1 

Status of Davis-Besse Lessons Learned Task Force Recomm

Last Update: August 31, 2005

Category: Stress Corrosion Cracking 

LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

3.1.1(1) Assemble foreign and domestic information

concerning Alloy 600 (and other nickel based alloys)nozzle cracking and boric acid corrosion. Analyze nickel based alloy nozzle susceptibility to stresscorrosion cracking (SCC), including other susceptiblecomponents, and boric acid corrosion of carbon steel,and propose a course of action and animplementation schedule to address the results. 

High SCC Complete TBD

Not Req

STATUS: Data collection was accomplished in two phases. Collection of information on cracking was completed 03/31/A test program on boric acid corrosion was completed on 10/22/04 and was published in NUREG/CR-6875, “Boric Acid Water Reactor Pressure Vessel Material” (ML050410026). The information contained in these two reports and a third recracking susceptibility (ML032461221), which was issued on 3/31/04 to address LLTF 3.1.4(1), have been compiled in NPlant Experience with Alloy 600 Cracking and Boric Acid Corrosion of Light-Water Reactor Pressure Vessel Materials” (MBased on the reports, the staff concluded that additional inspections are warranted for identifying leakage from primary wcracking (PWSCC) and for precluding boric acid corrosion as a result of such through-wall leakage. The RES reports procomprehensive set of information that supports and confirms the appropriateness of these conclusions and does not chaperception of the problem. The staff concluded that definitive actions are needed to address shortcomings with the currthese inspections and proposed a plan and schedule for accomplishing them. This completed the LLTF recommendationimplement the plan are being tracked through an NRR action plan that addresses stress corrosion cracking and boric aci
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

2

3.2.2(1) Inspect the adequacy of PWR [pressurized-water

reactor] plant boric acid corrosion control programs,including their implementation effectiveness, todetermine their acceptability for the identification ofboric acid leakage, and their acceptability to ensurethat adequate evaluations are performed for identifiedboric acid leaks.

High SCC 05/05

Complete

05/0

STATUS: The evaluation of responses to Bulletin 2002-01, which included audits of boric acid corrosion control (BACCplants, determined that plants appeared to be complying with requirements at the programmatic level. The results of the summarized in Regulatory Issues Summary (RIS) 2003-13 (ML032100653). The RIS concluded that existing monitoring to be enhanced to ensure early detection and prevention of leakage from the RCPB and provided suggestions for improvprograms.Subsequent inspections conducted at all operating reactor plants have reviewed licensee BACC programs using new insTemporary Instruction (TI) 2515/150, issued on October 18, 2002, which provides guidance for inspecting licensees’ reac(RPV) head inspections pursuant to Order EA-03-009, also includes instructions for follow-up on findings of boric acid acInspection Procedure (IP) 71111.08, “Inservice Inspection Activities,” was revised on 5/11/04 to add periodic inspection rguidance for BACC. Staff review of inspection results from TI 2515/150 and IP 71111.08 and feedback from Region inlicensees’ current programs are generally adequate for locating and evaluating and/or correcting boric acid leaks and the guidance is adequate and effective for oversight of BACC programs. All inspection findings have been categorized as vsignificance. The effectiveness of IP71111.08 will continue to be evaluated as part of annual ROP self-assessment and improvements will be made as needed.

3.3.2(1) Develop inspection guidance for the periodic

inspection of PWR plant boric acid corrosion controlprograms.

High SCC Complete Not requ
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

3

STATUS: Temporary Instruction (TI) 2515/150, issued in 08/03, supports the review of licensees’ RPV head and vessel nozzle inspection activities that are implemented in accordance with the requirements of NRC Order EA-03-009. This Tconforms to its inspection commitments and requirements, during refueling outages, using procedures, equipment, and pbeen demonstrated to be effective in the detection and sizing of PWSCC in VHP nozzles and detection of RPV head waissued in 11/03, provides interim inspection guidance for follow-up to Bulletin 2003-02, which includes BACC programs. 71111.08, “Inservice Inspection Activities”, was revised in 05/04 to add NRC inspection samples to observe and evaluate of PWR RPV head and VHP nozzle inspection activities on a periodic basis consistent with the guidance in TI 2515/150. included guidance and requirements to perform a performance based inspection of licensee’s boric acid program implemThe effectiveness of these inspection procedures will be evaluated as part of LLTF 3.2.2(1) and a separate effectiveness required.

3.3.4(3) Develop inspection guidance or revise existing

guidance to ensure that VHP [vessel headpenetration] nozzles and the RPV head area areperiodically reviewed by the NRC during licensee ISI [inservice inspection] activities. 

High SCC Complete Not requ

STATUS: TI2515/150, issued 08/03, provides interim inspection guidance for follow-up to Order EA-03-009.IP 71111.08, “Inservice Inspection Activities,” was revised on 5/11/04 to add periodic inspection requirements and guidan

head penetration inspections. The effectiveness of these inspection procedures will be evaluated as part of LLTF 3.2.2(1effectiveness review is not required.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

4

3.3.4(8) Encourage ASME [American Society of Mechanical

Engineers] Code requirement changes for bare metalinspections of nickel based alloy nozzles for whichthe code does not require the removal of insulationfor inspections. Also, encourage ASME Coderequirement changes for the conduct of non-visualNDE [nondestructive examination] inspections ofVHP nozzles.Alternatively, revise 10 CFR 50.55a to address theseareas. 

High SCC TBD TBD 

STATUS: Completion of this recommendation depends on industry and ASME actions. Staff will review EPRI/MRP guidexpected to form the basis for ASME code changes, when issued. Issuance has been delayed several times. NRC mancommunicated with industry to encourage timely issuance of proposed guidelines. The NRC Staff also participates in AScommittees. Once the ASME Code requirements are updated, the staff will evaluate them for inclusion by reference into 

Interim inspection requirements have been established by issuance of First Revised Order EA-03-009. Due to the delay Code, the NRC staff initiated action to incorporate Order EA-03-009 guidelines into 10 CFR 50.55a and submitted a ruleCommission approval in 07/04. The Commission decided not to proceed with separate rulemaking and directed the staff with the industry to revise the ASME code (SRM-SECY-04-0115, 8/6/04). The target date for separate rulemaking was dto 10 CFR 50.55a will be done following NRC staff review of industry actions. In June 2005 the ASME Board on NucleaStandards approved Code Case –729, which provides additional inspection requirements for RPV upper heads. Separately, the ASME Board on Nuclear Codes and Standards approved Code Case –722, which recommends bare mexamination of all ASME Code Class 1 alloy 600/82/182 components at frequencies that depend on the temperature of NRC supported development and approval of these code cases. Once these code cases are formally published, the stendorsing them in a revision to 10 CFR 50.55a. These actions will be tracked along with the follow-on actions for LLTF 3NRR action plan that addresses stress corrosion cracking and boric acid corrosion issues. 
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

5

3.1.4(1) Determine if it is appropriate to continue using the

existing SCC models as a predictor of VHP nozzlePWSCC [primary water SCC] susceptibility given theapparent large uncertainties associated with themodels. Determine whether additional analysis andtesting are needed to reduce uncertainties in thesemodels relative to their continued application inregulatory decision making.

Medium SCC Complete Not requ

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

inspections. It has been used in the development of inspection requirements in Order EA-03-009 and the bulletins that pInspection results to date have been consistent with model predictions and do not indicate a need for revising the model report by the Office of Nuclear Regulatory Research, issued 7/21/03 (ML032461224 and ML032461221), identified refinemade to the model. These improvements are not needed to satisfy this recommendation and will require research activithe scope of the LLTF recommendation. The report will be issued in a NUREG together with the reports required for LLT

3.3.7(6) Determine whether ISI summary reports should be

submitted to the NRC, and revise the ASMEsubmission requirement and staff guidance regardingdisposition of the reports, as appropriate. 

