ML030920538

Minutes of Internal Meeting of Davis-Besse Oversight Panel

ML030920538
Person / Time
Site:	Davis Besse
Issue date:	03/31/2003
From:	Grobe J NRC/RGN-III
To:
References
Download: ML030920538 (45)

Text

March 31, 2003 MEMORANDUM TO: Davis-Besse Nuclear Power Station IMC 0350 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 March 14, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel, the Corrective Action Implementation Team Inspection Plan and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Dyer, RIII J. Caldwell, RIII K. Coyne, NRR D. Thatcher, NRR DB0350

MEMORANDUM TO: Davis-Besse Nuclear Power Station IMC 0350 Panel FROM: John A. Grobe, Chairman, Davis-Besse Oversight Panel

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 March 14, 2003. Attached for your information are the minutes from the internal meeting of the Davis-Besse Oversight Panel, the Corrective Action Implementation Team Inspection Plan and the Open Action Items List.

Attachments: As stated cc w/att: H. Nieh, OEDO J. Dyer, RIII J. Caldwell, RIII K. Coyne, NRR D. Thatcher, NRR DB0350 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML030920538.wpd To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy OFFICE RIII RIII RIII NAME D.Passehl/klg /RA DPassehl JGrobe Acting for/CLipa DATE 03/31/03 03/31/03 03/31/03 OFFICIAL RECORD COPY

MEETING MINUTES: Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE: March 14, 2003 TIME: 9:00 a.m. Central ATTENDEES:

J. Grobe J. Hopkins M. Phillips C. Lipa D. Passehl R. Gardner C. Thomas Agenda Items:

1. Discuss Corrective Action Team Inspection Plan Z. Falevits presented the Corrective Action Team Inspection Plan. The Panel approved the plan with clarification of Objective 10. The approved plan is attached to these minutes.

2. Plant Status and Inspector Insights C. Thomas provided a briefing on current plant activities.

3. Discuss Potential Concern Regarding NRCs Follow-up of Post-restart Items The panel discussed a concern raised by a member of the NRR staff regarding tracking of corrective action items classified as "post-restart." The Panel determined that the follow-up of items for post-restart is adequately addressed with existing NRC programs and processes. Also, the Panel previously directed that a listing of issues be maintained for consideration at some future time when the Panel is terminated.

5. Discuss Action Items The Panel discussed the list of open action items. No action items were closed.

6. Discussion of Licensing Issues and Actions J. Hopkins discussed the status of licensing issues and actions. No new items were identified.

7. Discuss Items for Licensee Weekly Calls The Panel discussed discussion topics for the next weekly call with the licensee.

8. Discuss/Update Milestones and Commitments The Panel reviewed and discussed upcoming milestones and commitments. No new items were identified.

Item Action Item (Date Assigned to Comments Number generated) 24a Discuss making Panel Discuss by June 30, after safety information related to significance assessment complete; HQ/licensee calls publicly 6/27 - Invite Bateman to panel mtg.

available To discuss what else is needed to closeout the CAL (i.e. quarantine plan); 7/2 - NRR not yet ready to discuss; 7/16 - See if procedures have changed on CAL closeout -

does JD need to send letter?; 7/18

- Discussed - is there an applicable regional procedure?; 8/6 -

Discussed. Need to determine the final approach on the core removed from the head and the final approach on the head before the quarantine can be lifted; 8/22 -

Revisit action item after letter sent to licensee confirming plans with old vessel head (head may be onsite longer than originally anticipated); 8/29 - Memo to be sent to Region, with a letter to go out next week; 10/01- Discussed.

1) Conduct NRC staff survey-due 10/7 2)Memo to NRR - due 10/11

3) Region to issue letter; 11/07-Letter required from NRR on head quarantine status; 11/19 - Letter in draft; 01/03 - A. Mendiola to look at phone conference writeups on quarantine decision making to determine if they can be released to the public; 01/07 - discussed; 01/21 - discussed; 01/31- A.

Mendiolas action; 02/11 -

Completion of Licensee Phase 3 sampling plan required; 02/21 -

17.5 Rem to cut samples, Less samples may be required

Item Action Item (Date Assigned to Comments Number generated) 54a Review TSP amendment D. Pickett 7/9 - Discussed. Will wait for and advise the panel on response from licensee; 7/16 -

the need for a TIA on Discussed - added action item 54b; Davis-Besse (7/2) 8/6 - Sent to the licensee on 7/22 and a response is due by 8/22; 8/22 - Discussed - need to check if response has been received; 8/27

- Received response - DRS is reviewing - will fax to NRR for 54b; 8/29 - Discussed, DRS report of response to be issued to panel prior to item 54b; 10/1-Discussed.

DRS coordinating with NRR 11/07-Discussed - On hold for draft with specific information; 12/10 - B.

Dean believed B. Bateman thought a calculation for sufficient volume of TSP was completed to technical specification value. However questions whether the calculation was to technical specification or actual TSP level remain; 01/03 -

Item under NRR review.

Calculation completion expected on Jan 17. Allegation issue in RIII domain; 01/07 - Allegation Item #3 under NRR Review for Resolution; 01/21 - Item #3 is under Region III control for final letter, holding for NRR input; 02/11 - Writeup for NRR input provided 4 answers, going back to reviewer to ensure specific tasking is clear to answer allegation concerns. Action item 54c created; 02/21 - Allegation at 242 day mark. Effective expression of due date required 54c In relation to action item A. Mendiola 02/11 - Address first meeting in 54a - Assess method to March ensure Technical Specifications are adequate for a cycle, administrative controls vs.

amending technical specifications (02/11)

Item Action Item (Date Assigned to Comments Number generated) 73 Send feedback form on Lipa 8/6 - Generate feedback after IMC 0350 procedure to Mendiola panel meetings reduced to once IIPB (8/6) per week; 8/29 - Discussed - no change; 10/1 - Discussed; 11/7 -

D Passehl sent email to C Carpenter and D Coe indicating that we would be able to perform a review of the draft IMC 0350 during the first quarter of 2003; 12/3- discussed; 01/03 - 2 parts, short part- C. Lipa with P. Harris, long part- B. Dean; 01/07 - 2nd larger response will require meeting between all parties; 01/21

- Communications with P. Harris; 01/31-Meeting with P. Harris on Feb 4; 02/11 - Many concerns identified by the panel for inclusion; 02/21 - July 1 due date for larger input.

97 Bulletins 2002-01 and NRR 11/07 - Discussed, further 2002-02 response and research and discussion required; acceptance (9/5) 01/07 - RAI response expected Mid February; 01/31- On track; 02/11 - New Orders will supercede BL2002-01 and BL2002-02 responses with the exception of the BL2002-01 Boric Acid Corrosion program information request; 02/21 - Licensee RAI response delayed. Both Order and BL2002-01 Boric Acid Corrosion program responses to be tracked as RAM items.

126 Review Davis- Strasma Besse/Vessel Head 02/11 - Checked, but revisiting Degradation web site item; 02/21 - Web site being content for ease of use by reassessed.

the public. (11/07)

Item Action Item (Date Assigned to Comments Number generated) 127 Decision of the extent of W. Dean 12/10 - Completion date the needs for resolution of requested; 12/19 - Discussed -

the technical root cause Est. delivery Jan. 31st, put in Jan-(11/19) Feb report 03-02; 01/31 - On track; 02/21 - J. Hopkins has the review.

Through comprehensive review, A.

Hiser determined OI concerns did not effect the technical root cause.

Attachment of Technical Root Cause Review on next Inspection Report 132 Consolidate RAM (12/19) C.Lipa/ Due Fri 1/17; 01/31 - Item open; A.Mendiola 02/11 - working; 02/21 - to determine the need for ONE list.

133 12/29 Taping of debate J.Collins/ 01/03 - Licensee to deliver tape to D.Simpkins J. Strasma; 02/24 - Tape sent 136 NRR acceptance of NOP W. Dean 01/07 - Item discussed. Meeting criteria and method summary of November 26, 2002 (01/03) meeting has notation of NRR staff impressions of test plan. Once drafted, issue will be surveyed to staff to determine if consensus is correct; 01/21 - Meeting summary to discuss Flus System, Test agreement, and future inspections; 1/31 - T. Chan fwd to J. Hopkins; 2/11 - J. Jacobson questions need to be folded in (chem-wipes); 2/21

- Polling of staff discussed; 2/24 -

Polling of staff by March 7 138 Evaluate the effectiveness A. Mendiola, 01/31 - Ongoing; 02/21 - New EDO of the Comm Plan (01/07) C. Lipa Comm Plan for Crisis Update, A.

Mendiola to review for inclusion.

143 Prepare a special J. Jacobson 02/21 - date to be determined inspection plan for the NOP test. (01/09) 144 Prepare a special D. Hills 01/31 - Working Z. Falevits and R.

inspection plan for the Gardner; 02/21 - date to be corrective action team determined; 03/04 - plan discussed inspection. (01/09) and comments to be incorporated; 03/14 - Closed.

