ML040690008

Commission Briefing on Davis-Besse Lltf Recommendations

ML040690008
Person / Time
Site:	Davis Besse
Issue date:	02/26/2004
From:	Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research
To:
Moroney B, NRR/DLPM, 415-3974
References
Download: ML040690008 (40)

Text

STATUS OF IMPLEMENTATION OF DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATIONS Office of Nuclear Reactor Regulation (NRR)

Office of Nuclear Regulatory Research (RES)

2 Agenda

• Overview J. Dyer

• Stress Corrosion Cracking W. Bateman

• Operating Experience W. Beckner

• Inspection Program Management S. Richards

• Barrier Integrity N. Chokshi

• Summary J. Dyer

3 Overview

• Action Plans developed for 21 High Priority items (3/03)

- Responsible Office

- Schedule

- Resources

4 Overview (cont.)

• Remaining items integrated into individual Office operational activities via Planning, Budgeting and Performance Management (PBPM) process

• Status reported semiannually to EDO and forwarded to Commission

5 Overview (cont.)

• 23 recommendations were scheduled for completion by 12/03

- 16 were completed including all 7 scheduled high priority items

- 7 lower priority rescheduled

• 22 recommendations are planned for completion by 12/04

• 5 recommendations are planned for completion by 12/05

• 6 recommendations TBD

6 Stress Corrosion Cracking (SCC)

• LLTF recommendations incorporated in Action Plan

- SCC and Boric Acid Corrosion database

- SCC susceptibility model evaluation

- ASME Code changes

- 10 CFR 50.55a revision

- Inspection Program Guidance

7 Stress Corrosion Cracking (cont.)

• LLTF recommendations have been combined with previously initiated actions

• Progress being made on activities

• Industry response has been generally positive

8 Stress Corrosion Cracking (cont.)

• Activities completed and ongoing since Davis-Besse

- Bulletin and follow-up questions on licensees boric acid corrosion control programs (BL 2002-01)

- Regulatory Issues Summary (RIS 2002-13) summarizing staff review of responses to BL 2002-01

9 Stress Corrosion Cracking (cont.)

- Bulletin 2002-02 on upper head penetration inspections

- Order EA-03-009 plus revision on upper head inspections

10 Stress Corrosion Cracking (cont.)

- Bulletin 2003-02 on lower vessel head penetration inspections

- Pressurizer Generic Communication

11 Stress Corrosion Cracking (cont.)

• Staff completed review and evaluation of responses to Bulletin 2002-01 regarding Boric Acid Corrosion Control programs and published results in RIS 2003-13 (8/03)

12 Stress Corrosion Cracking (cont.)

• Bulletin 2002-02 on upper vessel head penetration inspection was precursor to the Order

• Interim requirements for Reactor Pressure Vessel head inspection issued through Order EA-03-009 (2/03)

13 Stress Corrosion Cracking (cont.)

• Staff reviewing inspection results and processing requests for alternatives to Order (Ongoing)

• Temporary Inspection Procedure TI 2515/150 was issued for regional inspector guidance (8/03)

14 Stress Corrosion Cracking (cont.)

• Bulletin 2003-02 issued after discovery of leakage on bottom head penetrations at South Texas Project (8/03)

- TI 2515/152 issued (11/03)

- No additional cracking found in inspections to date

15 Stress Corrosion Cracking (cont.)

• Staff and industry responding to pressurizer heater sleeve leaks

- Staff developing generic communication

- Westinghouse Owners Group letter on inspection of Combustion Engineering pressurizer heater sleeves

16 Stress Corrosion Cracking (cont.)

• RES activities related to SCC

- Integrated assessment to support regulatory decisions/actions

- Components of research programs

17 Stress Corrosion Cracking (cont.)

- Cooperative programs

- Results used to support review and confirmation of industry programs

18 Stress Corrosion Cracking (cont.)

• Challenge: Replace interim guidelines in Orders and Bulletins with Rulemaking

- Endorsement of revised ASME code

- Industry working on alternative guidelines and technical justification

19 Stress Corrosion Cracking (cont.)

• Current plan

- Incorporate Order into 10CFR50.55a

• Develop a rulemaking plan

- Also considering developing a performance-based rule

• Needs detailed evaluation

20 Operating Experience

• Interoffice task force defined the objectives and attributes of an effective Operating Experience program