Low SCC 05/05

Complete

05/0

Not Req
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effective

Revie

6

STATUS: The staff has reviewed the uses of the ISI reports and concludes that it is appropriate to continue to have the 

the NRC, so that there is no need to revise the ASME requirements. In particular, the Regions use the ISI reports for insto follow up on issues associated with inspection procedure IP 71111.08, “Inservice Inspection Activities.” In addition, thRegulatory Research reviews the ISI reports to trend aging effects and material degradation, in order to develop recommand standards activities.The staff has determined, however, that the NRR practice of reviewing the ISI reports is unnecessary. In the future, the review the ISI reports; rather, since the reports should still be submitted for other reasons, the reports will be available wh

that the NRR staff should use them as references in support of the operating experience program. No effectiveness revi
7

Category: Operating Experience 

LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

3.1.6(1) Take the following steps to address the effectiveness

of programs involving the review of operatingexperience: (1) evaluate the agency’s capability toretain operating experience information and toperform longer-term operating experience reviews;(2) evaluate thresholds, criteria, and guidance forinitiating generic communications; (3) evaluateopportunities for additional effectiveness andefficiency gains stemming from changes inorganizational alignments (e.g., a centralized NRCoperational experience “clearing house”);(4) evaluate the effectiveness of the Generic IssuesProgram; and (5) evaluate the effectiveness of theinternal dissemination of operating experience to endusers.

High OpE Complete 12/

STATUS: This action required the evaluation of various aspects of the agency’s operating experience program. This acfoundation of the charter for to Operating Experience Task Force (OETF) [ML031200535]. The OETF documented its evthrough (5) of the recommendation in its report dated 11/26/03 (ML033350063). The OETF made 23 recommendations effectiveness of the agency’s operating experience program that are currently being implemented in accordance with the Experience Action Plan dated 4/29/04 (ML041180024).
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

8

3.1.6(2) Update NRC operating experience guidance

documents.

High OpE Complete 12/

STATUS: This LLTF recommendation is directed at the fact that Management Directive (MD) 8.5, “Analysis and EvaluatData” had not been updated since the dissolution of the Analysis and Evaluation of Operational Data organization and thOperating Experience Program responsibilities to NRR and RES. However, NRR Office Instruction, LIC-401, “NRR OpeProgram,” was issued in March 2003 to reflect the current practices of NRR’s Operating Experience Section located in thInspection Program Management.As part of the Operating Experience Action Plan (ML041180024), which implemented the recommendations of the OperaForce (ML033350063), the staff developed MD 8.7, “Reactor Operating Experience Program” (ML043570013, ML043570to NRR Office Instruction, LIC-401 (ML043570075) as the framework for a new operating experience program.On December 22, 2004, the Office Directors of NRR and RES authorized the staff to begin implementation of MD 8.7, in year prior to its final issuance. Also, the Director of NRR authorized implementation of NRR Office Instruction, LIC-401pending completion of final editing and administrative processing. 

3.1.6(3) Enhance the effectiveness of NRC processes for the

collection, review, assessment, storage, retrieval, anddissemination of foreign operating experience.

High OpE Complete 12/
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

9

STATUS: At the time of this recommendation, foreign operating experience, such as that received through the IAEA Inc

System (IRS), was only communicated and distributed in an ad hoc fashion. Today, it is a formal element of the NRC OSection screening process and available on the internal web site.NRR Office Instruction LIC-401, “NRR Operating Experience Program,” was issued on 3/31/03. This office instruction inenhance the effectiveness and utilization of foreign operating experience within the Operating Experience Section. This 

enhanced upon implementation of the Operating Experience Action Plan (ML041180024). An overall effectiveness revieapproximately one year following implementation of the action plan.

3.2.4(1) Assess the scope and adequacy of requirements

governing licensee review of operating experience.

High OpE Complete 12/

STATUS: This assessment was performed as part of the Operating Experience Task Force Report (ML033350063), whiNovember 26, 2003. Section 5 of this report concludes that the scope and adequacy of the requirements related to the l

operating experience are currently acceptable. Inspection Procedure 71152, “Identification and Resolution of Problems,” procedure for evaluating licensee utilization of operating experience, and the Operating Task Force found that recent cha

procedure (Change Notice 03-032) enhanced NRC baseline inspection efforts.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

10

3.3.1(1) Provide training and reinforce expectations to NRC

managers and staff members to address thefollowing areas: (1) maintaining a questioningattitude in the conduct of inspection activities;(2) developing inspection insights stemming from theDBNPS [Davis-Besse Nuclear Power Station] eventrelative to symptoms and indications of RCS [ReactorCoolant System] leakage; (3) communicatingexpectations regarding the inspection follow-up of thetypes of problems that occurred at DBNPS; and(4) maintaining an awareness of surroundings whileconducting inspections. Training requirementsshould be evaluated to include the appropriate mix offormal training and on-the-job training commensuratewith experience. Mechanisms should be establishedto perpetuate these training requirements. 

High OpE Complete 05/

Comp
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

11

STATUS: The focus of this recommendation is on regional staff. The Inspection Program Branch developed a web-basbased on the Columbia Space Shuttle Accident to (1) illustrate the importance of maintaining a questioning attitude towapotential negative consequences that can occur when such a questioning attitude is lost or compromised; (2) provide exaconcerning an organization’s safety culture can lead to technological failures; (3) provide insights into investigation technused to assess safety significant issues or events; and (4) illustrate the importance of a robust corrective action program corrective action program weaknesses that contributed to the shuttle accident. The Regions provided documentation that all managers and inspectors required to complete the training on the Columbia completed the training. In addition, IMC 1245, “Qualification Program for the Office of Nuclear Reactor Regulation Proginclude this web-based training program as an individual study activity for future inspectors. The IMC 1245 Management Steering Group and IMC 1245 Working Group annually review the effectiveness of inspectofeedback forms submitted, results of the inspector oral boards, and regional experience. Improvements and revisions arimplemented as appropriate. In addition, the Regions encourage a questioning attitude during semiannual inspector counewsletters discussing value-added findings, and during periodic reactor oversight process refresher training. The traininthis recommendation was effectively implemented in 2003 and will be continually reviewed as part of the inspector trainiand regional management attention.

3.3.4(2) Strengthen inspection guidance pertaining to the

periodic review of operating experience. 

High OpE Complete 05/

Comp
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

12

STATUS: The inspection guidance pertaining to the periodic review of operating experience has been strengthened throProblem Identification and Resolution Inspection Procedure 71152 on 9/8/03. This revision specifically requires the reviebasis, of the issues identified through the past NRC generic communications. A fundamental goal of the NRC’s reactor oestablish confidence that each licensee is detecting and correcting problems. This inspection procedure’s purpose is to sbaseline inspection procedures and the performance indicators to provide assurance that licensees adequately identify aIssues identified through operating experience are an integral part of that assessment.  The effectiveness of the changes to IP 71152 was reviewed by verifying that: (1) the planned procedure revisions were to inspectors, (2) the latest version of the inspection procedure was being used, (3) the inspection guidance pertaining to operating experience was strengthened, and (4) there were no unintended consequences. The staff reviewed 30 inspectdocumented the results of completing IP 71152 inspections (fifteen reports each from 2004 and 2005 with a mix from eaThe review determined that the four criteria were met. In addition, a pilot inspection program conducted in 2005 resulted the procedures for inspecting licensee use of operating experience in the design and engineering areas. The staff conclu

changes were effectively implemented and the inspection guidance pertaining to the periodic review of operating experiestrengthened. IP 71152 will continue to be evaluated on an ongoing basis as part of the annual ROP self-assessment pro

3.3.5(1) Maintain expertise in the subject areas by ensuring

that NRC inspector training includes: (1) boric acidcorrosion effects and control; and (2) PWSCC ofnickel based alloy nozzles. 

