IR 05000346/2006007

IR 05000346-06-007; Firstenergy Nuclear Operating Company; 10/30/2006 - 11/17/2006; Davis-Besse Nuclear Power Station; Problem Identification and Resolution

ML063620346
Person / Time
Site:	Davis Besse
Issue date:	12/28/2006
From:	Eric Duncan NRC/RGN-III/DRP/RPB6
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
IR-06-007
Download: ML063620346 (24)

Text

December 28, 2006

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000346/2006007

Dear Mr. Bezilla:

On November 17, 2006, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the inspection findings that were discussed on November 17, 2006, with you and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved a selected examination of procedures and representative records, observation of activities, and interviews with personnel.

On the basis of the samples reviewed, the NRC concluded, overall, that problems entered in the corrective action program were properly identified, evaluated, and corrected. Audits and self-assessments were effective in identifying deficiencies, and recommendations were appropriately captured. The use of operating experience was adequate. The NRC did not identify any weaknesses in the Employee Concerns Program (ECP) that contributed to recent station performance deficiencies or adversely impacted the establishment of a Safety Conscious Work Environment (SCWE).

Based on the results of this inspection, one finding of very low safety significance that involved a violation of NRC requirements was identified. However, because the finding was of very low safety significance and because the issue was entered into your corrective action program, the NRC is treating this violation as a non-cited violation (NCV) in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest the subject or severity of this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Davis-Besse facility.

In accordance with 10 CFR 2.390 of the NRC's "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 NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 6 Division of Reactor Projects Docket No. 50-346 License No. NPF-3 Enclosure:

Inspection Report 05000346/2006007 w/Attachment: Supplemental Information cc w/encl:

The Honorable Dennis Kucinich G. Leidich, President and Chief Nuclear Officer - FENOC J. Hagan, Senior Vice President of Operations and Chief Operating Officer Richard Anderson, Vice President Director, Plant Operations Manager - Site Regulatory Compliance D. Pace, Senior Vice President of of Fleet Engineering J. Rinckel, Vice President, Fleet Oversight D. Jenkins, Attorney, FirstEnergy Manager - Fleet Licensing Ohio State Liaison Officer R. Owen, Administrator, Ohio Department of Health Public Utilities Commission of Ohio President, Lucas County Board of Commissioners President, Ottawa County Board of Commissioners

SUMMARY

OF ISSUES

IR 05000346/2006007; 10/30/2006 - 11/17/2006; Davis-Besse Nuclear Power Station; Problem Identification and Resolution.

The inspection was conducted by the Davis-Besse resident inspector and three region-based inspectors. One Green finding and an associated non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The inspectors concluded that, overall, problems were properly identified, evaluated, and corrected. Generally, licensee personnel properly prioritized and evaluated issues.

However, the inspectors identified numerous examples in which degraded manual declutch operators associated with safety-related motor-operated valves (MOVs) were not identified in the corrective action program for resolution. Root cause evaluations for significant problems were appropriately detailed. Corrective actions to address problems were generally adequate.

Audits and self-assessments were effective in identifying deficiencies and recommendations were appropriately captured. The use of operating experience was adequate. The inspectors did not identify any weaknesses in the Employee Concerns Program (ECP) that contributed to station performance deficiencies or adversely impacted the establishment of a Safety Conscious Work Environment (SCWE).

A.

Inspector-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

C

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when licensee personnel failed to generate condition reports or notifications to identify deficiencies associated with safety-related equipment. In particular, the inspectors identified eight instances between April 2006 and November 2006 in which licensee personnel failed to document degraded declutch operators associated with safety-related MOVs although personnel were aware of the condition. As part of the licensees immediate corrective actions, notifications and/or condition reports were generated to ensure that the identified deficiencies were entered into the corrective action program.