Item Action Item (Date Assigned to Comments Number generated) 145 Prepare a special D. Passehl 02/21 - date to be determined inspection plan for the restart readiness team inspection. (01/09) 147 Generate a list of items to D. Passehl 01/31 - working; consider after restart as 02/11 - Include dates and well as transition back to deadlines to Manual Chapter 0350 the normal 0350 when restart inspections planner terminating the 0350 Panel. The items should include plans to augment inspection of corrective actions, inservice inspection, and safety culture monitoring.

(01/09) 149 SRI to coordinate with S. Thomas 01/31 - open; 02/11 - Documented GWright inspection of items in Resident Inspection corrective actions that Report; 02/21 - Good have been completed by communications noted; the resident staff. The Documentation in IR03-02 intent is to find ways to allow GWrights inspection to take credit for what the resident staff already accomplished. (01/09) 150 SBurgess to develop a S. Burgess position paper on the state of plant risk when the plant attains Mode 4 for the first time. The purpose is to support NRC scheduling of major inspections until closer to Mode 2. (01/09) 151 Develop a plan to assess G. Wright the safety culture at the plant to close Restart Checklist Item 4.b, effectiveness of corrective actions. Discuss at next 0350 internal Panel meeting. (01/09)

Item Action Item (Date Assigned to Comments Number generated) 154 Marty has action to M. Farber 02/21 - Date to be determined followup by 1/21 with licensee to understand licensees actions to address common mode failure issues (i.e., topical issues) and brief Panel.

Then develop inspection plan to address topical issues. (01/09) 156 Read Generic Safety J. Hopkins 01/21 - Determine status of GSI-Issue-191, "Assessment of 191; 02/21 - Check GL98-04 Debris Accumulation on response on coatings. Draft GL PWR Sump Pump and Draft Reg Guide needs review Performance" (01/09) for DB relevance; 02/24 - Request Response Review and Program Implementation to GL98-04; 03/04

- activity to be reassigned to Reactor Engineer who will close sump LER 158 In Ken OBriens D. Hills/ 02/25 - Plan for Programs, part 2 programmatic inspection J. Jacobson brought to panel - comments to be plan, add to the summary incorporated.

page the addition of Restart Checklist Item 3.i, Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC, and deletion of Item 3.h, Radiation Protection Program.

(01/09) 162 Modified Containment P. Lougheed 02/21 - Factor into ILRT plan Walkdown List assessment to look into effects on ILRT and NOP/NOT tests. (01/21) 163 Flag Allegations requiring M. Phillips 02/11 - All of them require action.

action prior to restart Resolve with one letter including (01/21) Item 164; 02/21 - Develop criteria for Allegations considered Restart Items. Criteria needs Panel approval.

Item Action Item (Date Assigned to Comments Number generated) 164 Discuss the need for a M. Phillips 01/31 - Pre-work and then ARB; Chilling Effect Letter with 02/11 - Resolve with one letter Bruce Berson (01/21) including Item 163; 02/21 - Draft letter with C. Lipa, emailed to Panel for review; 166 Once DRS has developed Panel 02/11 - currently in planning; 02/21 a draft CY-2004 baseline - inspection schedule letter due as inspection schedule for soon as possible; 03/04 - in final Davis-Besse (in conjunction with the upcoming regional inspection planning meeting), DRS will present this to the 0350 panel for review. (01/31) 172 Create a schedule letter to 02/11 - Panel determined that replace/notify that annual Annual Assessment letter and End assessment letter and end of Cycle public meetings not of cycle public meetings occurring.

are not occurring (02/11) 173 Prepare an OSHA MOU S.Thomas 02/21 - D. Simpkins working letter based on email dated 2/6 from Bilik (2/18) 174 Review 2/4 transcript for R. Lickus Mr. Witts recommendations (2/18) 175 LER licensee commitment J. Hopkins 02/21 - Attempt to get by end of on Containment Air Cooler February; 03/04 - Licensee wrote Supplement for 01/31/03 CR to address missed commitment (02/21) 176 Determine which C. Lipa inspection will cover containment coatings (03/04)

Item Action Item (Date Assigned to Comments Number generated) 177 Research IMC0620 and D. Passehl determine what agency policy re: placing inspection plans on ADAMS, including when (e.g., before or after conduct of inspection) does the plan need to be posted. (03/04) 178 Determine the type of C. Lipa backlog assessment that will be performed and by whom. Two attributes need to be considered: (1) the capability of the licensee to manage the backlog in an operating environment; and (2) the impact of the backlog on equipment reliability.

(03/04) 179 Provide answer to S. Thomas questions and document in next inspection report:

1} Did NRCs O350 Panel review FirstEnergys analysis to forego inspection and testing of two of the four reactor coolant pumps to assure compliance with technical specifications and regulatory requirements?

(RAM Item E-23)

2) If so, what were the NRC findings? (RAM Item E-24) (03/04) 180 Draft a memo to NRR D. Passehl (Tad Marsh) to include in response to AMS RIII 0014 (Kucinich Petition) that RIII reviewed the petition and there are no new technical issues.

(03/04)

INSPECTION PLAN CORRECTIVE ACTION IMPLEMENTATION TEAM INSPECTION Davis-Besse Nuclear Power Station Inspection Report Number 50-346/2003010(DRS)

(Do not share this Inspection Plan with the licensee)

Inspection Objectives The 0350 Oversight Panel established for Davis Besse determined that a comprehensive review by the NRC was needed to assess the implementation of the licensees upgraded corrective action program. This is required to determine the effectiveness of the corrective action process in identifying, correctly assessing, and promptly correcting risk-significant findings.

In addition, this inspection will fulfill the baseline inspection program requirements for the biennial portion of inspection procedure 71152 (Identification and Resolution of Problems). The biennial inspection objectives are to provide an assessment of the effectiveness of licensee problem identification and resolution (PI&R) programs, including problem identification, evaluation, and resolution, based upon a performance-based review of specific issues; to look for instances where the licensee may have missed identifying potential generic concerns, including specific problems involving safety equipment, procedure development, or design control; and to assess whether conditions exist that would challenge the establishment of a safety conscious work environment. In addition, the team will also use applicable inspection guidance delineated in IP 93812 (Special Inspection).

Inspection Dates: March 17-21, March 31 to April 4, and April 14-18, 2003 EXIT: April 18, 2003, at 10:30 a.m..

Applicable Inspection Procedures IP 71152, Identification and resolution of problems IP 93812, Special Inspection Prepared by: /RA/

Zelig Falevits and Martin J. Farber Electrical Engineering Branch Reviewed by: /RA/

Ronald N Gardner, Chief Electrical Engineering Branch Reviewed by: /RA/

Christine A. Lipa, Chief Reactor Projects Branch 4 Approved by : /RA/

John A. Grobe, Chairman Davis-Besse Oversight Panel

INSPECTION PLAN DETAILS I. Inspectors Z. Falevits, Team Leader M. Farber, Assistant Team Leader P. Lougheed, Senior Reactor Engineer A. Walker, Senior Reactor Engineer J. Panchison, Mechanical, Consultant W. Sherbin, Mechanical, Consultant F. Baxter, Electrical, Consultant W. Bennett, Corrective Action, Consultant II Detailed Inspection Schedule Preparation and Inspection Activities Team Leader Preparation: March 3-14, 2003 Team Inspection Preparation at Region III offices: March 10-14, 2003 Entrance Meeting: March 17, 2003 On-site Inspection Weeks: March 17-21, March 31 to April 4 and April 14-18, 2003 Exit Meeting: April 18, 2003 Licensee Contacts Regulatory Affairs: Joe Sturdevant Corrective Action: David Gudger Inspection Documentation Inputs Due: April 25, 2003 Draft Completed: May 7, 2003 Management Review and Approval Completed (target): May 28, 2003 An inspection report must be issued before June 2, 2003 (45 days from the exit)

III Lead Inspector Preparation Activities Information Requests As part of the inspection preparation, the team leader listed selected corrective action documents in tables below. The team will select the documents to be reviewed. In addition, the team leader will request the required information from the licensee and will ensure that the necessary information be conveyed to the inspection team.

If during the preparation week, additional information is determined to be necessary, please inform the team leader.

IV Team Preparation Activities Review of Material Each team member will review the licensee administrative procedures that control the identification, evaluation, and resolution of problems. These documents will be reviewed

to provide sufficient knowledge of the licensees revised corrective action program and process, as necessary to conduct an effective and efficient inspection.

Each team member will review documentation on licensee efforts to identify, resolve and prevent structure, system, and component performance problems through performance monitoring, root cause analysis, cause determination, and corrective action to meet the monitoring requirements of the maintenance rule (10 CFR 50.65).

Preparation Meetings A team meeting will be held Monday, March 10, 2003, at 1:00pm. In this team meeting, the team leader will discuss the inspection plan and distribute available information provided by the licensee and specific inspector items for review and follow-up.

Additionally, during this meeting, the team leader will go over inspection logistics and answer team questions.

Over the next several days, each inspector, including the team leader shall review the provided documentation and select additional corrective action items to be reviewed.

Also, each inspector will become familiar with the requirements of the applicable NRC IPs.

