Item No. - NCV-20 Closed: Y Description of Issue - Inadvertent Operation of DH7A and DH7B Caused By Inadequate SFAS Component Testing Procedure. Closed in same report.

Description of Resolution - The performance deficiency associated with this event was the failure to develop adequate procedures for testing SFAS components. The inspectors reviewed the corrective actions associated with condition reports (CR) 03-02554, DH7B Opened Unexpectedly, and CR 03-02571, DH7A Opened After Testing Was Complete. The inspectors determined that the corrective actions associated with these condition reports had been implemented and appropriately addressed the causes of the performance deficiency.

Reference Material - CR 03-02554, DH7B Opened Unexpectedly, and CR 03-02571, DH7A Opened After Testing Was Complete.

RAM Item No. - NCV-21 Closed: Y Description of Issue - Failure to Provide Adequate Procedural Guidance for Tightening Fasteners Internal to the High Pressure Injection Pump.

Description of Resolution - The performance deficiency associated with this event was the failure to provide adequate procedural guidance in a safety-related maintenance procedure which provides guidance for tightening fasteners internal to the high pressure injection pump.

The inspectors reviewed the corrective actions associated with CR 03-04278, Broken Bolting Found in High Pressure Injection Pump #1. The inspectors determined that the corrective actions associated with this CR had been implemented and appropriately addressed the causes of the performance deficiency. The inspectors also reviewed the outstanding corrective actions and determined the due dates assigned to these actions were appropriate.

Reference Material - CR 03-04278, Broken Bolting Found in High Pressure Injection Pump

  1. 1.

RAM Item No. - NCV-22 Closed: Y Description of Issue - Failure to Perform Work in Accordance With Approved Maintenance Procedures During the Installation of Reactor Coolant Pump Mechanical Seal RTDs.

Description of Resolution - The performance deficiency associated with this issue was the failure to perform work in accordance with approved maintenance procedures. The inspectors reviewed the corrective actions associated with CR 03-04773, RCP/RTD Installation Not In Accordance With Vendor Manual. This CR was classified by the licensee as a Significant Condition Adverse to Quality. The inspectors determined that a majority of the corrective actions associated with this CR had been implemented and appropriately addressed the causes

of the performance deficiency. The inspectors also reviewed the outstanding corrective actions and determined the due dates assigned to these actions were appropriate.

Reference Material - CR 03-04773, RCP/RTD Installation Not In Accordance With Vendor Manual.

Nov. 4, 2003 Panel Briefing Paper Restart Checklist Item 5.a, Review of Licensees Restart Action Plan For the Panels review of this restart checklist, it is recommended that the panel be familiar with Section G of the licensees Return to Service (RTS) Plan, dated March 31, 2003, and consider several activities that have taken place by the licensee and NRC since the RTS plan was initiated.

Section G, Restart Action Plan, describes the licensees building block, the charter of this plan is described as:

Administer the identification, coordination, monitoring, and closure of actions required to meet all Company-identified objectives and requirements under the Davis-Besse RTS Plan.

Specific Activities credited in the plan and NRC associated actions are described below:

Licensee Activities Associated NRC Activities Establish the process and criteria for NRC Inspections (IR03-02&03-04) - see evaluation of CRs attached excerpt RSRB - identify and classify items NRC Inspections - see attached excerpt Senior Management Team - approve NRC Inspections - see attached excerpt addition of items to licensees 0350 list Restart Readiness Reviews NRC Resident Inspection (IR ) + Phase 3 Inspection 12 Restart Oversight Panel 0350 Panel member attendance for observation/evaluation Engineering Assessment Board - NRC evaluation of EAB during Programs evaluate Building Block Action Plans (IR02-11) and System Health (IR02-13)

Closure/approval of activities associated NRC discussions with licensee at weekly phone with building blocks calls and public monthly meetings.

Also, specific inspections related to other restart checklist items.

Below is an excerpt from Resident Inspection IR 03-04:

.3 Classification, Categorization, and Resolution of Restart Related Issues The resident inspectors continued to monitor the licensee activity related to properly classifying, categorizing and resolving their backlog of work orders, corrective actions, and modifications required to be completed prior to transitioning to Mode 5 and 4. To accomplish this, the inspectors:

Nov. 4, 2003

 attended and assessed licensee management meetings;

 monitored the management of open Mode 5 and 4 restraints;

 evaluated the licensee classification of emergent deficient conditions; and

 evaluated closed mode restraints.

As part of this inspection, the inspectors attended selected Mode Change Readiness Review meetings, Senior Management Team meetings, Management Review Board meetings, and Restart Station Review Board meetings where classification of CRs, prioritization of work activities, and setting of work completion dates took place. Specific items noted by the inspectors during these meetings included:

 a large number of issues that originally were classified as Significant Conditions Adverse to Quality (SCAQ), were downgraded to Conditions Adverse to Quality (CAQ);

 approximately 17 percent of the Design Engineering issues discussed at a Mode Change Readiness Review meeting and approximately 33 percent of the Plant Engineer issues discussed at another Mode Change Readiness Review meeting had work completion dates moved up to align the completion of the work activities with current milestone schedule; and

 Some rolling up of multiple CRs and corrective actions into single CRs was noted.