High OpE Complete 05/

Comp
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

13

STATUS: Training modules on these topics have been included in the web-based training described under 3.3.1(1). The the current NRC understanding and approach to monitoring boric acid corrosion and shows photographs of the Davis-Becutaway drawing of the degradation. A training module on the “Effects of Corrosion,” which includes both PWSCC and BACC, was completed by all current inInspection Manual Chapter (IMC) 1245, “Qualification Program for the Office Of Nuclear Reactor Regulation Programs,” Proficiency-Level Training and Qualification Journal” (ML041820014), was revised to include an individual study activity inspectors to review the technical subject web-based training, which includes the training on PWSCC and BACC, as well training items. This action was effectively implemented in 2004 and the Regions documented that all appropriate managers and inspecttraining. In the long term, the training was added to the IMC 1245 requirements. In addition, during 2005, the Inspectiowork with the Materials Engineering Branch of the Division of Engineering Technology in the Office of Nuclear Regulatorthe training material. The training associated with this recommendation will be continually reviewed as part of the inspecreviews and regional management attention.

3.1.2(1) Revise NRC processes to require short-term and

long-term follow-on verification of licensee actions toaddress significant generic communications (i.e.,bulletins and GLs).

Medium OpE Complete 12/

STATUS: NRR Office Instruction LIC-503, “Generic Communications Affecting Nuclear Reactor Licensees,” was revised 

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

3.1.2(2) Establish review guidance for accepting owners

group and industry resolutions for genericcommunications and generic issues. Guidanceshould include provisions for verifying implementationof activities by individual owners groups andlicensees.

Medium OpE Complete 06/

10/
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

14

STATUS: NRR Office Instruction LIC-503, “Generic Communications Affecting Nuclear Reactor Licensees,” was revised include guidance regarding review of owners group and industry resolution to generic communications. Guidance for accadded to the sections addressing origin and closeout of generic communications. The revision requires the staff to estabfor accepting owners group and industry proposals during the preparation of a generic communication and to establish crowners group and industry resolutions during closeout. NRR Office Instruction LIC-105, “Managing Regulatory CommitmLicensees to the NRC,” was revised in August 2004 to include guidance on accepting regulatory commitments made by towners groups.With regard to verification, LIC-503 requires an assessment of the method to be used for verifying licensee responses duof a generic communication. One method is by use of a temporary instruction (TI) and guidance for the preparation of a alternative to a TI is verification of licensee responses through DLPM Project Managers’ audits of regulatory commitmenaccordance with LIC-105. LIC-105 provides detailed guidance for conducting the audits. LIC-105 also directs lead PMs communications to provide guidance for verification of owners group or industry commitments in conducting periodic audaccepted in response to the generic communication, and directs PMs to review generic communication guidance in the ssample. The “Commitment Management Program,” section of the DLPM Handbook provides an overview of DLPM management NRR staff guidance for handling regulatory commitments made by licensees for commercial nuclear reactors, and providThe target date for the effectiveness review was extended to allow a full year of experience with the new procedures befreview.

3.1.2(5) Conduct follow-on verification of licensee actions

associated with a sample of other significant genericcommunications, with emphasis on those involvinggeneric communication actions that are primarilyprogrammatic in nature.

Medium OpE Complete Not Re
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

15

STATUS: A task force performed a screening process of candidate generic communications in 07/03 using criteria approSelection of generic communications and focus areas was completed in 11/03 following management review and input oVerification plan was presented to NRR LT in 12/03 and revised to address comments. Five focus areas were initially id(Service Water) were being addressed by other initiatives. Through TI 2515/159 (issued 7/29/04) a sample review of thregion was conducted to verify licensee actions in response to GL 89-13, “Service Water Problems Affecting Safety-Relaaddition, a follow-up to RIS 2004-05, “Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power,” 

through TI 2515/156 to determine if the RIS accomplished its purpose of raising industry awareness of the potential impaon nuclear power plants.The staff concluded that GL 89-13 was generally effective in addressing issues associated with service water systems, adeficiencies exist and licensees continue to address operational issues. The staff believes that the effectiveness of this the comprehensive follow-on NRC inspections after the issuance of the GL and by the ongoing inspection program oversTI2515/159 was an effective method for assessing GL 89-13 effectiveness. The staff concluded that RIS 2004-05 was effective in informing licensees of NRC expectations in the area of offsite powAdditionally, TI 2515/156 was an effective method of collecting additional operational data. 

3.1.3(2) Conduct follow-on verification of licensee actions

pertaining to a sample of resolved GIs.

Medium OpE Complete Not Re

STATUS: The staff obtained a list of all resolved GIs, which indicated that 20 GIs have been resolved since 1983. All bresolved by issuance of generic communications (GCs). One remaining issue was resolved by plant-specific backfits, anwithout further action. Thus, a follow-on verification of resolved GIs would essentially require a verification of GCs.However, a follow-on verification of GCs was conducted separately in response to LLTF Item 3.1.2(5), which selected GCscreening process of all GCs that considered safety significance, risk significance, functional area and other factors, and the NRR, RES and Region Offices in establishing priority for follow-up. Only two of the 19 GCs used to resolve GIs matpriority list determined for LLTF Item 3.1.2(5), and one of these is the subject of one of the TIs being used to close out LLconcluded that the response to LLTF 3.1.3(2) would be effectively implemented by the completion of LLTF 3.1.2(5) and a activity was unnecessary.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

16

3.2.3(1) Review a sample of NRC safety evaluations of

owners’ group submissions to identify whetherintended actions that supported the bases of theNRC’s conclusions were effectively implemented.

Medium OpE Complete Not Re

STATUS: The basis for this recommendation was a 1993 request from the NRC to pressurized-water reactor owners grosafety evaluation (SE) documenting why no unreviewed safety question existed for Alloy 600 nozzle cracking. The BabcOwners Group provided a report that included a statement that B&W plants had developed plans to visually inspect contfor boric acid deposits. The applicable commitment was not effectively incorporated at Davis-Besse. In general, the NRC staff does not accept owners’ group commitments on behalf of licensees, and it appears that the paras the basis for Davis-Besse LLTF recommendation 3.2.3(1) was unique. The DLPM lead project managers for each of through individual research and discussion with their respective vendors, were unable to identify any other NRC SEs of osubmissions related to a generic issue that required an action to be implemented by industry. The NRR technical staff adid not know of any documentation of this nature.Therefore, after a thorough search by the owners group lead project managers, vendors, and NRR technical staff, it was SEs similar to the one described in the recommendation are not available, and LLTF 3.2.3(1) was closed.

3.2.3(2) Develop general inspection guidance for the periodic

verification of the implementation of owners groups’commitments made on behalf of their members.