Requests for Additional Information As soon as possible, but no later than noon on March 12, 2003, team members should provide to the team leader a list of any additional information and/or documents they want to have readily available on the first day of the inspection. The team leader will coordinate with the team members to ensure there is no duplication of efforts.

Selection of Specific Items for Review The samples chosen for review should include a range of issues including:

1. Licensee identified issues (including issues identified during audits or self assessments);

2. NRC identified issues;

3. Issues identified through NRC generic communications;

4. Issues identified through industry operating experience exchange mechanisms (including Part 21 reports, NSSS vendor reports, EPRI reports, experience reports from similar facilities, LERs);

5. Specific or cross cutting issues identified by safety review committees or other management oversight mechanisms;

6. Issues identified through employee concerns programs V. Inspection Objectives The main objectives of the Corrective Action Team Inspection (CATI) are:

(1) To determine if the corrective action process at Davis Besse is being effectively implemented to identify risk-significant conditions adverse to quality and if appropriate corrective action is taken to prevent recurrence of identified problems.

(2) To determine if licensees identified problems in risk-significant systems were evaluated using a systematic method(s) to identify the correct root cause(s) and contributing cause(s).

(3) To evaluate licensee's implementation of the corrective action program to address identified issues including determination of root cause(s), apparent cause(s), potential common cause(s), and extent of condition evaluation.

(4) To review a sample of Restart corrective action items to determine if the corrective action items required to be accomplished prior to plant restart have been correctly characterized and actions had been completed in accordance with licensee and regulatory requirements.

(5) To review a sample of Post Restart corrective action items to determine if they were properly classified to be addressed after restart.

(6) To evaluate the licensee's effectiveness in assessing and correcting the risk-significant issues identified during the System Health Assurance/Readiness (SHRR, LIR and SFVP) Reviews.

(7) To determine if the prioritization and schedule established by the licensee for implementing and completing the corrective actions is adequate and timely.

(8) To accomplish applicable inspection activities required by Inspection Procedures 71152 and 93812.

(9) To examine adequacy of the licensees corrective actions taken and proposed to address findings documented in selected LERs, and NRC inspection reports (URIs and NCVs) and determine if they are ready for closure.

(10) To characterize any adverse trends or patterns including corrective actions that the licensee is taking, the status of program, or any additional trends that may not have been identified by the licensee.

(11) To determine how the licensee measures effectiveness of the corrective action process (12) To review the assigned items (CRs, URIs, NCVs, LERs etc..,) and focus on adequacy of licensees assessment to identify the correct root/apparent cause(s) and the effectiveness of the corrective action process in addressing these causes, including extent of condition.

(13) To verify whether the licensee is reporting, in a timely manner, conditions that warrant 50.73 LERs or are they in violation of 50.73? (RAM item L-90)

(14) To verify that the licensee is identifying risk-significant issues at an appropriate threshold and entering them in the corrective action program.

(15) To review audits and self-assessments completed and planned to assess Corrective Action implementation.

(16) Pay particular attention to repeat issues or identified problems that need rework.

Are these issues being trended ?

(17) To ensure that licensee performance goals are not in conflict with the actions needed to correct performance issues and are in alignment throughout the organization.

General Guidance for Review of Condition Reports Review each condition report against the following performance attributes:

(1) Did the licensee completely and accurately identify the problem in a timely manner, commensurate with its significance and ease of discovery?

(2) Did the licensee properly and adequately evaluate and resolve of any operability or reportability issues?

(3) Did the licensee consider the extent of condition, the generic implications, whether there might be a common cause, or if there have been previous occurrences? Assess the validity of the licensees conclusions regarding extent of condition, consideration should be given to whether multiple risk significant design or performance issues have been identified.

(4) Did the licensee identify significant negative trends associated with human or equipment performance?

(5) Did the licensee classify and prioritize the resolution of the problem, commensurate with its safety significance?

(6) For any significant conditions adverse to quality, did the licensee identify the root and contributing causes of the problem?

(7) Did the licensee identify appropriately focused corrective actions to correct the problem? For significant conditions adverse to quality, do the corrective actions address the root and contributing causes.?

(8) Did the licensee complete the corrective actions in a timely manner, commensurate with the safety significance of the issue? Were extensions of corrective action due dates adequately justified? Was combining of several condition reports under one new condition report justified ? If permanent corrective actions require significant time to implement, then verify that interim corrective actions or compensatory actions have been identified and implemented to minimize the problem or mitigate its effects, until the permanent action could be implemented; (9) In addition, for samples that involve maintenance rule issues, the inspector should verify the following:

(a) The licensee has designated items under 10 CFR 50.65(a)(1) as appropriate, (b) Determine if corrective actions for 10 CFR 50.65(a)(1) items are adequate, (c) Review maintenance rule repetitive maintenance preventable functional failures (MPFFs) for indications of weaknesses in the licensees corrective action program. In addition, identify any problems with root cause analysis or cause determination and corrective action for items experiencing repetitive MPFFs or exceeding their goals or performance criteria, (d) Ensure that risk assessment, risk management, and emergent work control problems associated with maintenance are identified and resolved promptly.

More Ticklers for review of Condition Reports Status Questions

• Is the CR open or closed?

• How long has it been open?

• If open, where is it in the process?

• If closed, was closure timely?

• Was closure based on a corrective action or an administrative action?

Characterization Questions

• At what significance level was this classified?

• Do you agree with the classification?

• Were all steps of the process completed properly (i.e., accurately and timely)?

• Was an appropriate level of management involved?

• Was proper department assigned responsibility?

• Is the current level the same as originally assigned?

• If not, was revision appropriate?

Analysis Questions

• Was a new or unique activity involved?

• Were generic (plant and industry-wide) implications addressed?

• Were repetitive problem implications addressed?

• Was the chronology of the issue examined?

• Did the licensee look for precursors?

• Were human factors considered?

• Were procedural problems considered?

• Were environmental factors involved?

• Was training considered?

• Were all the people involved in the issue interviewed?

• Was some form of oversight involved?

Resolution Questions

• Is this a final or interim corrective action?

• If interim, when is final anticipated?

• What is impeding final corrective action?

• Is corrective action focused on event itself or on root cause?

• If this is a repeat event, what is different about this new corrective action?

• If this is a repeat event, does it identify the inadequacy in the previous corrective action?

• If a repeat, was previously defined corrective action completed and still in effect?

• Was present corrective action approved by appropriate level of management?

• How much of the current corrective action is already in place?

• How long has corrective action been in place?

• Does corrective action appear to be effective (staff engaged, no recurrence, etc)?

• Does licensee have a follow-up mechanism in place to test effectiveness?

Team Assignments Successful completion of the CATIs inspection objectives and procedure requirements requires good planning and team work. Therefore, the team is being divided into areas with the following general assignments:

Electrical Engineering/Design/Management/Assessments -Zelig Falevits Electrical Engineering/Design/Operations -Marty Farber Electrical Engineering/OE/Maintenance-Al Walker Mechanical Engineering/Design/Operations -Patricia Lougheed Mechanical Engineering/Design-J. Panchison, Mechanical, Consultant Mechanical Engineering/Design - W. Sherbin, Mechanical, Consultant Electrical Engineering/Design-F. Baxter, Electrical, Consultant Effectiveness of Corrective Actions/audits/assessments - W. Bennett, Corrective Action, Consultant Within these areas, the intent is to ensure that all inspection attributes are met without duplication of effort. To ensure effective teamwork and knowledge sharing, a daily afternoon team meeting will be held at 3:30 p.m. starting Tuesday March 18, 2003 which will focus on how assigned activities are being completed and what remains to be done to accomplish the inspection objectives.

Assessment of Corrective Action Program At the completion of the inspection, the team will develop a clear and concise discussion of the results of their review. An assessment of the licensees corrective action program/process, based on the inspection results developed during the inspection. By reviewing a sufficient number and breadth of samples, the team should be able to develop insights into the effectiveness of the licensees corrective action process.

Compare the results of the teams findings with the results of the licensees findings, audits and assessments of the corrective action process.

IV Issues and Findings The Risk Informed Inspection Notebook and the Significance Determination Process (SDP) for Davis-Besse Nuclear Power Station have been developed and approved.

Inspectors shall address the questions of Manual Chapter 0612 and process the finding

through phase 2 of the SDP as necessary. Green findings will be documented in the inspection report. Findings that appear to be "other than green" shall be immediately discussed with the team leader, the licensee and the senior reactor analyst, to ensure that Davis Besse PRA information is correctly considered. Enforcement action for green or non-SDP issues will be handled in accordance with the Enforcement Policy.

Unless an issue can be shown to be greater than minor, additional inspection time (over approx. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) should not be spent. If an issue appears greater than minor, then sufficient questions need to be asked of the licensee to enable the inspectors to confirm any assumptions and complete the Phase 1 and 2 worksheets. If a color cannot be determined by the end of the inspection, the issue will be described as an "unresolved item," pending final determination of the appropriate risk significance. Some flexibility will be allowed for documenting non-green observations due to the nature of the inspection.