The inspectors determined that the finding was more than minor because the issue was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the issue was of very low safety significance because the finding did not represent an actual loss of a safety function of a system. The cause of the finding was related to the corrective action program aspect of the cross-cutting area of Problem Identification and Resolution because the implementation of the licensees corrective action program did not identify declutch operator degradation completely, accurately, and in a timely manner commensurate with the safety significance of the issue. (Section 4OA2.1.a)

Licensee-Identified Violations

No findings of significance were identified.

REPORT DETAILS

4OA2 Identification and Resolution of Problems

The inspectors conducted a review of the licensees processes for identifying and correcting problems. Although this was a biennial inspection, a Problem Identification and Resolution inspection was conducted in the fall of 2005. Therefore, this inspection reviewed licensee activities associated with the implementation of their corrective action program for a period of about 1 year. The inspectors reviewed selected licensee documents for the period from July 31, 2005, to November 17, 2006, such as NRC inspection report findings, corrective action documentation, Oversight audits, self-assessments, operating experience reports, and trend analyses. The inspectors also conducted plant walkdowns to determine whether equipment problems were identified at an appropriate threshold and were resolved in a timely manner.

.1 Corrective Action Program

a.

Effectiveness of Problem Identification

(1) Inspection Scope The inspectors conducted a review of the licensees processes for identifying and initiating corrective actions for issues. The inspectors reviewed previous NRC inspection report findings and selected corrective action documentation to determine if issues were entered into the licensees corrective action program at an appropriate threshold. In particular, the inspectors reviewed 33 notifications generated from July 31, 2005, to October 15, 2006, that were associated with safety-related equipment.

The inspectors determined if any of the issues identified in these notifications represented a condition adverse to quality (CAQ), which required the generation of a condition report, and if so, whether a condition report was generated. The inspectors also conducted plant walkdowns to determine whether equipment problems were identified at an appropriate threshold and were resolved in a timely manner.

(2) Observations and Findings The inspectors concluded that, in general, issues were entered into the licensees corrective action program at an appropriate threshold. In the fall of 2005, the condition reporting and notification processes were separated. The revised process prescribed that a notification be generated to initiate a work order and track repair, whereas a condition report was to be generated to identify a CAQ. During this inspection, the inspectors identified the following finding of very low safety significance and other minor examples in which licensee personnel failed to initiate condition reports or notifications to identify deficiencies.

Failure to Initiate Condition Reports for Equipment-Related CAQs

Introduction:

A finding of very low safety significance and an associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors when licensee personnel failed to generate condition reports or notifications to identify deficiencies associated with safety-related equipment. In particular, the inspectors identified eight instances between April 2006 and November 2006 in which licensee personnel failed to adequately document degraded declutch operators associated with safety-related motor-operated valves (MOVs), although personnel were aware of the condition.

Description:

The inspectors conducted plant walkdowns to determine whether equipment problems were identified at an appropriate threshold and were resolved in a timely manner. During these walkdowns, the inspectors observed deficiency tags that identified degraded declutch operators associated with high pressure injection system and low pressure injection system safety-related MOVs. However, through followup interviews, the inspectors determined that there were seven additional degraded declutch operators associated with safety-related MOVs in which neither a notification nor a condition report was generated, and one other degraded declutch operator for which a condition report had not been generated although a notification existed.

Specifically, the inspectors identified that during refueling outage 14 (RFO14), which was completed in April 2006, licensee personnel identified eight safety-related MOVs with manual declutch levers that would not remain in the manual operating position, as designed, to operate the valve manually, but required that the declutch lever be held in the manual operation position. As a result, during an event in which these valves could not be operated remotely and licensee personnel were required to operate these valves locally, operators may not recognize the need to hold these declutch levers in the manual position to successfully operate these valves. All of these examples were required by NOP-LP-2001, Corrective Action Program, to have been identified through a notification and a condition report.

Specifically, licensee personnel failed to generate a required condition report for the following notification:

• Notification 600288650; HP-2B Will Not Stay in Manual; dated March 3, 2006.

