IR 05000346/2003024

IR 05000346-03-024(DRS); on 11/17/2003 - 11/21/2003, for Firstenergy Nuclear Operating Company; Davis-Besse Station. Engineering and Maintenance Backlog Inspection

ML040060504
Person / Time
Site:	Davis Besse
Issue date:	01/05/2004
From:	Grobe J NRC/RGN-III
To:	Myers L FirstEnergy Nuclear Operating Co
References
IR-03-024
Download: ML040060504 (17)

Text

ary 5, 2004

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION SPECIAL INSPECTION REPORT NO. 05-346/03-24

Dear Mr. Myers:

On November 21, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a special inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report documents the inspection findings which were discussed with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on the backlog of engineering and maintenance work that would not be performed until after restart of the plant. The inspection was an integral portion of the panels review for Restart Checklist Item 5.b., Systems Readiness for Restart.

The checklist item remains open until further review during subsequent inspections. The inspection focused on a review of the licensees process for tracking open backlog items, a review of the effectiveness of the process in justifying deferral of activities, an evaluation of the licensees use of probabilistic risk assessment insights in deferring items to a post-restart status, and an evaluation of the potential risk implications of deferred items. The inspectors concluded that the restart scoping process was satisfactory and that the deferred actions did not individually or collectively have a risk significant impact on plant restart. However, continued management attention is needed to assure resources are committed to the post-restart backlog.

On the basis of the results of this inspection, no findings of significance were identified. In accordance with 10 CFR Part 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by John A. Grobe Acting for/

John A. Grobe, Chairman Davis-Besse Oversight Panel Docket No. 50-346 License No. NPF-3

Enclosure:

Inspection Report No. 05-346/03-24

REGION III==

Docket No: 50-346 License No: NPF-3 Report No: 05-346/03-24 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: 5501 North State Route 2 Oak Harbor, OH 43449-9760 Dates: November 17 - 21, 2003 Inspectors: M. Parker, Senior Reactor Analyst, RIII S. Burgess, Senior Reactor Analyst, RIII W. Schmidt, Senior Reactor Analyst, RI J. Rutkowski, Resident Inspector Approved by: Christine A. Lipa, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05-346/03-24(DRS); FirstEnergy Nuclear Operating Company; on 11/17-21/2003;

Davis-Besse Station. Engineering and Maintenance Backlog inspection.

The report covers a one-week special inspection by three regional Senior Reactor Analysts and a resident inspector. The inspection assessed the potential risk impact of Davis-Besses deferred/post-restart items prior to startup. The inspection focused on a review of the licensees program/process for tracking backlogged open items, a review of the effectiveness of the program/process in justifying deferral of activities, an evaluation of the licensees use of PRA insights in deferring items to post-restart status, and an evaluation of the potential risk implications of deferred items. No findings of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

4OA5 Other Activities

.1 Review of Licensees Program/Process for tracking backlogged open items

a. Inspection Scope

The inspectors examined backlogged items that were not scheduled to be completed prior to the expected plant restart for the following programs: Work Orders, Engineering Change Requests, Engineering Work Requests, Design Changes, Temporary Modifications, Operator Workarounds, Procedure Change Requests, Vendor actions, Request for Assistance, Updated Final Safety Analysis Report (UFSAR) changes, Preventative Maintenance, Condition Reports, and Corrective Actions. In addition to evaluating the impact of the maintenance and engineering backlog on individual systems, the inspectors screened backlog items for potential impact on initiating events and containment performance.

b. Observations The inspectors noted that based on the licensees Probabilistic Safety Assessment (PSA), the most likely core damage scenarios by initiating event type were associated with component cooling water malfunctions, loss of DC power, service water malfunctions, loss of offsite power, and loss of coolant accidents. Using these accident scenarios captured sequences that accounted for over 79% of the core damage frequency (CDF). In addition, the inspectors examined overall system contribution to CDF. The risk importance of many of the more highly ranked systems on the inspectors final list was influenced by their potential failure to mitigate these scenarios and their overall contribution to CDF. As a result, the inspectors selected backlog items related to 12 systems and the loss Component Cooling Water and Service Water initiating events for further review of their potential collective risk significance. These mitigating systems represented over 95% of the overall CDF contribution to the plant.

These systems were: component cooling water, auxiliary feedwater, DC power, motor driven feedwater pump, service water, emergency diesel generator, station blackout emergency diesel generator, low pressure injection, 480 Volt alternating current, instrument air, service air, and high pressure injection.

Risk-Significance of Post-Restart Backlog The post-restart backlog represented approximately 17,000 items tracked by the licensee. The inspectors noted that the maintenance backlog represented approximately 20% of the total backlog. However, the majority of the maintenance backlog consisted of elective maintenance activities. In reviewing the maintenance backlog for the selected risk significant systems, the inspectors determined that the deferred backlog did not have a high risk significance. A large portion of the items represented duplication or redundant activities that had not been administratively closed out. Another large portion represented valve packing leaks identified from previous comprehensive system and containment walkdowns. Work orders were generated to address these issues where only minor cleaning resolved the issue. The majority of the remaining non-maintenance backlog consisted of engineering issues related to resolving condition reports and corrective actions.