V Documentation Inspection findings normally result in a number of questions being raised. These questions are to be given to the licensee verbally or, if written, the licensee must copy the information and the inspector must retain the written document. As part of the daily interfaces with the licensee, the team leader will go over the status of outstanding questions. Therefore, the team members need to keep the team leader informed of any concerns with timeliness or quality of responses to questions. Lack of response to questions will not be accepted as a reason for any delay in providing an input unless the team leader has been informed prior to the exit and the issue is one that will necessitate a writeup in the report. Any document requests generated on the day of the exit or afterwards must be approved by the team leader, must pertain to areas already inspected, and must be only for the purpose of ensuring an accurate document list entry.

Issues which the inspector deems meet the criteria for report writeups shall be discussed with the team lead prior to preparing an input. Inputs are to be e-mailed to the team lead within five working days (seven calendar days) of the exit. All documents critically/deliberately reviewed shall be included in the document list. Corrective action documents generated as a result of the inspector's questions shall be listed separately from corrective action documents that were in the licensee's system prior to the inspection.

VI Interface and Coordination Meetings Meetings with the Licensee A status meeting will be held at 9:30 a.m. each day during the inspection.

A short licensee debrief will be held at 10:30 a.m., on Friday, at the close of each of the first two inspection weeks, prior to leaving the site.

Daily debriefings with the licensee will start Tuesday, March 18, 2003. Team members are expected to attend the debrief on Fridays, and the exit meeting on April 18, 2003.

Team members do not have to routinely attend the daily debriefings, unless they identify a complex issue.

An extensive team meeting will be held starting at 2:00 p.m. Thursday, April17th, to discuss the teams findings and determine what will be discussed at the exit. This meeting will last longer than normal team meetings.

Routine Interactions Through-out the inspection, inspectors are expected to have routine interactions with licensee employees. It is expected that these interactions will be professional in nature and will normally be conducted without the lead inspector present. Any questions or requests for further information arising from these meetings will be conveyed to the lead inspector.

Exit Meeting The team leader will conduct the exit meeting on April 18, 2003. Team members are expected to provide the team leader a final short summary of findings the day before the exit. Team members need attend the final exit meeting and be prepared to answer any questions that may be raised by the licensee.

VII Starfire Information This special inspection is estimated to require approximately 960 (+/- 80) hours of direct inspection effort. The review will include mostly Restart as well as a small sample of Post-Restart corrective action items. Approximately 75% (or 700) of these hours should be spent as direct inspection evaluating effectiveness of the licensees corrective action program in assessment and resolution of identified risk significant issues and review of RAM items for closure (charge to IP 93812 with IPE code of ER).

Approximately 25% (or 250) of these hours should be spent in reviewing CRs, LERs, URIs, NCVs, audits, self-assessments and other corrective action related issues to determine effectiveness of licensee corrective actions taken and proposed to resolve the identified issues and determine if they are ready for closure (charge to IP 71152 with IPE code of BI,). We need to fulfill the requirements pertaining to assessment of effectiveness of corrective action process delineated in IP 71152. Preparation and documentation for this inspection will use IPEs, SEP, SED, BIP or BID. The direct inspection hours do not include time spent in travel, entrance or exit meetings, debriefing the residents, checking on e-mail, or keeping track of hours to correctly credit them. However, it does include time spent in team meetings and in preparing for team meetings.

General Information Checking E-mail and Other Such Activities For planning purposes, the lead inspector has assumed that each inspector will spend a maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> each week of the inspection, maximum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, checking e-mail or doing other activities not directly related to the inspection. This time, if used, should be charged to general administration.

Travel Charges All travel time is to be charged in HRMS to an IPE code of "AT", including travel during non-regular hours (see below). For planning purposes, a total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> travel is allotted for travel one way to the site.

Overtime The lead inspector has requested authorization of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of overtime for each inspector for each of the onsite weeks. The overtime is to only be used to meet the inspection requirements and must be claimed in HRMS if used. Any overtime spent traveling (although there shouldnt be any) also must be claimed in HRMS using the overtime code of "ADDLT".

SCOPE AND TEAM MEMBER ASSIGNMENTS Note to inspection team members: Please review the list of corrective action related documents delineated in the tables below and select a good sample of Restart items to be examined during this inspection. In addition, select a small sample of Post-Restart items to determine if they were properly categorized. Additional assignments may be provided by the team leader during the inspection to distribute the work load amongst the team members.

Our inspection objective is to conduct a comprehensive review of as many items, listed in the tables, as time will permit during the five weeks of inspection (3 weeks onsite and 2 weeks in the office) to determine effectiveness of licensees implementation of the upgraded Davis Besse corrective action program/process.

Corrective Action Condition Reports, LERs, URIs, NCVs, OE, Audits, Assessments General Notes

1. All items listed in the tables below are Restart items unless designated Post-Restart.

2. Per the End of Cycle Paper, it is not acceptable to close a URI/NCV item based on the licensee's putting it into their corrective action system. Closure should be based on implementation of the action to correct the problem.

General Corrective Action Condition Reports Number Subject Assigned Status To 01-2019 Evaluation of the Status of the licensee High Energy Farber Line Break Re-analysis. IR-0219, URI-2001-011-01 (per Christine) SHA-PATH-C (Topical) 02- Corrective Action Form CAF # 16, 29, 30, 36, 40, 47, Bennett 00891 48, 50, 52, 55, 57, 58, 71, 77, 88, 81, 84, 97, and 125.

TCAR-Technical Root Cause Analysis Report MRCAR-Management Root Cause Analysis Report CR-02-04884, 02-06677, 02-04292, 02-08356, 02- Bennett 10214, 02-03862, 02-08907 Sample of Corrective Action implementation CRs provided by the Resident Inspectors per TL request.

01-2820 Determine accident flow to EDGs if normal flow was Panchison limited to 1050 g.p.m.

02- continued erosion of the EDG heat exchangers at high Panchison 03027 flow levels.

Augmented Inspection Team Follow-up Issues (50-345/02-08)

Number RAM Title Assigned Status To 50-346/2002-08-01 URI - Reactor Operation with Pressure Farber 01 Boundary Leakage 50-346/2002-08-02 URI- Reactor Vessel Head Boric Acid Farber 02 Deposits 50-346/2002-08-03 URI- Containment Air Cooler Boric Acid Farber 03 Deposits 50-346/2002-08-04 URI- Radiation Element Filters Farber 04 50-346/2002-08-05 URI- Service Structure Modification Delay Farber 05 50-346/2002-08-06 URI- Reactor Coolant System Unidentified Farber 06 Leakage Trend 50-346/2002-08-07 URI- Inadequate Boric Acid Corrosion Farber 07 Control Program Procedure 50-346/2002-08-08 URI- Failure to Follow Boric Acid Corrosion Farber 08 Control Program Procedure 50-346/2002-08-09 URI- Failure to Follow Corrective Action Farber 09 Program Procedure System Health Assurance Implementation (50-346/02-013)

Condition Report Title Assigned Status To CR 01-01232 Crack in Battery Post Seal Ring Baxter CR 02-00412 DC Voltage Drop Calculation Baxter CR 02-04586 SHRR: 1992 PCAQR Corrective Action Not Yet Baxter Completed - Fuse Size CR 02-06723 SHRR LIR NRC Concern regarding Sites Farber Lubrication CR 02-06765 Sway Strut Bushing Grease Fittings Farber CR 02-08742 Inadequate Follow up to Self Assessment Farber 1999-0076 CR 02-09036 Greasing of Struts Farber System Health Assurance Condition Reports (SHRR, LIR, SFVP)

System Health Readiness Review/Safety Function Validation Project Decay Heat/Low Pressure Injection Condition Title Assigned Statu Report To s CR 03- Lack of documentation confirming pump DHR/LPI Panchison 00501 P42-1 will not runout during recirculation phase operation CR 03- Acceptance criteria for test DB-CH-03004, Revision 7, Farber 00496 are non-conservative Main Steam System Condition Title Assigned Status Report To CR 03-00561 MSLB analysis credits MSIV closure under reverse Sherbin flow CR 03-00568 Bases for Main Steam Safety Valve relief capacity listed in Technical Specifications could not be located Safety Features Actuation System Condition Title Assigned Status Report To CR 03- Calculation error affects Tech Spec value 00511 Steam and Feedwater Rupture Control System Condition Title Assigned Status Report To CR 03- Errors in calculation C-ICE-083.03-004 result in errors in 00519 Technical Specification Allowable Value and test procedures DB-MI-03203 and 04

125/250 VDC Condition Title Assigned Status Report To CR 03- Calculation C-EE-002.01-010 has a non-conservative Baxter 00566 mismatch between the stated assumptions and the implementation of those assumptions in the calculation CR 03- Fuse supplying inverter is not coordinated with inverter Baxter 00516 breaker and both will trip if a fault occurs at the inverter input CR 03- Missing calculations for cable ampacity Baxter 00565 480 VAC Condition Title Assigned Status Report To CR 03- Containment Spray Pump 1-1 full load current is above Baxter 00425 its power cable ampacity once fire barrier derating is included CR 03- Calculations are inappropriate justification for not Baxter 00575 coordinating breakers (480VAC-08)

CR 03- No calculations to support high and low voltage limits Baxter 00585 (480VAC-19) 4160 VAC Condition Title Assigned Status Report To CR 03- Protective relay for makeup pump improperly set Walker 00567 Latent Issues Review Reactor Coolant Condition Title Assigned Status Report To

02-06215 Excessive indicated Total RCS flow error in SP-03358.