This notification identified that the manual declutch lever associated with MOV HP-2B, High Pressure Injection Line 2-2 Isolation Valve, would not remain in the manual operating position as designed to operate the valve manually without being held in the declutch position.

The following notifications with associated condition reports were initiated after licensee personnel realized that they had not been initiated as required by NOP-LP-2001 when a degraded declutch operator was originally identified by plant personnel during RFO14:

• Notification 600345105; DH-9B, [Decay Heat Pump 1 Suction from the Emergency Sump] Will Not Stay in Manual; dated November 3, 2006

• Notification 600345027; DH-1A [Decay Heat Pump 2 Discharge to the Reactor Coolant System Isolation Valve] Will Not Stay in Manual; dated November 3, 2006

• Notification 60035616; FW-601 [Main Feed Containment Isolation Valve (Stop Valve) for Steam Generator #1] Will Not Stay in Manual; dated November 6, 2006

• Notification 600346018; HP-2A [High Pressure Injection Line 2-1 Isolation Valve]

Will Not Stay in Manual; dated November 7, 2006

• Notification 600346019; MS-106 [Main Steam Line 1 to Auxiliary Feedwater Pump Turbine Isolation Valve] Will Not Stay in Manual; dated November 7, 2006

• Notification 600347645; MS-603 [Containment Isolation Valve for Blowdown of the #2 Steam Generator] Will Not Stay in Manual; dated November 14, 2006

• Notification 600347670; RC-11 [Block Valve for the Pilot Operated Relief Valve (PORV)] Will Not Stay in Manual; dated November 14, 2006 Licensee personnel subsequently identified one case in which the use of a degraded declutch lever to manually re-position a valve was referenced in an Abnormal Operating Procedure.

As part of the licensees immediate corrective actions, the notifications and/or associated condition reports referenced above were generated to ensure that the identified CAQs were entered into the licensees corrective action program.

Analysis:

The inspectors determined that the failure to generate condition reports and/or notifications to identify degraded declutch operators associated with eight safety-related MOVs was a performance deficiency warranting a significance evaluation.

The inspectors concluded that the finding was greater than minor in accordance with Appendix B, Issue Screening, of IMC 0612, Power Reactor Inspection Reports, because the finding was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences.

The inspectors completed a significance determination of this issue using Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, of IMC 0609, Significance Determination Process (SDP), dated November 22, 2005.

The inspectors determined that this finding: 1) was not a design deficiency or qualification deficiency; 2) did not represent an actual loss of safety function of a system; 3) did not represent an actual loss of safety function of a single train for greater than its technical specification (TS) allowed outage time; 4) did not represent an actual loss of safety function of one or more non-TS trains of equipment designated as risk significant; and 5) did not screen as potentially risk significant due to seismic, flooding, or a severe weather initiating event. Therefore, the finding screened as Green and was considered to be of very low safety significance.

The cause of the finding was related to the corrective action program aspect of the cross-cutting area of Problem Identification and Resolution because the implementation of the licensees corrective action program did not identify issues associated with degraded declutch operators completely, accurately, or in a timely manner commensurate with the safety significance of the issue.

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, required, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions or procedures.

NOP-LP-2001, Corrective Action Program, a quality-related procedure, required that condition reports be generated for conditions adverse to quality and be entered into the corrective action program. Contrary to the above, between April 2006 and November 2006, condition reports were not generated to identify the failure of eight declutch operators associated with safety-related MOVs, that were conditions adverse to quality. However, because the finding was determined to be of very low safety significance and was entered into the licensees corrective action program (Condition Report (CR) 06-10042, CR 06-10081, CR 06-10085, CR 06-10086, CR 06-10087, CR 06-10089, CR 06-10091, CR 06-10092, and CR 06-10093), this violation is being treated as an NCV consistent with Section VI.A of the NRC Enforcement Policy (NCV 05000346/2006007-01).