Medium OpE Complete 06/

10/
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

17

STATUS: NRR Office Instruction LIC-503, “Generic Communications Affecting Nuclear Reactor Licensees,” was revised include guidance regarding review of owners group and industry resolution to generic communications. Guidance for accadded to the sections addressing origin and closeout of generic communications. The revision requires the staff to estabfor accepting owners group and industry proposals during the preparation of a generic communication and to establish crowners group and industry resolutions during closeout. NRR Office Instruction LIC-105, “Managing Regulatory CommitmLicensees to the NRC,” was revised in August 2004 to include guidance on accepting regulatory commitments made by towners groups.With regard to verification, LIC-503 requires an assessment of the method to be used for verifying licensee responses duof a generic communication. One method is by use of a temporary instruction (TI) and guidance for the preparation of a alternative to a TI is verification of licensee responses through DLPM Project Managers’ audits of regulatory commitmenaccordance with LIC-105. LIC-105 provides detailed guidance for conducting the audits. LIC-105 also directs lead PMs communications to provide guidance for verification of owners group or industry commitments in conducting periodic audaccepted in response to the generic communication, and directs PMs to review generic communication guidance in the ssample. The “Commitment Management Program,” section of the DLPM Handbook provides an overview of DLPM management NRR staff guidance for handling regulatory commitments made by licensees for commercial nuclear reactors, and providThe target date for the effectiveness review was extended to allow a full year of experience with the new procedures befreview.

3.1.2(3) Establish process guidance to ensure that generic

requirements or guidance are not inappropriatelyaffected when making unrelated changes toprocesses, guidance, etc. (e.g., deleting inspectionprocedures that were developed in response to ageneric issue).

Low OpE Complete 08/

Comp
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

18

STATUS: Language was added to IMC 0040, “Preparing, Revising and Issuing Documents for the NRC Inspection Manuinspection requirements are not removed that were previously inserted to emphasize licensee performance in areas idenLetter or Nuclear Regulatory Commission (NRC) Bulletin (IMC 0040, Change Notice 04-003, ADAMS Accession # ML0402/2/04). This is a permanent modification to the NRC Inspection Manual, applicable to all changes. The revised Manual Chapter requires that the previous four (4) years of changes be reviewed. An effectiveness review idetermined that no requirements had been deleted, and also identified a procedure improvement that will enable historicrequirements beyond 4 years. The Inspection Manual change process will be updated with the new requirements.

3.1.3(1) Evaluate, and revise as necessary, the guidance for

proposing candidate GIs.

Low OpE Complete 05/

STATUS: The staff has completed an evaluation of the guidance for proposing candidate Generic Issues (GIs) in Manag6.4, "Generic Issues Program." A revision of the Handbook 6.4 to address the DBLLTF recommendation to enhance anprocess was completed by 10/04 and inter-office/regional review and comments were obtained in accordance with MD 1Management Directive System." That action met the intent of DBLLTF recommendation and closed out this task.

3.3.4(7) Reassess the basis for the cancellation of the

inspection procedures that were deleted byInspection Manual Chapter, Change Notice 01-017 todetermine whether there are deleted inspectionprocedures that have continuing applicability. Reactivate such procedures, as appropriate.

Low OpE 03/05

Complete

05/

Not req

STATUS: A review of 80 procedures deleted by Change Notice CN01-017 was conducted to determine if there were aprocedures that have continuing applicability. Four inspection procedures were determined to have continuing applicab

reactivated. These were IP56700, “Calibration,” IP82201, “Emergency Detection and Classification,” IP82202, “ProtectMaking,” and IP90700, “Feedback of Operating Experience Information at Operating Power Reactors.” This action was eeffectiveness review of the previous decision and no additional effectiveness review is required. The procedures will be the annual ROP self-assessment.
19
20

Category: Inspection Programs 

LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

3.2.5(2) Revise inspection guidance to provide assessments

of: (1) the safety implications of long-standing,unresolved problems; (2) corrective actions phased inover several years or refueling outages; and(3) deferred modifications.

High Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

21

STATUS: Inspection Procedure (IP) 71152, "Identification and Resolution of Problems," was revised to require the residperform a screening review of each item entered into the corrective action program. The intent of this review is to be aleas repetitive equipment failures or human performance issues that might warrant additional follow-up through other baseprocedures. IP 71152 was also revised to require a semi-annual review to identify trends that might indicate the existencsignificant safety issue. Included within the scope of this review are repetitive or closely related issues that may have bethe licensee outside the normal corrective action program, such as in trend reports or performance indicators, major equrepetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assuranreports, self-assessment reports, maintenance rule assessments, or corrective action backlog lists.To address the issue of deferred modifications, the staff revised IP 71111.15, "Operability Evaluations." The objective oreview operability evaluations affecting mitigating systems and barrier integrity to ensure that operability is properly justif

component or system remains available, such that no unrecognized increase in risk has occurred. The procedure was redeferred modifications as one of the areas an inspector can assess to ensure that structures, systems, and components aperforming their design function. 

The effectiveness of the changes to IP 71152 was discussed during a problem identification and resolution focus group mMarch 11, 2005. The consensus of the group members was that the changes have resulted in no unintended consequenexpectations that inspectors have a questioning attitude, and provide a method for highlighting issues that might be indicsignificant problem. In addition, semiannual trend reviews have successfully identified negative equipment trends. In sonegative trends may not have been documented if the inspection guidance had not been changed. There has been sominspectors requesting additional guidance on how to conduct the semiannual trend reviews. The inspection guidance in tdeliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issues that might not fit well elsinspection program. Overall, the changes were effectively implemented and addressed the recommendations. IP 71152 

evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.5(4) Develop guidance to address the impacts of

IMC 0350 implementation on the regionalorganizational alignment and resource allocation.

High Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

22

STATUS: The Inspection Program Branch completed an evaluation of the IMC 0350, “Oversight of Operating Reactor FCondition with Performance Problems," process in June 2003, (ML031890873). It identified the need for specifically budIMC 0350 inspections and providing prescriptive inspection guidelines for the process. The budget estimate was increasbeyond (ML033010385) to account for one IMC 0350 plant per year. IMC 0350 was revised in December 2003, to providinspection guidelines. Davis-Besse remained the only plant under the IMC 0350 process during CY 2004. At the time of the effectiveness revieplants had been considered for IMC 0350 oversight since the implementation of the DBLLTF recommendations. HoweveDavis-Besse Oversight Panel and other stakeholders indicated that the procedural and budgetary changes have been geaddressing the concerns noted by the DBLLTF, particularly in the allocation of resources and implementation of the comand oversight guidance. In addition, in accordance with the guidance in IMC 0350, the Davis-Besse Oversight Panel is drecommended improvements to the process based on additional lessons learned. Accordingly, the staff will revise IMC 0address these recommendations and further improve the process. The IMC 0350 process, including these procedural anchanges, will also continue to be evaluated for efficiency and effectiveness as part of the annual ROP self-assessment p

3.3.7(2) Establish guidance to ensure that decisions to allow

deviations from agency guidelines andrecommendations issued in generic communicationsare adequately documented.

High Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

23

STATUS: Guidance on documenting decision making and a training package containing applicable reference material wDLPM Handbook update and placed on the Project Managers web site in 02/03. In 04/03, the NRR Director distributed tto other NRR divisions by e-mail, and the Deputy EDO for Reactor Programs forwarded it by memorandum (ML0303001and the regions.Office Instruction LIC-503, “Generic Communications Affecting Nuclear Reactor Licensees,” issued in 06/03, contains gudocumenting review and closeout of generic communications. A revision in 07/04 added the specific requirement for dofor allowing deviations from generic communications.The intent of the LLTF 3.3.7(2) was met by the above actions. An effectiveness review of distributing the guidance indicrefresher training for licensing Project Managers. This was conducted at DLPM staff meetings in 06/04 and 03/05. The been included in the Project Manager qualification program, so all new PMs will be made aware of the requirements. An for generic communication closeout recommended more specific guidance in LIC-503, which was added in the 07/04 rev

3.2.5(1) Develop inspection guidance to assess scheduler

influences on outage work scope.