02-06505 Ineffective Corrective Action Implementation Bennett 02-07185 Incorrect Root Cause /Ineffective Corrective Action Bennett 02-07278 RC2, Pressurizer Spray Valve Design Sherbin 02-07512 Pressurizer Heater Cable Configuration Walker/

Baxter 02-07706 Multiple open work request to install inspection openings Bennett in the service structure 02-07868 Inadequate Condition Report Corrective Action Response Bennett 02-07880 NRC response to GL 88-017 : loss of DHR Walker 02-07913 PM Program is Unverifiable Walker 02-08278 Maximum Allowable Pressurizer Level should be 228 Panchison inches not 305 inches 02-10072 Closed Condition Reports with Open Corrective Actions Bennett Auxiliary Feedwater Conditio Title Assigned Status n Report To 02- Review of DBI-100, Electrical Equipment Qualification Walker 03537 Environmental Conditions has resulted in the following EQ related items.

02- Safety analysis does not address the effect of allowing Sherbin 05079 water to pass into the upper steam annulus through the upper tap of the operate range level instrument.

02- LIR-AFW-CR: CR 95-0351 addresses the water content of Sherbin 06767 bearing lube oil. The Justification for continued operation relies on inputs that are not bounding for mitigation of design basis accidents using licensing assumptions.

02- LIR-AFW-CR: No actions taken to prevent recurrence to Bennett 06770 address valve vibration problem. (Post Restart) 02- LIR-AFW-CR 95-0906 Extent of Condition did not have to Walker 06773 be evaluated per PCAQR procedure. No action to prevent recurrence. (OE) 02- LIR-AFW-CR-96-0240 - Inadequate corrective actions to Bennett 06775 prevent recurrence.

02- LIR-AFW-CR-2000-0072 - Inadvertent trips of overcurrent Bennett/

06778 relay targets has been an intermittent, but recurrent Baxter problem. Potential recurring issue. (Post Restart)

02- LIR-AFW-CR-2000-0991 - During calibration check the Bennett 06779 voltage reading exceeded the tolerance and there was evidence of heat damage. The circuit board was replaced but the real root cause was not determined, no extent of condition was evaluated. (Post Restart) 02- LIR-AFW-CR-2000-1578 - Untimely corrective action to Bennett 06780 address a Tech Spec violation.

02- The referenced Surveillance Procedures should be revised Sherbin/

06821 to include a low point flow determination. This flow should Baxter be that used in the USAR Section 15 analyses. Ref: Calc.

C-NSA-50.03-022 Rev 2.

02- LIR-AFW: The interim revision of the AFW system Sherbin 07236 description indicates pump capacity (flow vs. head) requirements beyond the current design capabilities of the AFW pumps 02- LIR-AFW AFW PUMP CURVES A controlled documented Sherbin 07524 derivation of the current pump curves for the Auxiliary Feedwater Pumps, P14-1 and P14-2, could not be found.

02- The DB-1 licensing basis has to be revised to Sherbin 08331 unambiguously state the required event combinations for the AFW system during a large and small break LOCA. A distinction must be made between allowable load combinations and required event combinations.

Service Water Conditio Title Assigned Status n Report To 02- LIR of SW system condition reports Bennett 05284 02- LIR-SW: possible inaccurate consideration of design Panchison 05516 bases CAC fouling factor 02- LIR-SW: design capacity of ultimate heat sink Lougheed 05727 02- LIR-SW: LAR 96-0008 not supported by analysis Farber 05732 02- LIR-SW: no design bases for service water pump NPSH Panchison/

05923 available Baxter 02- LIR-SW: flow balance testing of alternate safety related Panchison 06166 return flow paths

02- LIR-SW: lack of degraded voltage calculation for SW Baxter 06392 pump motors 02- LIR-SW service water pump run out Panchison 06439 02- LIR-SW: Review of industry experience (OE) Walker 06341 02- LIR_SW: No over pressure protection evaluation for Panchison 07640 isolable components 02- LIR-SW: In-Service testing of SW pumps Panchison 08342 Emergency Diesel Condition Title Assigned Status Report To 02- LIR-EDG: Oxidation build up on fuses Walker 04202 02- Do Not Have Documentation To Assure Compliance With Walker 04680 GE SIL 44 For HFAS 02- LIR-EDG 1 Output Breaker Closing Circuit Baxter 04814 Errors/Discrepancies 02- LIR-EDG Procedural Deficiency For Restoring EDG Walker 04971 Following Emergency Shut Down 02- LIR-EDG System Does Not Meet IEEE-STD-387-1972 Baxter 05039 Requirements No Calculations.

02- LIR-EDG-59% Under Voltage Relay Logic Shown In Baxter 05627 EC128AI Is Incorrect 02- LIR-EDG- 59% Under Voltage Relay Logic Shown In SD- Baxter 05628 003A Is Incorrect 02- LIR-EDG -Tech Spec Table 3.3-4 Trip Setpoint Tolerance 05632 Is Inadequate 02- LIR-EDG-USAR Section 15.4.4.2.6.6 Does Not Reflect The 05633 Design.

02- LIR-EDG-TDPU Relay 27X-6/C1(D1) Not Designed To Baxter 05636 Meet Functional Requirement 02- LIR-EDG Bearing Oil Post Restart 05703

02- LIR-EDG-High Temperature Evaluation ESI Report Restart 05845 02- LIR-EDG-High Temperature Evaluation-Internal 05848 Temperature Rise For Cabinets 02- LIR-SW Appendix R Tech Spec 6.8.1.F Restart 05859 02- LIR-EDG Lube Oil Procedure Guidance Restart Sherbin 05914 02- LIR-EDG: Fuel filter inlet operating pressure exceeds Sherbin 06062 vendor limits for change 02- LIR-EDG Undervoltage Auxiliary Relays Logic Is Not Walker 06209 Tested To Meet GL 96-01 02- LIR-EDG: Documentation of OE 11330 can not be located Walker 06511 02- LIR-EDG: Relays SAX, SEQX, K6&97/C1 are not tested to Walker 06661 meet GL-96-01 02- LIR-EDG Output Modules Are Not Tested As Part Of The Walker 06667 Sequencer To Meet GL 96-01 02- LIR-EDG: OE 8753 and many other EDG OES not Walker 06669 evaluated 02- LIR-EDG: EGB Actuator failure OE7078 Walker 06682 02- LIR-EDG: Load swing OE11321 Walker 06687 02- LIR-EDG: Inoperability due to low viscosity oil OE 11817 Walker 06729 (Post Restart) 02- LIR-EDG: Lube oil level control OE 13134 (Post Restart) Walker 06731 02- LIR-EDG Engine Derating Panchison/

06951 Baxter 02- LIR-EDG: Testing of aux relays associated with sequencer Walker 06986 OE-11628 02- LIR-EDG: GE SBM switch failure OE10278 (Post Restart) Walker 07393 02- LIR-EDG: NRC Information Notices are not officially Walker 07547 reviewed by station 02- LIR-EDG: OE12365 oil level in EDG bearing less than Walker 07774 adequate

02- LIR-EDG: GE HGA relays failure (IN 97-12) Walker 07986 02- LIR-EDG: GE SBM switch failure (IN-98-19) Walker/

08010 Baxter Component Cooling Water Conditio Title Assigned Status n Report To 02- LIR CCW - Non Seismic Piping Over Safety Related Sherbin 05749 Components 02- LIR CCW - Lack Of Functional Testing Of Letdown Cooler Sherbin 07148 And RCP Interlocks 02- LIR CCW - Non-Compliance With USAR Single Failure Panchison/

07159 Statements Baxter 02- LIR CCW - Outdated Pump Curves In Procedure DB-PF- Panchison 07380 06704 02- LIR CCW - Loss Of Offsite Power Start Interlock Not Baxter 07382 Tested On All CCW Pumps 02- LIR CCW - Required CCW Flow Rate Inconsistencies Panchison 08084 Downgraded Condition Reports The following downgraded items were identified during a Mode Change Readiness Review of Design Engineering.

Please select several items from the list and determine if the downgrading was appropriate considering significance of issue. Were any Restart items changed to Post-Restart ? Did the licensee use the established process to justify the downgraded items ?