Other Observations Regarding the Effectiveness of Problem Identification No findings of significance were identified. The inspectors concluded that, in general, issues were entered into the licensees corrective action program at the proper threshold. The inspectors determined that condition reports that were identified to involve CAQs were appropriately characterized and corrective actions were implemented to address these issues were appropriate with the exception of the following issues that were considered minor in nature:

• Notification 600287152; N2 [Nitrogen] Bottle for SW1356 Needs to be Replaced; dated March 12, 2006, identified that during the performance of Work Order 2000120731 to replace a nitrogen bottle, nitrogen system leaks were identified.

The inspectors determined that licensee personnel had not generated a condition report to identify this condition adverse to quality. Licensee personnel subsequently generated CR 06-10011 to enter this issue into the corrective action program.

• The inspectors identified the following examples in which licensee processes and practices for informing the operations staff of equipment deficiencies were not effective or timely:

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As discussed above, the inspectors identified eight instances between April 2006 and November 2006 in which licensee personnel failed to document degraded valve declutch operators. As a result, the operations staff was not informed of the deficiencies.

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As discussed in NRC Inspection Report 05000346/2006003, a finding of very low safety significance was identified when, with the plant shut down for a planned refueling outage, an uncontrolled 10 degree Fahrenheit heatup of the reactor coolant system occurred over a period of about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Licensee personnel had remotely closed a degraded air-operated valve to isolate cooling water flow to the in-service decay heat cooler to control plant heatup. However, because the valve was degraded, it could not be remotely opened to control the heatup. The onshift operating crew was unaware that the valve had been identified as degraded and inoperable by a previous operating crew.

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Licensee personnel were unaware that a valve that was utilized to perform a plant evolution had been previously identified as stroking slowly. This resulted in the unexpected draining of the makeup tank to the borated water storage tank.

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A containment/annulus differential pressure gage that had been identified as inoperable following calibration was not reflected on the main control room annunciator panels although a condition report had been generated and the condition had existed for more than 2 weeks.

• The inspectors identified that licensee personnel, on occasion, generated a single condition report to identify multiple examples of an issue. The inspectors determined that this practice could adversely impact the licensees ability to trend and analyze data since all of the occurrences of a problem in a single condition report may not be recognized.

b.

Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors assessed the prioritization and evaluation of a sample of condition reports in the areas of Operations, Engineering, Maintenance, Radiological Protection, Emergency Preparedness and Security. The inspectors reviewed selected issues identified in previous NRC inspection reports and licensee-identified condition reports which had been identified since August 2005 to verify that the issues were appropriately characterized and prioritized. The inspectors assessed the completeness of root and apparent cause analyses, including the consideration of extent of condition, generic implications, common causes, previous occurrences, and the adequacy of planned corrective actions. Additionally, the inspectors attended several condition report screening meetings during which condition reports were discussed and assigned a significance level.

(2) Observations and Findings No findings of significance were identified. The inspectors determined that licensee personnel properly categorized and evaluated the issues that were reviewed. In general, root cause and apparent cause evaluations were thorough and planned corrective actions to address root and contributing causes were adequate.

However, the inspectors identified that in some cases it was difficult to locate documentation that explained how an issue was resolved. Other cases were identified in which no documentation existed. An inconsistent cross-referencing between condition reports and notifications was a contributing cause.

c.

Effectiveness of Corrective Action

(1) Inspection Scope The inspectors reviewed selected condition reports to determine whether the licensee had implemented appropriate corrective actions in a timely manner to address identified issues. The inspectors also determined whether corrective actions were properly documented, assigned, and tracked to ensure they were implemented. Where possible, the inspectors independently determined whether the corrective actions were properly implemented. The inspectors also determined whether common causes and generic concerns were appropriately addressed. In addition, the inspectors reviewed and evaluated the adequacy of the corrective actions for a sample of findings identified in previous NRC inspection reports.

(2) Observations and Findings No findings of significance were identified. The inspectors determined that corrective actions were appropriately developed and implemented in a timely manner commensurate with the safety significance of the problem.