Medium Insp Complete 05/

Com

STATUS: Operability of plant structures, systems, and components was considered to be the fundamental operative regTherefore, Inspection Procedure (IP) 71111.15, “Operability Evaluations,” was modified (IP 71111.15, Change Notice 04

dated 2/2/04) to include deferred modifications (potentially deferred due to outage schedular pressure as well as other repopulation of items from which to sample for the adequacy of a licensee’s process for ensuring operability of all plant sysand continuous monitoring. In addition, existing IP 71111.20, "Refueling and Other Outage Activities" assesses the adeqactions to mitigate and control the changes in plant risk during outage activities. The effectiveness of the regional impleinspection procedures are evaluated annually and the results are documented in the annual Reactor Oversight Process sSECY paper.The staff’s review of inspection results and region feedback regarding implementation of these changes did not identify aissues or findings resulting from the IP revisions. IPs 71111.15 and 71111.20 will continue to be evaluated on an ongoin

annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 0801, “Reactor Feedback Program.”
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

24

3.3.1(2) Develop inspection guidance to assess repetitive or

multiple TS action statement entries, as well as, theradiation dose implications associated with repetitivetasks.

Medium Insp Complete 05/

Com

STATUS: IMC 2515, Appendix D, Plant Status, was revised in 05/04 to evaluate licensee actions when operating with munplanned Technical Specification (TS) action statements, and included inspection guidance for assessing radiation dose associated with repetitive tasks. These procedure changes were reviewed and commented on by the regional staff and aimplementation.The staff’s review of inspection results and feedback from each Region regarding the implementation of these changes ilicensees were neither operating with excessive repetitive or multiple TS action statement entries nor causing any signifiworkers as a result of repetitive tasks. The licensees’ actions were consistent with TS requirements and occupational radguidance. No implementation issues or findings were identified in this area. IMC 2515 will continue to be evaluated on a

part of the annual ROP assessment process and as part of the procedure feedback process in accordance with IMC 080

3.3.3(1) As an additional level of assurance, identify

alternative mechanisms to independently assessplant performance as a means of self-assessing NRCprocesses. Once identified, the feasibility of suchmechanisms should be determined.

Medium Insp Complete 05/
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

25

STATUS: The staff researched plant assessments performed by independent parties and identified two (Institute of NucOperations (INPO) and International Atomic Energy Agency (IAEA) that could be used as a means of self-assessing the plant performance assessment process. Inspection Manual Chapter (IMC) 0305, “Operating Reactor Assessment PrograDecember 21, 2004 (ML043560249), to include consideration of these independent assessments during the mid-cycle an

assessment preparations. During the assessment preparations, the staff will determine if there are possible plant performnot identified by the NRC, and if so, make a determination if baseline inspection resources should be directed to evaluatdeficiencies. In addition, this information will be assessed during the annual reactor oversight process self-assessment tprocess changes are warranted. 

3.3.4(1) Review inspection guidance pertaining to refueling

outage activities to determine whether the level ofinspection effort and guidance are sufficient given thetypically high level of licensee activity during relativelyshort outage periods. The impact of extendedoperating cycles on the opportunity to inspect inside

containment and the lack of inspection focus onpassive components should be reviewed. Thisreview should also determine whether the guidanceand level of effort are sufficient for inspecting otherplant areas which are difficult to access or whereaccess is routinely restricted.

Medium Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

26

STATUS: Inspection Procedure (IP) 71111.20 “Refueling and Other Outage Activities” was revised to include containmconsideration of walkdowns in other restricted areas (IP 71111.20, Change Notice 04-011, ADAMS Accession #ML04128In addition, the inspection of passive component integrity is being increased in response to DBLLTF items 3.3.2(1) and 3enhanced inspection of licensee inservice inspection activities, including boric acid corrosion control. The effectiveness implementation of these inspection procedures are evaluated annually as part of the annual Reactor Oversight Process sRegion feedback identified a need to expand on the IP 71111.20 guidance to ensure proper focus during outages on strucomponents that are inaccessible during power operations. However, prior to the 5/6/04 revision, the Regions had used opportunities to inspect plant areas that are only accessible during outages. This includes inspections under other IPs in and environmental conditions (i.e., high temperature) were identified as limiting factors for containment walkdowns in sevreactors, which indicates that containment type should be factored into containment walkdown guidance. This is being epotential IP 71111.20 revision. IP 71111.20 will continue to be evaluated on an ongoing basis as part of the annual ROP and as part of the procedure feedback process in accordance with IMC 0801.

3.3.4(4) Revise IMC 0350 to permit implementation of IMC

0350 without first having established that a significantperformance problem exists, as defined by the ROP.

Medium Insp Complete 05/

Com

STATUS: IMC 0350 was revised 12/31/03 to state that a plant can be considered for oversight under the IMC 0350 procoperational event has occurred. The next revision to IMC 0350 will revise the title to reflect this change.Davis-Besse remained the only plant under the IMC 0350 process during CY 2004. At the time of the effectiveness revieplants had been considered for IMC 0350 oversight since this change was made in December 2003. However, feedback Besse Oversight Panel and other stakeholders indicates that this change and those noted under DBLLTF item number 3effective in addressing the concerns noted by the DBLLTF, particularly in the allocation of resources and implementation comprehensive inspection and oversight guidance. The IMC 0350 process, including this particular change, will continue 

efficiency and effectiveness as part of the ROP self-assessment process on an annual basis.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

27

3.3.4(5) Review the range of NRC baseline inspections and

plant assessment processes, as well as other NRCprograms, to determine whether sufficient programsand processes are in place to identify andappropriately disposition the types of problemsexperienced at DBNPS. Additionally, provide morestructured and focused inspections to assesslicensee employee concerns programs and safetyconscious work environment (SCWE). 

Medium Insp Complete TB

Not Re

STATUS: The Inspection Program Branch (IIPB) reviewed the NRC baseline inspection program and plant assessment the annual Reactor Oversight Process (ROP) self-assessment in April 2004, and also reviewed completed DBLLTF itemBased on these reviews, the staff has enhanced the baseline inspection program by (1) requiring the screening of all liceitems, (2) performing a semi-annual trend review focused on recurring equipment issues, (3) requiring containment walkdoutages, (4) reviewing deferred modifications, and (5) evaluating licensee actions when operating with multiple, repetitivtechnical specification action statements. The staff has enhanced the plant assessment process by (1) strengthening the extended shutdowns, (2) requiring more complete documentation of important staff decisions, and (3) budgeting resourceManual Chapter 0350 plants. The staff has also enhanced the ROP by (1) requiring training on boric acid corrosion, streand the importance of a questioning attitude, and (2) requiring annual refresher training on different aspects of the ROP. actions, the first half of this DBLLTF action item is complete.Regarding the second half of this item, on August 30, 2004, the Commission issued a Staff Requirements Memorandum disapproved an option to develop an inspection process to systematically assess safety culture. Instead the SRM requireenhance the ROP treatment of cross-cutting issues to more fully address safety culture. The SRM noted that the staff shobservations and other indicators already available to the NRC, should develop tools that allow inspectors to rely on morshould consider including enhanced problem identification and resolution initiatives, and should ensure that the inspectorin the area of safety culture. Based on this direction from the Commission, the staff will work with the appropriate stakehmore structured inspection and guidance in the area of safety culture, which encompasses SCWE. As a result of the Cothe DBLLTF item to provide more focused inspections on employee concerns programs and SCWE has been supersedeand will be tracked separately in response to the SRM. Therefore, the second half of this recommendation is complete. any changes made to the ROP will be evaluated as part of the annual ROP self-assessment.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

28

3.3.7(1) Reinforce expectations for the implementation of

guidance in the PM handbook for PM site visits,coordination between PMs and resident inspectors,and PM assignment duration. Reinforce expectationsprovided to PMs and their supervisors regarding thequestioning of information involving plant operationand conditions. Also, strengthen the guidancerelated to the license amendment review process toemphasize the need to consider current systemconditions, reliability, and performance data in SERs. In order to improve the licensing decision-makingprocess, the NRC should strengthen its guidanceregarding the verification of information provided bylicensees.