CR # Eval. Issue Assigned Status Code To 03-00120 SR CAC Thermal Performance Roll-up Panchison 02-05322 SR Additional Review of the Containment is Farber Warranted 02-05440 CB BWST Vent Line and Vacuum Breaker Panchison Potential Issues

02-05514 SB SHRR Assessment of Testing Containment Farber Spray Valves - Locked Closed 02-05526 CB LIR-AFW-HELB Collective Significance CR Farber 02-06100 CB SSDPC Assessment Identified Incorrect Information in OJ 2000-14 02-06337 SR SSDPC SW Calculation C-NSA-011.01-007, REV. 1 Concerns 02-06436 ST SSDPC Collective Significance of Issues from SW Self Assessment and LIR 02-06702 SR Potential for Inadequate HPI Pump Minimum Sherbin Recirculation Following LOCA 02-07110 CB EQ Walkdown: Unqualified Splice Found on Baxter Internal Motor Leads for HV240a 02-07347 CB Design Package for ECR-02-0580, Polar Baxter Crane Lights, is Less than Adequate 02-07701 CB Control Room Operator Dose Due to ECCS Farber Leakage Post-LOCA 02-07760 CB Flood Analysis Discrepancies in the Service Panchison Water Pipe Tunnel and Valve Rooms 02-08020 SR SHRR/480V: Apparent Incomplete Basis in CR 97-00275 Disposition 02-09027 CB EQ Walkdowns: Unqualified Splice Found on Baxter Internal Motor Leads for HVCF5B 02-09011 SB EQ Walkdowns: Potential Replacement of SOR Pressure Switch PSHRC2B4 02-05691 SR LIR-AFW-Minimum Temperature to the AFWS Sherbin SG Nozzles 02-06701 CB Post LOCA Dose From BWST with Farber Inadvertent HP31/HP32 Failure 02-06996 CB HPI Flow Test Acceptance Criteria Versus Sherbin T.S. 4.5.2.H 02-07225 SR Thermowell/RTD Innerface for TWRC3A3 Does Not Meet Requirements 02-08452 CB CAC Dropout Register Fusible Link Response Time 03-00563 SR SFVP: MSIVS MS100 and MS101 Surveillance Testing/Flowserve Vendor Documentation

RAM Open Items (Do Not show this table to the licensee)

(For additional information see the latest RAM copy)

Notes: URI - Unresolved Item from inspection C - Concern SUP - Supplemental Inspection Program Item L - Letter RAM Issue Notes Assign To Stat

1. us L-50 If boric acid was the root cause of the damage UCS Bennett to RC-262, doesnt the back-to-back damage CATI to to RC-2 and RC-262 suggest that FENOC's evaluate EOC extent-of-condition (EOC) and problem and problem resolution processes are flawed? resolution only L-90 Did FENOC properly evaluate problems raised Lochb Bennett during the system assessments at D-B for (see URI-42) reportability under 10 CFR 50.72 and 50.73? CR 0209314 C-02 DG loading - CR # 02-8482 350 Baxter (also see CR 02-05922 & 05925)

SUP- Review of Licensee Control Systems for IP 71152 Team 15 Identifying, Assessing, and Correcting Performance Deficiencies: Determine whether licensee evaluations of, and corrective actions to, significant performance deficiencies have been sufficient to correct the deficiencies and prevent recurrence.

SUP- Review of Licensee Control Systems for IP 71152 Zelig 16 Identifying, Assessing, and Correcting (CATI to Performance Deficiencies: Evaluate the review effectiveness of audits and assessments effectiveness performed by the quality assurance group, line of audits and organizations, and external organizations. assessments of CAP only)

SUP- Review of Licensee Control Systems for IP 71152 Walker 20 Identifying, Assessing, and Correcting Performance Deficiencies: Evaluate the effectiveness of the organization's use of industry information for previously documented performance issues.

SUP- Assessment of Performance in the Reactor IP 71152 Bennett 27 Safety Strategic Performance Area: Inspection Preparation: Review licensee analyses of corrective actions related to specific findings and general audits where available.

SUP- Assessment of Performance in the Reactor IP 71152 30 Safety Strategic Performance Area: Key Attribute - Design: Assess the effectiveness of corrective actions for deficiencies involving design.

SUP- Assessment of Performance in the Reactor IP 71152 41 Safety Strategic Performance Area: Key Attribute - Procedure Quality: Assess the effectiveness of corrective actions for deficiencies involving procedure quality.

SUP- Assessment of Performance in the Reactor IP 71152 Walker 44 Safety Strategic Performance Area: Key Attribute - Equipment Performance: Assess the effectiveness of corrective actions for deficiencies involving equipment performance, including equipment designated for increased monitoring via implementation of the Maintenance Rule.

SUP- Assessment of Performance in the Reactor IP 71152 Bennett 48 Safety Strategic Performance Area: Key Attribute - Configuration Control: Assess the effectiveness of corrective actions for deficiencies involving configuration control.

LER- Review and Evaluate EDG Missile Shield LER. LER-2002-06 Panchison 06 See also Condition Report 02-5590.

LER- Review and Evaluate Containment Air Coolers LER-2002-08 Sherbin 08 collective significance LER. See also Condition Report 02-5563.

LER- Degradation of High Pressure Injection thermal LER-2002-09 Sherbin 09 sleeves.

URI- Potential impact of corrosion on the ground IR 02-12-02 Baxter 13 function of electrical conduit in containment URI- Potential failure to follow the procedure for IR 02-12-03 Walker 14 Raychem splice removal on electrical cables URI- Failure to perform comprehensive Moderate IR 02-14-01c 15 Energy Line Break analysis CR 02-07757 URI- IR 02-14-01d Bennett Lifting of Service Water Relief Valves 16 CR 02-07879 URI- Inadequate SW pump room temperature IR 02-14-01e Panchison 17 analysis CR 02-07188 URI- Inadequate ASW pump room steam line break IR 02-14-01f Sherbin 18 analysis CR 02-07475 URI- IR 02-14-01g Baxter Inadequate cable ampacity analysis 19 CR 02-06893 URI- Inadequate flooding protection for the SW IR 02-14-01h Panchison 20 pump house CR 02-07714

URI- Poor quality calculation for 90 percent IR 02-14-01j Baxter 21 undervoltage relays CR 02-07633 Inadequate calculations for control room IR 02-14-01l Farber URI- operator dose (GDC-19) and offsite dose (10 CR 02-06701 22 CFR Part 100) related to HPI pump minimum CR 02-07701 flow valves URI- IR 02-14-01m Farber Other GDC-19 and 10 CFR Part 100 issues 23 CR 02-07713 URI- HPI Pump Operation Under Long Term IR 02-14-01n Sherbin/

24 Minimum Flow CR 02-07684 Baxter URI- IR 02-14-01o Panchison Some small break LOCA sizes not analyzed 25 CR 02-06702 IR 02-14-01p Panchison URI-Inadequate SW flow analysis CR 02-06438 26 CR 02-06333 IR 02-14-01g Lougheed URI-Inadequate SW thermal analysis CR 02-05372 27 CR 02-07716 IR 02-14-01r Sherbin URI-Inadequate UHS inventory analysis CR 02-05986 28 CR 02-07692 URI- No Valid Service Water Pump Net Positive IR 02-14-01s Panchison 29 Suction Head Analysis CR 02-05923 URI- IR 02-14-01t Sherbin SW source temperature analysis for AFW 30 CR 02-05923 IR 02-14-01u Baxter URI-Inadequate short circuit calculations CR 02-06837 31 CR 02-06302 URI- IR 02-14-02b Panchison Inadequate SW system flow balance testing 32 CR 02-06064 URI- Inappropriate SW pump curve allowable IR 02-14-03a Panchison 33 degradation CR 02-07468 URI- IR 02-14-03b Bennett Repetitive failures of SW relief valves 34 CR 02-07995 URI- Non-Conservative Differences in UHS IR 02-14-03c Lougheed 35 Temperature Measurements CR 02-07716 URI- Non-Conservative containment air cooler IR 02-14-03e 36 mechanical stress analysis CR 02-05563 URI- Inadequate Implementation of the Corrective IR 02-17 Bennett 42 Action Process Which Led to Not Identifying a NCV Potentially Reportable Issue regarding the containment air coolers. ( CR-02-09314)

NCV- Lack of a design basis analysis for IR 02-14-01a Sherbin 06 containment isolation valve backup air supplies CR 02-07750 NCV- Inadequate blowdown provisions for CAC IR 02-14-01b Sherbin 07 backup air accumulators CR 02-07750 NCV- Non-conservative TS value for 90 percent IR 02-14-01i Baxter 08 undervoltage relays CR 02-07766

NCV- IR 02-14-01k Baxter Non-conservative relay setpoint calculation for 09 CR 02-06737 the 59 percent undervoltage relays CR 02-07646 NCV- No analytical basis for the setpoint to swap IR 02-14-01v Lougheed 10 service water system discharge path CR 02-07802 NCV- SW surveillance test did not use worst case IR 02-14-02a Lougheed 11 values CR 02-07781 NCV- Inadequate corrective actions related to SW IR 02-14-03d Lougheed 12 pump discharge check valve acceptance CR 02-07657 criteria NCV- Failure to perform TS surveillance requirement IR 02-14-04 Walker 13 for HPI pump following maintenance CR 02-06996

Licensees Assessment Findings Classified as Potential Safety Consequences of Nonconforming Conditions at Davis-Besse (From MPR Engs review, dated 12/27/02)

Note: See list of A-1 and A-2 Nonconformances Categorized as Potential Impacts on Chapter 15 Safety Analysis in Table 2-2 next page.