The inspectors discussed backlogged items with system engineers to understand the details of the issues that were designated as post-restart. System engineers were knowledgeable of system design and outstanding deferred items since each system engineer was responsible for defending system restart readiness in the System Health Report and during System Health Report for Restart Expectations meetings. The inspectors attended a system health report meeting for the Auxiliary Feedwater, Service Water, Instrument Air, Low Pressure Injection, and High Pressure Injection.

The inspectors also discussed backlogged items with plant management; specifically, with design engineering, plant engineering, work planning, and operations to understand their perspective and understanding of the overall impact of the post-restart backlog.

The managers were knowledgeable of outstanding deferred items and their overall cumulative impact.

Discussions with system engineers, observation of a system health report meeting, review of Probabilistic Safety Assessment groups Risk Evaluation of Plant Material Condition Backlog report, and a detailed evaluation of the backlogged items assured the inspectors that the restart scoping process was satisfactory and deferred action did not individually or collectively have a risk-significant impact on the unit restart.

Configuration Control The inspectors identified that a large amount of the backlog consisted of drawing changes, calculations, procedure change requests, condition reports, corrective actions, UFSAR, engineering change requests, and work orders. In reviewing the issues individually, the inspectors determined that the licensee appropriately categorized the issues as post-restart; however, a significant amount of the backlog had no target completion date other than a default post-restart date. The inspectors were not able to identify that the licensee had performed any assessment of the integrated impact of the engineering backlog other than to identify the issues as post-restart. The combined integrated effect of the backlog could ultimately have an effect in the licensees ability to appropriately address issues in a timely manner. System engineers, maintenance planners, maintenance workers and operators routinely utilize these documents to conduct activities and would continue to use these documents without the knowledge that the documents may not have been updated. Overall, the large backlog of engineering issues could potentially have an impact on continued operation of the facility. In discussing these issues with the licensee, the licensee indicated to the inspectors that they would be assigning target completion dates for these activities and were in the process of developing a program to reduce the backlog.

c. Conclusions

Detailed review of the backlogged items, review of self assessments, discussions with system engineers, management discussions, and system health meetings concerning the post-restart backlog, assured the inspectors that the restart scoping process was satisfactory and deferred actions did not individually or collectively have a risk-significant impact on plant restart. However, continued management attention was needed to assure resources are committed to addressing the post-restart backlog.

No findings of significance were identified.

.2 Evaluation of the licensees Use of PSA Insights in Deferring Items to Post Re-Start

a. Inspection Scope

The team evaluated the licensees use of PSA insights relating to the backlog of open work requests. Specifically the team reviewed a detailed risk evaluation of plant material condition backlog items in a report dated November 4, 2003, completed by the licensees PSA group. The team also reviewed the tracking of modification activities that would require updating of the PSA to reflect actual plant conditions/operation.

b. Observations The team found that the risk analysis was well prepared and provided a very detailed account of the elective and corrective maintenance backlog on the most risk significant systems. This assessment used overall conservative bounding values with respect to the potential affects of the known equipment backlog deficiencies on both initiating event frequencies and equipment mitigation capabilities. The team found the licensees assessment conservative and represented a very low increase in CDF.

Relative to PSA updating following modification, the team found that the design control process specified the issuance of a condition report if a modification could affect the PSA. The condition reports were then reviewed by the PSA staff to determine the need for a PSA update. In some cases the condition report was issued long before the modification was actually installed and used as a tracking mechanism. The team noted that recent modifications to the high pressure injection system did not require an update to the PSA, because the modifications were restoring the systems to conditions already assumed in the PSA.

a. Conclusions

The licensee had completed a detailed conservative analysis which indicated only a small increase in plant risk considering the backlog of maintenance items at startup.

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. Lew Myers, and other members of licensee management at the conclusion of the inspection on November 21, 2003.

The NRC inspectors asked the licensee whether any materials discussed as potential report material should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Myers, Chief Operating Officer, FENOC

J. Hagan, Senior Vice President, FENOC

M. Bezilla, Site Vice President

B. Boles, Manager, Plant Engineering

K. Byrd, Supervisor, Design Engineering

G. Dunn, Manager, Work Management

J. Grabnar, Manager, Design Engineering

D. Gudger, Supervisor, Regulatory Affairs

R. Hovland, Supervisor, Plant Engineering

S. Loehlein, Manager, Nuclear Quality Assurance

W. Marini, Regulatory Affairs

K. Ostrowski, Manager, Regulatory Affairs

J. Powers, Director, Nuclear Engineering

M. Roder, Manager, Plant Operations

R. Schrauder, Director, Support Services

M. Stevens, Director, Maintenance

C. Gale, EDG System Engineer

D. Duquette, 4160V System Engineer

M. Roelant, 480V System Engineer

C. Henge, CCW System Engineer

Attachment