Medium Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

29

STATUS: Several of these recommendations are addressed, at least in part, by existing procedures.The “Site Visits” section of the DLPM Handbook provides guidance to PMs on activities to be conducted during site visitssection discusses interactions with Region personnel. Office Instruction LIC-100, Rev. 1 (issued 01/04) provides guidanccurrent conditions during licensing action reviews. Office Instruction LIC-101 provides guidance on the amendment revieRequests for Additional Information (RAI)for obtaining information. IP 71005 (issued 08/03) provides a mechanism for Pinspector (RI) support in obtaining plant information. In addition, a memo from the DLPM Director to the DLPM staff (6/2clarification of management expectations for PM site visits, coordination between PMs and resident inspectors, PM assigquestioning of information, and verifying information provided by licensees. This also has been discussed at division anmeetings. The DLPM handbook and appropriate Office Instructions were updated to include this additional guidance . The effectiveness review determined that this recommendation was successfully implemented. In general, PMs visited twith the expectation, although travel and budget constraints, special assignments such as the security plan review team, issues resulted in some PMs not visiting their sites.With regard to PM assignment duration, a review of 34 PM reassignments that occurred between May 2004 and June 20were due to medical reasons, retirements, resignations, permanent rotations to other divisions, and temporary rotations tOf the 18 remaining transfers, the average time the previous PM was assigned to the plant was 3.44 years. PM assignmless than the desired length but within the control of the office) was documented in memos from Project Directors. Most PMs include the Region and RI during the licensing review and when drafting the safety evaluation. Verification of by licensees is being accomplished, as evidenced by the identification of deficiencies with licensee submittals on a few oaction and attentiveness by several PMs resolved complicated issues by supplying plant operational information to the tesending the licensee an RAI. Communications between the PM, RI and the technical staff took various forms. Sharing othe Resident and the PM led to many successful reviews and the capturing of potential safety issues. Some examples acooperation on heavy loads accident analysis; an RI provided operational information that the licensee's foreign materiaprogram had deficiencies and the licensee took steps to correct those issues prior to approval of an amendment that relieprogram; and, an RI provided information on the lack of margin for the ultimate heat sink and an emergency TS change examples demonstrate that the PMs work with RIs and the region to consider current plant conditions, question and veriflicensee, and improve the licensing decision-making process. 

APP. F Conduct an effectiveness review of the actions taken

in response to past lessons-learned reviews.

Medium Insp Complete 05/

Not Re
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

30

STATUS: A task force conducted the recommended review and issued its report on 8/2/04 (ML042110287). This complwork required by this LLTF recommendation and, since the Appendix F effort was itself an effectiveness review, an additreview is not required. However, the report findings and recommendations are being addressed. The task force found that, while previous lessons learned reviews were thorough and produced good recommendations, effectively implemented. It recommended development of an agency-wide corrective action program. This recommendmanagement and endorsed by the Commission in its 12/15/04 SRM (ML043500639). The EDO formed a team to develprogram that addresses the task force report and the SRM. The team is developing a program that will address lessons special attention from high-level, multi-office or agency level lessons that stem from organizational failures. The program through a phased approach. Program definition and draft documentation will be developed by December 31, 2005. Folland staff training, the base program will be implemented by June 2006. The team’s activities are being tracked and repothe Davis-Besse LLTF recommendations.Specific items from the previous lessons learned reports that were identified for additional follow-up have been entered icorrective action program and will be tracked to completion by that process.

3.3.2(2) Revise the overall PI&R inspection approach such

that issues similar to those experienced at DBNPSare reviewed and assessed. Enhance the guidancefor these inspections to prescribe the format ofinformation that is screened when determining whichspecific problems will be reviewed. 

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

31

STATUS: The Inspection Program Branch issued a revision in 09/03 to Inspection Procedure (IP) 71152, “Identification Problems,” to include an inspection requirement to perform a semi-annual review to identify trends that might indicate thsignificant safety issue. Training to inform the inspection staff of this change to IP 71152 was conducted using web-basup conference calls between the regions and the program office. The training was documented as complete in May 2004The effectiveness of the changes to IP 71152 addressing the DBLLTF recommendations was discussed during a problem resolution focus group meeting held on March 11, 2005. The consensus of the group members was that the changes haunintended consequences, have reinforced expectations that inspectors have a questioning attitude, and provide a methissues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conprogram office, have highlighted and communicated semiannual trend reviews that have been successful at identifying ntrends. In some cases, these negative trends may not have been documented if the inspection guidance had not been cbeen some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. Tguidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issuewell elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommwill continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.2(3) Provide enhanced Inspection Manual Chapter

guidance to pursue issues and problems identifiedduring plant status reviews.

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

32

STATUS: IP 71152, “Problem Identification and Resolution,” was revised in 09/03 to require the resident inspector to pereview of each item entered into the corrective action program. The intent of this review is to be alert to conditions such equipment failures or human performance issues that might warrant additional follow-up through other baseline inspectioThe effectiveness of the changes to IP 71152 addressing the DBLLTF recommendations was discussed during a problem resolution focus group meeting held on March 11, 2005. The consensus of the group members was that the changes haunintended consequences, have reinforced expectations that inspectors have a questioning attitude, and provide a methissues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conprogram office, have highlighted and communicated semiannual trend reviews that have been successful at identifying ntrends. In some cases, these negative trends may not have been documented if the inspection guidance had not been cbeen some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. Tguidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issuewell elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommwill continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.2(4) Revise inspection guidance to provide for the

longer-term follow-up of issues that have notprogressed to a finding.

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

33

STATUS: IP 71152, “Problem Identification and Resolution,” was revised in 09/03 and includes enhanced requirements PI&R reviews conducted by the resident inspectors, biennial reviews of longstanding issues, and biennial reviews of licenexperience issues. The effectiveness of the changes to IP 71152 addressing the DBLLTF recommendations was discussed during a problem resolution focus group meeting held on March 11, 2005. The consensus of the group members was that the changes haunintended consequences, have reinforced expectations that inspectors have a questioning attitude, and provide a methissues that might be indicative of a more significant problem. In addition, the regional inspection procedure leads, in conprogram office, have highlighted and communicated semiannual trend reviews that have been successful at identifying ntrends. In some cases, these negative trends may not have been documented if the inspection guidance had not been cbeen some feedback from inspectors requesting additional guidance on how to conduct the semiannual trend reviews. Tguidance in this area was deliberately kept non-prescriptive to afford inspectors ample opportunities to follow up on issuewell elsewhere in the inspection program. Overall, the changes were effectively implemented and addressed the recommwill continue to be evaluated on an ongoing basis as part of the annual ROP assessment process.

3.3.3(2) Perform a sample review of the plant assessments

conducted under the interim PPR [Plant PerformanceReview] assessment process (1998-2000) todetermine whether there are plant safety issues thathave not been adequately assessed.

Low Insp Complete Not Re

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

3.3.4(6) Provide ROP refresher training to managers and staff

members.