A: SIGNIFICANT IMPACT There are two subcategories for this category:

A-1 Potential significant impact on Chapter 15 analysis; analysis will be required prior to restart.

Includes a nonconformance in this subcategory if:

• The physical attribute required (as identified in the LIR/self-assessment) to satisfy a safety related function can not be met. For example, the pump head/flow characteristic employed in the Chapter 15 analysis or the required system startup time can not be met.

• The required physical analysis could be met if limitations to system operation were imposed, but it is desired to avoid such restrictions by re-analysis. For example, post accident criticality analysis were performed assuming a minimum auxiliary feedwater temperature of 60EF, but actual feedwater temperature can be below 40EF for limited periods of time.

A-2. Nonconforming condition that does not require an analysis change but which must be corrected in order for the plant to survive Chapter 15 accident scenarios.

Examples of nonconformance in this subcategory include:

• Absence of calculations needed to define component/system operating characteristics or to determine functional or structural capability.

• Incorrect or missing emergency operating procedures.

• Plant equipment not able to perform its design function.

Excluded from this subcategory are issues that are expected to be addressed by normal plant programs such as Seismic Qualification, Environmental Qualification, Appendix R, HELB and Flooding.

Also included in this category are conditions expected to have a significant impact on the likelihood of core damage, even if not directly associated with Chapter 15 accident analysis.

Table 2-2. Nonconformances Categorized as Potential Impacts on Chapter 15 Safety Analysis

CR Title/Description System/ Assigned Status Number Category To 02- LIR-AFW-MINIMUM TEMPERATURE TO AFW/A-1 Sherbin 05691 THE AFWS SG NOZZLES 02- LIR-SW: DESIGN CAPACITY OF SW/A-1 Lougheed 05727 ULTIMATE HEAT SINK 02- CONTROL ROOM OPERATOR DOSE Misc/A-1 Sherbin 07701 DUE TO ECCS LEAKAGE POST-LOCA 02- POST ACCIDENT CONTROL ROOM Misc/A-1 Sherbin 07713 CALCULATIONS 02- INADEQUATE VENTILATION FOR 4160 V/A-2 Panchison/

02658 ROOMS 323, 324, 325 Baxter 02- SSDPC-C-EE-015.03-003, STEADY 4160 V/A-2 Baxter 06305 STATE ANALYSIS: ELMS (ELECT LOAD MANAGEMENT SYS) 02- SSDPC-HPI PUMP PERFORMANCE NOT 4160 V/A-2 Sherbin 06477 EVALUATED FOR EXPECTED INPUT POWER VARIATIONS 02- LIR-AFW-STRAINERS LIMITING AFW/A-2 Lougheed 04673 PARTICLE SIZE 02- LIR-AFW-DESIGN BASES AFW/A-2 Lougheed 05904 CALCULATIONS NOT LOCATED 02- LIR-AFW-TIME CRITICAL OPERATOR AFW/A-2 Lougheed 07441 ACTIONS 02- LIR-AFW-PERFORMANCE OF AFW/A-2 Lougheed 07458 CAVITATING VENTURES 02- LIR CCW-DESIGN PERFORMANCE CCW/A-2 Lougheed 07165 LIMITS NOT REFLECTED IN TEST PROCEDURES 02- LIR CCW-LACK OF CCW FLOW CCW/A-2 Lougheed 07169 VERIFICATION TO ESSENTIAL COMPONENTS 02- LIR CCW-POTENTIAL CCW IMPACT CCW/A-2 Lougheed 07292 FROM LETDOWN LINE BREAK 02- LIR EDG-ELECTRICAL CAPACITY EDG/A-2 Baxter 05364 CALCULATION C-EE-024.01-005 02- LIR EDG-EDG ELECTRICAL CAPACITY EDG/A-2 Baxter 05383 CALCULATION C-EE-015.03-002

CR Title/Description System/ Assigned Status Number Category To 02- LIR EDG-STEP 1 BLOCK LOADING EDG/A-2 Baxter 05385 CALCULATION C-EE-024.01-006 IS INADEQUATE 02- LIR EDG-ENERGIZING BUS TIE EDG/A-2 Baxter 05397 TRANSFORMER FOR MOTOR DRIVEN FEED PUMP NEEDS TO BE REVISED 02- LIR EDG-EDG LOADING COULD EXCEED EDG/A-2 Baxter 05446 ELECTRICAL CAPABILITY WHEN PARALLELED 02- LIR EDG-SFAS VALVE LOADS NOT EDG/A-2 Baxter 05878 LISTED IN EDG LOADING TABLE 02- LIR EDG-DISCREPANCY IN EDG EDG/A-2 Baxter 05922 VOLTAGE AND FREQUENCY DURING LOADING 02- LIR EDG-EDG TRANSIENT ANALYSIS EDG/A-2 Baxter 05925 DURING LOADING SEQUENCE 02- LIR EDG-POTENTIAL ICING OF FUEL OIL EDG/A-2 Baxter 06236 TANK FLAME ARRESTORS 02- LIR EDG-POTENTIAL OVERLOAD EDG/A-2 Baxter 06757 CONDITION 02- LIR EDG-EDG ROOM TEMPERATURE EDG/A-2 Panchison/

06940 CALCULATION Baxter 02- LIR EDG-HIGH TEMPERATURE EDG/A-2 Panchison 07596 OVERALL 02- LIR-EDG HIGH TEMPERATURE- EDG/A-2 Panchison 07599 DETERMINE CAPABILITY TO FUNCTION 02- LIR EDG-SINGLE FAILURE OF EDG 2 EDG/A-2 Baxter 09038 COULD INOP EDG 1 ALSO 02- SSDPC: ECCS PUMP ROOM HEAT LOAD HPI/A-2 Panchison 06370 CALCULATION IS NON-CONSERVATIVE 02- SSDPC: ENHANCEMENT TO HPI/A-2 Panchison 06384 CALCULATION 5§020 FLOODING OF Patricia ECCS ROOMS DUE FWLB 02- SSDCP-HPI PUMP PERFORMANCE NOT HPI/A-2 Sherbin 06477 EVALUATED FOR EXPECTED INPUT POWER VARIATIONS

CR Title/Description System/ Assigned Status Number Category To 02- POTENTIAL FOR INADEQUATE HPE HPI/A-2 Sherbin 06702 PUMP MINIMUM RECIRCULATION FOLLOWING LOCA 02- LIR-RCS: RCI3B MANUAL LIFT DEVICE RCS/A-2 04102 APPEARS TO BE LOCKED UP 02- LIR-RCS: PZR MANWAY SHORT STUD RCS/A-2 05272 TORQUE VALUE IS INCONSISTENT WITH DB-MM-09011 02- LIR-RCS: NO BASIS FOUND FOR RCS/A-2 05948 OPERATING LIMITS SPECIFIED IN TS 3/4.4.8 02- LIR-RCS: PZR VENT FLOW CAPACITY RCS/A-2 Sherbin 06536 HAS NO DESIGN BASIS 02- LIR-RCS: RCS FLOW UNCERTAINTY RCS/A-2 06885 MAY BE HIGHER THAN ASSUMED 02- LIR-RCS: LACK OF RESPONSE TO RCS/A-2 07559 RFAS FOR DESIGN BASIS VALIDATION INFORMATION 02- LIR-RCS: CABLE SEPARATION HIGH RCS/A-2 Baxter 07609 POINT VENT VALVES 02- LIR-RCS: CABLE SEPARATION FOR RCS/A-2 Baxter 07612 RC200 & RC239A 02- LIR OF INADEQUATE SERVICE WATER SW/A-2 Lougheed 05369 SYSTEM FLOW BALANCE PROCEDURE 02- LIR OF SERVICE WATER SYSTEM SW/A-2 Lougheed 05372 DESIGN FLOW RATES TO THE ECCS ROOM COOLERS 02- LIR-SW: NO DESIGN BASES/FLOW SW/A-2 Lougheed 05640 VERIFICATION TESTING OF SW FLOW TO AFW SYSTEM 02- LIR-SW: LACK OF SW/UHS DESIGN SW/A-2 Lougheed 05748 BASES FOR SEISMIC EVENT AND SINGLE ACTIVE FAILURE 02- LIR-SW: NO ECCS SW/A-2 Lougheed 05885 COOLER/CONTAINMENT AIR COOLER INSPECTION ACCEPTANCE CRITERIA 02- LIR SW: DEAD LEG INSPECTIONS AND SW/A-2 Lougheed 06134 CLEANING

CR Title/Description System/ Assigned Status Number Category To 02- SSDPC: UHS ANALYSIS DO NOT SW/A-2 Lougheed 06356 DOCUMENT THAT WORST-CASE CONDITIONS ARE ENVELOPED 02- SSDPC: ECCS PUMP ROOM HEAT LOAD SW/A-2 Lougheed 06370 CALCULATION IS NON-CONSERVATIVE Panchison 02- SSDPC: ERROR IN ECCS ROOM SW/A-2 Lougheed 06736 COOLER HEAT TRANSFER CAPABILITY CALCULATION 02- LIR-SW: POTENTIAL LOSS OF ALL SW/A-2 Lougheed 07409 SERVICE WATER DUE TO FLOODING IN THE SW PUMP ROOM 02- CONCERNS WITH ULTIMATE HEAT SINK SW/A-2 Lougheed 08251 ANALYSIS POST LOCA

RAM Closure Form Attached is the closure form to be used for closing RAM items. As you complete and close an item, please document your closure for an item on the attached form and give or e-mail the completed form to the team leader.