- Report documenting specific program improvement proposals issued in 11/03

21 Operating Experience (cont.)

• Line management to develop implementation plan (4/04)

• Framework to be established by 12/04

- Program will be dynamic and continuous improvements will occur

22 Operating Experience (cont.)

• Key Findings/Recommendations

- Agencys current activities contain necessary functions

- Clear vision lacking of how activities should function together to support licensing, inspection and research

23 Operating Experience (cont.)

• Recommends establishment of clearinghouse within single organization

24 Operating Experience (cont.)

• Improvements to date:

- Organizational alignment of inspection and Operating Experience programs

- Significant enhancement in web-based access

- Improved communications to end users

25 Operating Experience (cont.)

• Separately reviewing previous generic communications to assess effectiveness of commitments

- Initial screening completed (7/03)

- Selection of focus areas completed with management review and input (11/03)

- Verification Plan (3/04)

26 Operating Experience (cont.)

• Implementation Challenges

- Resource intensive

- Effectiveness of interoffice coordination

27 Inspection & Program Management

• The LLTF recommended several changes including:

- More focused inspections and follow-up to longstanding equipment issues

- Enhanced inspector training

- Enhanced oversight structure for plants in extended outages (IMC 0350)

28 Inspection & Program Management (cont.)

• Inspection guidance was revised to require resident inspector screening of all corrective action items

• A new requirement was added to inspection program to perform a semi-annual trend review focused on recurring equipment issues

29 Inspection & Program Management (cont.)

• Program guidance was enhanced regarding NRC oversight of plants in extended shutdowns

30 Inspection & Program Management (cont.)

• A new read and sign training program has been developed and implemented

• Training modules completed include boric acid corrosion, stress corrosion cracking, and the importance of maintaining a questioning attitude

31

• Guidelines were issued for ensuring a more complete documentation of important staff decisions (3/03)

- Follow up effectiveness review in progress Inspection & Program Management (cont.)

32

• Challenges

- Need to enhance process for timely incorporation of operating experience into inspection program Inspection & Program Management (cont.)

33 Barrier Integrity

• The LLTF recommended that the requirements for Reactor Coolant System (RCS) leakage be improved

- Assure that plants do not operate with Reactor Coolant Pressure Boundary (RCPB) leakage

- Plants can discriminate between unidentified leakage and RCPB leakage

34 Barrier Integrity (cont.)

• Initiated research program at Argonne National Laboratory (ANL) to develop technical basis for RCS leakage requirements (7/04)

• Identified units with nonstandard RCPB leakage requirements (7/03)

35 Barrier Integrity (cont.)

• Identified improvements to existing Performance Indicators (PI) (6/04)

- All leakage Technical Specifications (TS) could be monitored by PIs and compared to the allowable limits

36 Barrier Integrity (cont.)

• Barrier Integrity Program at ANL

- Evaluate leak rates associated with degradation of various RCPB components (3/04)

- Develop database of leakage events (4/04)

- Evaluate capabilities of leakage detection systems (5/04)

37 Barrier Integrity (cont.)

• Assess adequacy of plant alarm response procedures (3/04)

• Develop recommendations for inspection guidance and RCS leakage requirements (3/05)

• Develop and, if feasible, implement PI capable of tracking number, duration, and rate of primary system leaks (12/05)

38 Barrier Integrity (cont.)

• Completed preliminary scoping study of risk assessments involving passive component degradation

• Recommend multi-discipline review to identify potential risk from combination of failure mechanisms and RCPB locations

39

• Technical basis will be used to support potential revisions to requirements using appropriate regulatory processes Barrier Integrity (cont.)

40 Summary

• Significant progress on implementing recommendations

• Effort is integrated with other activities

- Ensures efficient and effective use of resources

- Maximizes safety benefit

• Activities have resulted in significant positive outcomes for the agency and nuclear industry