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

34

STATUS: Based on the Davis Besse LLTF Report, ROP Refresher Training was provided at each of the Regional InspeMeetings in 05/04. The topic of the ROP Refresher Training session was an individual’s role in developing and maintainattitude. The slide presentation can be found at ADAMS (ML041320101). The IMC1245, “Qualification Program For the Office of Nuclear Reactor Regulation Programs” (ML04180012), was revisrequirement for annual ROP Refresher Training. IMC 1245 requires that topics for ROP refresher training will be soliciteRegional Inspector Counterpart Meetings. The IMC 1245 Management Steering Group will select the topic(s), determine training, and determine the timing of the training. The NRR Inspection Program Branch will be responsible for ensuring tdeveloped and implemented during the fall of each year.This action was effectively implemented in 2004. The Inspection Program Branch provided the initial ROP refresher trairegional inspector counterpart meetings. The training focused on maintaining a questioning attitude. In the long term, IMto include a requirement for annual ROP refresher training.The IMC 1245 Management Steering Group and IMC 1245 Working Group annually review the effectiveness of inspectofeedback forms submitted, results of the inspector oral boards, and regional experience. Improvements and revisions arimplemented as appropriate. In addition, the Regions discuss current ROP issues during inspector counterpart meetings discussing value-added findings. Further, the IMC 1245 Management Steering Group, comprised of Regional Division/DDirectors, discusses potential ROP refresher training topics and chooses the topic to be discussed during formal training. In summary, the training associated with this recommendation was effectively implemented and will be continually reviewinspector training program reviews and regional management attention.

3.3.5(2) Reinforce IMC 0102 expectations regarding regional

manager visits to reactor sites.

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

35

STATUS: During the July 2003 Regional Division Director Counterpart Meeting, the Inspection Program Branch reinforcexpectations for site visits. During a general discussion of reactor oversight process topics, a hand out was distributed wvisit responsibilities for the senior resident and resident inspectors, each line manager, Division of Reactor Project (DRPOperator Licensing manager, the DRP Division Director or Deputy, and the Regional Administrator or Deputy Regional Avisit responsibilities were discussed and are outlined in detail in IMC 0102,”Oversight and Objectivity of Inspectors and E

Facilities,”This action was effectively implemented in 2003. The training was provided during the August 2003 regional Division Di

meeting and focused on the requirements of IMC 0102. In addition, as part of regional efforts to improve consistency anadded inspection activities, IMC 0102 is being revised to improve the expectations and requirements for regional managsite visits. In summary, the training associated with this recommendation was effectively implemented and will be continof the inspector training program reviews and regional management attention.

3.3.5(3) Establish measurements for resident inspector

staffing, including the establishment of programexpectations to satisfy minimum staffing levels. 

Low Insp Complete Not Re

STATUS: A “Site Staffing” metric (ML032410588) was developed in 12/03, with regional input, to monitor gaps in permasenior resident inspector staffing at reactor sites. This metric was pilot tested in calendar year 2004, adjustments have bthe results of the pilot, and a revised metric was issued to the regions in 12/04. A criterion of maintaining at least 90% shas been established for this metric. In addition, any single site that falls below 90% will be specifically evaluate

Reactor Oversight Process self-assessment process. This new metric will be used as an input to the annual Process self-assessment process. Since the effectiveness review for this change will be an ongoing assess

as the metric is used as an input to the process, no additional effectiveness review is required.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

36

3.3.7(5) Fully implement Office Letter 900, “Managing

Commitments Made by Licensees to the NRC,” orrevise the guidance if it is determined that the audit oflicensee’s programs is not required. Further, determine whether the periodic report oncommitment changes submitted by licensees to theNRC should continue to be submitted and reviewed.

Low Insp Complete 05/

Com
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiv

Rev

37

STATUS: Office Letter 900 was revised and incorporated into NRR Office Instruction LIC-105, “Managing Commitments the NRC,” which was issued on 05/27/03. LIC-105 requires periodic audits (every 3 years) by the DLPM Project Manageof two major parts. The first is a verification of the licensee’s implementation of NRC commitments by reviewing a sampLIC-105 provides criteria for selection of the sample. The second is a verification of the licensee’s program for managincommitments. Program controls will be verified to be consistent with industry guidelines in Nuclear Energy Institute docuwhich has been found by the NRC (SECY-00-045, dated 2/22/00) to provide acceptable guidance for managing regulatoNEI 99-04 also directs licensees to submit periodic reports of changes to commitments. This part of the audit will be don

samples of changes to commitments. It also includes a sample to confirm that the licensee’s program ensures commitmfollowing initial implementation. The results of the audit will be documented in a report from the PM.

In the discussion of the basis for this recommendation, the LLTF also noted that the DLPM handbook did not reference thdiscuss requirements for periodic audits of licensees’ commitment management programs. The DLPM Handbook has besections on “Site Visits” and “Commitment Management Program” reinforce the requirement for the periodic audits by PMto LIC-105.The intent of the LLTF recommendation has been met by the issuance of the guidance documents in 2004. An effectivfound that, consistent with the guidance and management expectations, one-third of the reviews were completed during PMs suggested that having the resident inspectors perform the audits as part of 10 CFR 50.59 reviews would retain the bimprove efficiency, and reduce travel costs. Most PMs were in agreement that the audit documentation requirements shThese items will be considered and the staff will determine whether changes to the audit procedures are needed when auperformed at all sites. In the course of the audits, PMs generally gained confidence that the licensees’ commitment management programs are Some items identified for future consideration include : (1) Some licensee do not have a dedicated system to track reguand, instead, rely on several plant tracking subsystems to manage regulatory commitments, which results in the licensee comprehensive listing and current status of all regulatory commitments, (2) Enforcement of commitments can be difficucan be eliminated in a 50.59 review, (3) Licensees typically do not formally identify regulatory commitments in submittaThe commitments to evaluate the efficiency of the audit process and the need for procedure changes have been entered corrective action program and will be tracked through that process.
38

Category: Barrier Integrity 

LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

3.1.5(1) Determine whether PWR plants should install on-line

enhanced leakage detection systems on critical plantcomponents, which would be capable of detectingleakage rates of significantly less than 1 gpm.

High BI 03/05

Complete

05/06

Not requi

STATUS: This recommendation focuses on determining if improvements can be made in leakage detection requirementhis, a comprehensive review and evaluation of plant experiences and current leakage detection systems was performesimilar study that was performed by Argonne National Laboratory (ANL) in the late 1980's. There are three main tasks aeffort. The first task is an assessment of the leakage associated with the degradation of various reactor coolant pressure components. The second task is a review of leakage operating experience by developing a database of leakage events. evaluation of the capabilities of various leakage detection systems. ANL submitted a draft report in 05/04. The RES and 

this draft report and provided comments to ANL. The final report was published as NUREG/CR-6861 in12/04. A working group consisting of members of the NRR and RES staff was formed to address this recommendation. In evaluating the need for additional requirements pertaining to leakage detection, the staff considered past operating exreactor coolant system integrity and the performance deficiencies that led to the degradation that occurred at Davis-Besstechniques that could improve localized leak detection and on-line monitoring and several areas of possible improvemendetection requirements that could provide increased confidence that plants are not operated at power with reactor coolanleakage. However, implementing these increased capabilities would most likely result in a very modest reduction in loss

frequencies. As a result, the staff concluded that the associated risk reduction that may be realized would not justify the the installation and maintenance of such equipment (i.e., the cost-benefit criteria associated with implementation of the b[10 CFR 50.109] could not be satisfied). Issuance of the working group report completed the recommendation and, since was proposed, an effectiveness review is not required. 
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

39

3.2.1(1) Improve the requirements pertaining to RCS

unidentified leakage and RCPB leakage to ensurethat they are sufficient to: (1) provide the ability todiscriminate between RCS unidentified leakage andRCPB leakage; and (2) provide reasonableassurance that plants are not operated at power withRCPB leakage.