RAM Item No.

Description of Issue Description of Resolution Reference Material Item Closed/Open If items remains open, what has to be done to close the item ?

General Inspection Guidance for Root and Apparent Cause Evaluations Determine whether licensee evaluations of, and corrective actions to, significant performance deficiencies have been sufficient to correct the deficiencies and prevent recurrence. Evaluate whether evaluations are of a depth commensurate with the significance of the issue. Evaluations should ensure that the root and contributing causes of risk significant deficiencies are identified. Corrective actions should be taken to correct the immediate problems and to prevent recurrence.

Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem. Determine that the root cause evaluation included a consideration of prior occurrences of the problem and knowledge of prior operating experience. Determine that the root cause evaluation included consideration of potential common cause(s) and extent of condition of the problem.

The root cause evaluation methods that are commonly used in nuclear facilities are:

Events and causal factors analysis -- to identify the events and conditions that led up to an event; Fault tree analysis -- to identify relationships among events and the probability of event occurrence;

• Barrier analysis -- to identify the barriers that, if present or strengthened, would have prevented the event from occurring;

• Change analysis -- to identify changes in the work environment since the activity was last performed successfully that may have caused or contributed to the event;

• Management Oversight and Risk Tree (MORT) analysis -- to systematically check that all possible causes of problems have been considered; and

• Critical incident techniques -- to identify critical actions that, if performed correctly, would have prevented the event from occurring or would have significantly reduced its consequences.

A determination of cause and effect relationships should result in an identification of root and contributory causes which consider potential hardware, process, and human performance issues.

NRC Inspection Procedures IP 71152 Objectives and Guidance (Selected portions extracted from the IP)

(Please review the entire IP for more guidance)

A fundamental goal of this inspection is to establish confidence that the licensee is detecting and correcting problems in a manner that limits the risk to members of the public.

Inspection objectives 01.01 To provide for early warning of potential performance issues.

01.04 To allow for follow-up of previously identified compliance issues (e.g. NCVs).

01.06 To determine whether licensees are complying with NRC regulations regarding corrective action programs.

02.03 Biennial Problem Identification and Resolution Inspection Perform a biennial inspection of the problem identification and resolution activities as follows:

a. From among conditions adverse to quality which the licensee has identified and processed through its corrective action process and are associated in some way with risk-significant SSCs, select a sample for review.

b. Review each condition/problem selected for review using the performance attributes contained in paragraph 03.03.c of the procedure.

c. Review recent audits and/or assessments of the licensees corrective action program, and compare and contrast the results of those audits and/or assessments with the results developed through this inspection.

e. Develop an assessment of the licensees implementation of the corrective action process, based on the inspection results developed through steps a. through c..

Inspection guidance To the extent possible, this inspection should follow a performance based approach.

Emphasize the products and results of the licensees PI & R program. Inspections performed under this procedure should concentrate on the identification of problems and the effectiveness of corrective actions for risk significant issues rather than on reviewing the administrative aspects of the corrective action program and associated procedures.

This inspection will examine, in part, a sample of licensee corrective action issues to provide an indication of overall problem identification and resolution performance. In selecting issues for inspection, the inspectors should take the following into considerations:

1. Licensee identified issues (including issues identified during audits or self assessments).

2. NRC identified issues.

3. Issues related to NCVs (for the biennial inspection it is mandatory to review the licensees response to a sample of NCVs unless no NCVs were issued in the cornerstone).

4. Issues identified through NRC generic communications.

5. Issues identified through industry operating experience exchange mechanisms (including Part 21 reports, NSSS vendor reports, EPRI reports, experience reports from similar facilities, LERs).

6. Specific or cross cutting issues identified by safety review committees or other management oversight mechanisms.

7. Issues identified through employee concerns programs.

03.02 Selected Issue Follow-up Inspection

b. Performance Attributes When evaluating the effectiveness of licensee corrective actions for a particular issue, the licensees actions must be viewed against the nature and significance of the identified problem. Risk should be a primary factor in the licensees significance determination. Attributes to consider during review of licensee actions associated with individual issues include the 8 attributes noted in 03.01 above.

In addition to the general performance attributes contained above, the inspector should refer to Inspection Procedure 95001 for additional guidance on assessing licensee evaluations of significant performance issues. It is not expected that the inspectors assess each attribute for every issue selected for follow up during these routine reviews. Rather, inspectors may choose to assess licensee performance against selected attributes, as necessary to be most effective.

03.03 Biennial Problem Identification and Resolution Inspection. The biennial inspection of problem identification and resolution is intended to complement and expand upon the reviews described in Section 03.01 and 03.02 of this procedure by:

1. Evaluating additional examples of licensee problem identification and resolution.

2. Reviewing the resolution of issues that earlier had been assessed for the licensees identification efforts only.

3. Comparing the NRCs results against the licensees own assessment of performance in the PI & R area.

4. Assessing whether PI & R deficiencies exist across cornerstones that might indicate potential programmatic issues.

e. Development of PI&R Program Performance Insights.

By reviewing a sufficient number and breadth of samples, the inspection team should be able to develop insights into the effectiveness of the licensees corrective action program.

f. Documentation and Evaluation of Program Effectiveness.

At the completion of inspection activities, the team should develop a clear and concise discussion of the results of their review.

Corrective Action Guidance from IP 95002 (For Reference only) 02.03 Corrective Actions

a. Determine that appropriate corrective action(s) are specified for each root/contributing cause or that there is an evaluation that no actions are necessary.

b. Determine that the corrective actions have been prioritized with consideration of the risk significance and regulatory compliance.

c. Determine that a schedule has been established for implementing and completing the corrective actions.

d. Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.

03.03 Corrective Action The proposed corrective actions to the root and contributing causes should:

a. Address each of the root and contributing causes to the White issue and the extent of condition of the issue. The corrective actions should be clearly defined.

Examples of corrective actions may include, but are not limited to, modifications, inspections, testing, process or procedure changes, and training.

The proposed corrective actions should not create new or different problems as a result of the corrective action. If the licensee determines that no corrective actions are necessary, the basis for this decision should be documented in the evaluation.

b. Include consideration of the results of the licensees risk assessment of the issue in prioritizing the type of corrective action chosen. Attention should be given to solutions that involve only changing procedures or providing training as they are sometimes over-utilized. In such cases, consideration should be given to more comprehensive corrective actions such as design modifications. The corrective action plan should also include a review of the regulations to ensure that if compliance issues exist, the plan achieves compliance.

Also, the licensee should ensure that:

c. The corrective actions are assigned to individuals or organizations that are appropriate to ensure that the actions are taken in a timely manner. Also, the licensee should ensure that there is a formal tracking mechanism established for each of the specific corrective actions.

d. A method exists to validate the effectiveness of the overall corrective action plan.

Specifically, a method should be established to measure, either quantitatively or qualitatively, the effectiveness of the corrective actions. Effective methods would include, but are not limited to, assessments, audits, inspections, tests, and trending of plant data, or follow-up discussions with plant staff.

02.04 Independent Assessment of Extent of Condition and Generic Implications. Perform a focused inspection(s) to independently assess the validity of the licensees conclusions regarding the extent of condition of the issues. The inspection(s) chosen should be selected from the list contained in Appendix B to Inspection Manual 2515. The objective of this procedure should be to independently sample performance, as necessary to provide assurance that the licensees evaluation regarding extent of condition is sufficiently comprehensive. The intent is not to re-perform the licensees evaluation, but is to assess the validity of the licensees evaluation by independently sampling performance within the key attributes of the cornerstone(s) that are related to the subject performance issue. The results of the NRCs review of extent of condition should be documented in this inspection report.

03.04 Independent Assessment of Extent of Condition

a. In choosing the inspection procedure(s) to assess the validity of the licensees conclusions regarding extent of condition, consideration should be given to whether multiple risk significant performance issues have been identified. For those instances where multiple issues have been documented, a broad based inspection(s) which would assess performance across the associated strategic performance area should be considered. If this procedure is being performed due to a single yellow issue, a more focused inspection would likely be appropriate.

Consideration should also be given to the comprehensiveness of the licensees evaluation(s). In those cases where significant weaknesses are identified in the licensees evaluation(s) during implementation of paragraphs 02.01 through 02.03 of this procedure, consideration should be given to performing a more in-depth programmatic review of the licensees corrective action program.