The inspectors evaluated a sampling of CR downgrade documentation forms associated with the SCAQs that were downgraded to CAQs and a sampling of CRs that resulted from the rolling up process.

No significant issues were identified by the inspectors. The process of adjusting work activity completion dates so that milestone dates were met, alone, was not an issue.

The inspectors continued to evaluate, on a day-to-day basis, the impact that scheduling had on quality of work and safety conscious work environment. No significant issues were identified.

Restart Checklist Item 3.i, Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC EXTENT OF CONDITION REVIEWS PERTAINING TO THE MATERIAL OMISSIONS/INACCURACIES REVIEW PROJECT The licensees Project Plan requires FENOC to increase the review sample size if any of the original documents contained statements that are inaccurate or incomplete in any material respect. The Project Plan requires that the sample size for that category of documents be expanded to include another 20 percent. If more than one document in that category contained statements that are inaccurate or incomplete in any material respect, then the balance of documents within the category (submitted between January 1996 and March 2002) will be verified.

Based on the licensees reviews, FENOC will perform additional reviews on the following documents by March 31, 2004:

Number (percentage Document Type of total population)

Licensee Event Reports1 39 (100)

License Amendment Requests2 9 (20)

Responses to Generic Letters3 5 (20)

Total: 53 1

Sample expanded based on two LERS: LER 99-003 (excessive cooldown not mentioned in previous LER - Minor Violation) and LER 97-004 (deleted paragraph regarding RCP lube oil - Apparent Violation) 2 Sample expanded based on LAR 96-0008, "License Amendment Application to Revise Technical Specification 3/4.7.5.1, Ultimate Heat Sink". Issue involved EQ equipment stated to be have a qualified life of approximately 1 year or greater but further review found at least one instrument that was qualified for about 0.58 years. SL IV violation.

3 Sample expanded based on GL 98-04 response (Coatings). Probably SL III violation.

The licensee reviewed 70 regulatory submittals that contained over 2,200 statements of fact. In addition, questionnaires were distributed via a site-wide e-mail, which requested personnel to identify any submittals to the NRC that may have contained incomplete or inaccurate information. FENOC determined that none of the issues resulted in significant implication for public health and safety or common defense and security.

As a result of the issue in LER 97-004 (deleted paragraph regarding RCP lube oil), FENOC performed a review of 286 documents that were prepared, revised, or submitted by the individual responsible for the material omission. FENOC determined that none of the issues resulted in significant implication for public health and safety or common defense and security.

The licensees argument is, when considered together, the material inaccuracies/omissions identified during these reviews indicate that there were no widespread noncompliances or programmatic concerns associated with the preparation, review, and submittal of regulatory correspondence at Davis-Besse. The reviews did not identify any issues having significant implications for public health and safety or common defense and security. (The licensee states that the past material false statements in GL 98-04 on coatings is not a current issue affecting public health and safety or common defense and security.)

Under the Davis-Besse Return to Service Plan, FENOC has conducted extensive reviews to verify that its systems, programs, and organizations are ready to support safe and reliable operation. These reviews included reviews under the Systems Health Assurance Plan to provide additional assurance that plant systems can perform their safety functions. Given the results of the Completeness and Accuracy Review together with the results of the reviews under the Return to Service Plan, there is reasonable assurance the plant can be restarted and will operate: (1) without endangering the public health and safety or common defense and security; and (2) in compliance with applicable NRC regulations and requirements.

Going forward, FENOC has taken several actions to ensure that future regulatory submittals are complete and accurate in all material respects. For example, the licensee revised its procedure for regulatory submittals to ensure that they be properly validated before the submittal can be issued. Site supervisory personnel have been given training to ensure that they are cognizant of the requirements of 10 CFR 50.9 and the implications of not complying with those requirements. New employees will also receive training on the requirements of 10 CFR 50.9 as part of their New Employee Orientation. New supervisory personnel will also be trained on management responsibilities related to completeness and accuracy.

November 4, 2003 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 138 Evaluate the effectiveness A. Mendiola, C. 01/31-Ongoing; 02/21-New EDO Comm of the Comm Plan (01/07) Lipa Plan for Crisis Update, A. Mendiola to review for inclusion; 10/14-Discussed, The new revised Comm. Plan is with the Panel Chairman for review. This item will be closed upon approval of the revised plan; 10/28-Comm Plan is to Regional Administrator for approval.

147 Generate a list of items to D. Passehl 01/31-Working; consider after restart as well 02/11-Include dates and deadlines to as transition back to the Manual Chapter 0350 restart inspections normal 0350 when planner; 07/0-Discussed; 7/22-Dave has list terminating the 0350 Panel. with Christines comments; 08/05-Discussed.

The items should include Bring back 6 weeks; 09/23-Discussed; plans to augment inspection 09/30-The Panel decision is to separate this of corrective actions, into three distinct listings: Inspection inservice inspection, and Schedule items for both prior to and safety culture monitoring. following restart; Focus Areas for post (01/09) restart; and 0350 Panel termination criteria.