High BI TBD

Complete

TBD

Not requi

STATUS: This item was implemented in conjunction with LLTF 3.1.5(1) above. In evaluating the need for additional requirements pertaining to leakage detection, the staff considered past operating exreactor coolant system integrity and the performance deficiencies that led to the degradation that occurred at Davis-Besstechniques that could improve localized leak detection and on-line monitoring and several areas of possible improvemendetection requirements that could provide increased confidence that plants are not operated at power with reactor coolanleakage. However, implementing these increased capabilities would most likely result in a very modest reduction in loss

frequencies. As a result, the staff concluded that the associated risk reduction that may be realized would not justify the the installation and maintenance of such equipment (i.e., the cost-benefit criteria associated with implementation of the [10 CFR 50.109] could not be satisfied). Since no changes were recommended, an effectiveness review is not required. 

3.2.1(2) Develop inspection guidance pertaining to RCS

unidentified leakage that includes action levels totrigger increasing levels of NRC interaction withlicensees in order to assess licensee actions inresponse to increasing levels of unidentified RCSleakage. The action level criteria should identifyadverse trends in RCS unidentified leakage thatcould indicate RCPB degradation.

High BI Complete 05/06 
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

40

STATUS: IMC 2515, Appendix D, “Plant Status,” was revised in 05/04 to require inspectors to trend leak rates and monileakage for adverse trends, and, if any are noted, to inform licensee management and regional management. The guidainspectors to review licensee procedures and action plans to identify source(s) of RCS unidentified leakages when RCS suspected and to review licensee procedures for action steps, as unidentified leakage approaches licensee administrativspecifications allowed values. IMC 2515, Appendix D, was revised again in 01/05 to provide guidance and techniques necessary for assessing potentiaaction levels in response to increasing levels of RCS unidentified leakage. The effectiveness review was deferred to properiod of time to use the new guidance. 

3.2.1(3) Inspect plant alarm response procedure requirements

for leakage monitoring systems to assess whetherthey provide adequate guidance for the identificationof RCPB leakage.

High BI Complete 05/05

Comple

STATUS: To address this recommendation, inspection guidance has been revised to verify that licensees have programplace to (1) monitor plant-specific instrumentation that could indicate potential RCS leakage, (2) meet existing requiremedegraded or inoperable leakage detection instruments, (3) use an inventory balance check when there is unidentified leaappropriate corrective action for adverse trends in unidentified leak rates, and (5) pay particular attention to changes in uThe revised procedures include Inspection Manual Chapter 2515 Appendix D (Plant Status Review), Inspection ProceduInspection Procedure 71111.08. These revisions were issued in 05/04 and inspections have commenced. The assessment of the adequacy of licensee procedure requirements was completed as part of the annual ROP self asThe staff’s review of inspection results and feedback from each Region regarding the implementation of these changes ilicensees’ alarm response procedures and operating procedures provide adequate guidance for the identification and correactor coolant system boundary leakage. No implementation issues or findings were identified in this area. IPs 71111.2IMC 2515 will continue to be evaluated on an ongoing basis as part of the annual ROP assessment process and as part o

feedback process in accordance with IMC 0801.
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

41

3.3.3(3) Continue ongoing efforts to review and improve the

usefulness of the barrier integrity PIs [PerformanceIndicators]. These review efforts should evaluate thefeasibility of establishing a PI which tracks thenumber, duration, and rate of primary system leaksthat have been identified but not corrected.

High BI 05/05

Complete

05/06

Not Requ
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

42

STATUS: The review and improvement of PIs is on ongoing process, which is performed by a working group that includrepresentatives. The PI program is a voluntary program for the industry in that there are no regulatory requirements assprogram. Changes to the program generally require consensus between the NRC staff and industry. The first part of LLTby the continuation of this ongoing process.  The second part of the recommendation requires a feasibility evaluation of establishing an additional PI for tracking num

of primary system leaks. The existing Reactor Coolant System (RCS) Leakage PI already monitors identified leakage athe plant technical specifications limit. The intent of the PI is to call attention to those plants that have identified primary not corrected them in a timely manner. Only five plants have crossed the green-white threshold (greater than 50 percenyears. The industry and NRC staff established a subgroup composed of NRC staff and industry representatives to assess the fePI to track the number, duration, and rate of primary system leaks that have been identified but not corrected. The group not feasible at present due, in part, to the difficulty licensees have in determining small leak rates accurately, and, in parreporting, which makes it difficult for the staff to determine the number of leaks, the rate, and the duration. However, the follow progress in leak detection capability and industry efforts in this area.As part of the continuing effort to improve usefulness of the barrier integrity PIs and the Reactor Oversight Process, the group agreed to have the subgroup explore possible improvements to the RCS leakage PI. The subgroup has met on a and is currently interacting with the Westinghouse Owners Group to understand the efforts being undertaken by that grouIn summary, the staff has assessed the feasibility of establishing the PI which tracks the number, duration, and rate of prthat have been identified but not corrected and has determined that it is not feasible at this time. As part of the ongoing Reactor Oversight Process and PI Program, the staff is working with its external stakeholders and has established a NRC subgroup to explore and possibly improve the RCS Leakage PI. Since this is a continuing process and no specific changis no need for an effectiveness review. 

3.3.4(9) Review PWR plant technical specifications to identify

plants that have non-standard RCPB leakagerequirements.Pursue changes to those technical specifications tomake them consistent among all plants.

High BI Complete Not Requ
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

43

STATUS: Plants with nonstandard RCPB technical specifications (TSs) were identified in a 07/03 study (ML031980277)that only one plant did not have TSs for RCPB leakage. Subsequently, this plant submitted a technical specification chabring it into alignment with the standard TSs. This change was approved on 5/7/04. Now all PWR TSs have RCPB leakwith standard TSs. The requirements for shutdown, if leakage exists, are not identical, but all plants require appropriate cplace the plant in cold shutdown within the time frame of the standard TSs.

3.3.7(3) Evaluate the adequacy of analysis methods involving

the assessment of risk associated with passivecomponent degradation, including the integration ofthe results of such analyses into the regulatorydecision-making process.

Medium BI 05/05

Complete

05/06

09/06
LLTF

No. LLTF Recommendation Priority Category 

Target

Date

Effectiven

Review 

44

STATUS: A working group consisting of members of the NRR and RES staff addressed this recommendation. In general, the WG found that the methods used to assess risk are adequate; however, in most cases there is insufficienmethods to produce robust results. Also, an understanding of the results of any risk assessment, as well as its limitations paramount for responsible risk-informed regulatory decisionmaking. The WG report, dated March 31, 2005, found that thassessment models alone are usually inadequate to provide strong support for many types of decisions. The portions of predict degradation rates and structural integrity effects, and the limited information about plant-specific conditions often make reliable predictions very far beyond the latest available measurements. However, the WG concluded that decisionof a proper combination of inspection results and predictive modeling can be successfully used to adequately control the The steam generator tube integrity program that has recently been developed in cooperation with industry, is suggested success in other portions of the pressure boundary components that are important to safety.The Division Directors agree that the methods used to assess risk are adequate and data limitations need to be well undeunderstanding of the limitations and uncertainties is necessary to make the appropriate decision. Degradation issues are respect to the need for decision makers to carefully consider the degree of uncertainty of and the level of confidence in tinformation and analytical results. But, it is more difficult than usual to do so for degradation issues, because of the greapredictive models in place of empirical reliability data. Based on the WG findings, the evaluation recommended by DBLconsidered complete.The Division Directors generally endorsed the WG recommendations and noted that the implementation of the recommeconsistent with the NRR/DSSA effort to assess the May 2004 GAO report on the Davis-Besse shutdown. NRR and RES strategy to implement the training identified by the WG for incorporating the risk assessment results in regulatory decisiotraining and other items required to implement these recommendations, and the effectiveness review are projected to be September 2006.