The Panel will approve listings; 10/14-Discussed, The inspection schedules and focus areas for post restart are incorporated in the punch list. When developed, the listing for 0350 Panel termination criteria will be presented to the Panel for approval.

197 Develop a communication J. Stang 6/24-Lead changed; 08/21-Lead changed; plan with restart Qs and As. 09/30-Discussed, list of Q & As is being (06/17) gathered for review and forwarding to RA; 10/14-Discussed, J. Shea is compiling the list of Q & As for review by the Panel and results will be forwarded to the RA; 10/21-Brainstorming session to occur 10/23 to final presentation to Panel; 11/04-Discussed, J.

Strasma will have draft Q&As drafted by 11/07.

202 Put a discussion of the J. Strasma 10/14-Discussed, Information surrounding actions the NRC took in this issue will be collated and discussed at a reviewing concerns future meeting; 11/04-Discussed, will put in involving the reactor coolant the November 2003 Newsletter.

pumps in the August 2003 newsletter. (07/15) 208 Evaluate the need to call M. Phillips 10/14-Investigation is still ongoing.

back CI regarding Allegation RIII-2002-A-0177 (D-B) after the OI Investigation is complete (08/21)

November 4, 2003 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 211 (a) Issue a status report of J. Jacobson 10/09-Discussed; Mr. Jacobson provided the the NOP test results thus Panel with an update on the licensees far; (b) Issue a status report progress to date. Draft status reports are after the NOP inspection of pending; 10/14-Discussed, This issue will be record has been completed; completed by licensee 10/15, and the results (c) Issue a status report will be presented to the Panel within the next after the upper reactor 2 weeks; 10/28-Mr. Jacobson will brief the vessel head and lower Panel on 11/06, following final week at site, reactor vessel head tests with results.

are completed. The reports are to be forwarded to NRC Division of Engineering personnel. (09/23) 212 Determine whether the J. Stang 10/14-Discussed, Set of bullets still under Communication Team has development; item will be discussed at next received all electronic and Panel meeting on 10/16; 11/04-Discussed, J.

written correspondence from Stang will add this item to the Comm. Team external sources. If there is tracking matrix and send J. Grobe the draft reasonable confidence that set of bullets.

the Communication Team has all the correspondence then develop a set of bullets explaining why there is reasonable confidence.

(09/23) 213 Update the punch list that C. Lipa 10/14-Discussed, Milestones are still being will be used to ensure that developed using 12/15/2003 as a NRC activities necessary for reasonable target date for restart and restart are accomplished completed matrix will be presented to the with intermediate steps and Panel next week; 10/21-Punch list has been their due dates. (09/25) added as a Standing Item to the Panel Agenda for ongoing update and discussion.

214 Discuss with Region III C. Lipa 10/14-Discussed, The preliminary decision is Public Affairs Officers that it is not appropriate to respond via the whether to include a NRC newsletter; final disposition is pending; discussion of the September 11/04-Discussed, final resolution is to not 20, 2003, rally sponsored by include discussion in the NRC Newsletter.

the Union of Concerned The Panel decided that this item is Closed.

Scientists in the next monthly NRC newsletter.

(09/25)

November 4, 2003 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 216 Submit a TIA which J. Lara 10/14-The TIA has been submitted to the addresses issues and Branch Chief for review; 10/21-The TIA is questions related to the with A. Mendiola; 10/28-Held telephone licensees 1991 10 CFR conversation yesterday for obtaining Appendix R exemption information.

request regarding Alternative Shutdown (ASD) regulations. (10/02) 217 Review and document the S. Thomas 10/14-Discussed, This review is ongoing and acceptability of the will be documented in Inspection Report 03-licensees withdrawal of the 22.

single safety group of control rods to provide a prompt trip response source of negative reactivity. The review will be documented in a resident inspection report. (10/09) 219 Brief Jim Caldwell on how S. Thomas 10/28-Brief will include research information Immediate Action on Exelon approach.

Maintenance issue was resolved. He would like to see the revised procedure.

(10/21) 220 Develop inspection plan D. Passehl requirements which include review of post restart security program effectiveness. (10/28) 221 Research use of a Quick D. Passehl 11/04-Discussed, suggestion was made to Look letter which formalizes send an email to S. Collins for assistance.

preliminary inspection results prior to final report being issued to address urgent Restart decision issues. (10/28) 222 Develop a list of Qs and As J. Strasma 11/04-Discussed, conference call set up for for the CATI discussion later today.

during the November 12, 2003 public meeting.

(10/30)

November 4, 2003 DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST Item Action Item (Date Assigned to Comments Number generated) 223 Develop a list of Qs and As J. Strasma for discussions on the October 17, 2003, NRC Inspector General Report, Event Inquiry Regarding NRCs Oversight of Davis-Besse Boric Acid Leakage and Corrosion During the April 2000 Refueling Outage, for use during the November 12, 2003 public meeting. (10/30)