.2 Operating Experience

a. Inspection Scope

The inspectors evaluated the licensees process for the review and use of operating experience (OE). In particular, the inspectors reviewed the operating experience review procedure, program assessments, and open item backlog. The inspectors also reviewed selected 10 CFR Part 21 reports, NRC Information Notices, and other generic correspondence to determine if the program had adequately assessed issues for applicability at the site. Additionally, the inspectors discussed the implementation of the OE program with the Fleet OE specialist and the Davis-Besse OE Coordinator.

b. Observations and Findings

No findings of significance were identified and the inspectors concluded that the licensee had adequately implemented a program to collect and review operating experience information.

The specific aspects of the OE program discussed below were reviewed:

• The operating experience program as described in NOP-LP-2100, Operating Experience Program, Revision 1, prescribed that licensee personnel screen incoming operating experience and determine if additional analysis was necessary. If the results of the screening identified a potential reportability or operability concern, then NOP-LP-2100 required that the Shift Manager or Shift Engineer be immediately notified and a condition report be generated. The inspectors did not identify any examples in which licensee personnel failed to notify required operations personnel or generate a condition report when required by the OE program.

• NOP-LP-2100 required that a condition report be generated if any OE reviewer identified an adverse condition. The inspectors did not identify any examples in which licensee personnel failed to generate a condition report to identify an adverse condition contained in OE information.

• Of the OE documents reviewed, the inspectors did not identify any that had been classified incorrectly. The inspectors also noted that for the OE screenings classified as not requiring any further action, OE coordinators had the option to provide the OE documents to plant personnel for information only. The distribution included a brief summary of the operating experience as well as a hyperlink to obtain additional information. The distribution also included a reminder that if at any time during the review process, plant personnel identified that additional actions may be necessary, a notification or condition report should be generated.

• NOP-LP-2100 required the initiation of an Evaluation Review Required order for all new Significant Operating Experience Reports (SOERs), Significant Event Reports (SERs), Significant Event Notices (SENs), Operations and Maintenance Reminders (O&MRs), Topical Reports (TRs), NRC Information Notices (INs)addressed to nuclear power reactors or dry fuel storage licensees, and evaluation-required OE Reports. The inspectors did not identify any cases in which orders were not written as required for these operating experience documents.

The inspectors also noted that an October 2006 licensee self-assessment concluded that appropriate discussions of operating experience were included in pre-job briefings.

.3 Self-Assessments and Audits

a. Inspection Scope

During this inspection, the inspectors reviewed selected self-assessments and audits performed by the Oversight group, line organizations, and external sources, to determine whether the licensee had demonstrated the capability to identify performance issues before they resulted in actual events or undesired consequences. The inspectors evaluated management support of the self-assessment and audit process through a review of the staffing of the Oversight organization, management response to self-assessment and audit findings, and the contributions of the Oversight organization to performance improvements. The inspectors reviewed self-assessments and Oversight audits of activities in the areas of Operations, Maintenance, Engineering and Emergency Preparedness.

b. Observations and Findings

No findings of significance were identified. The inspectors determined that self-assessments and audits of the corrective action program had effectively identified areas for improvement. Areas identified as needing attention were entered into the licensees corrective action program and appropriate corrective actions were identified and implemented.

The following issues that were considered minor in nature were identified:

• The overall conclusions discussed in some assessments were more positive than what was suggested by the assessment findings; and

• The number of samples used to assess the performance in an area was sometimes small for the scope of the activity evaluated.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors reviewed the licensees Employee Concerns Program (ECP) to determine whether licensee personnel were willing to raise safety concerns and whether safety significant concerns entered into the ECP received appropriate attention. In particular, the inspectors reviewed documentation and interviewed individuals to determine whether weaknesses, if any, in the ECP had contributed to previously identified performance deficiencies; whether additional safety issues existed that had not been adequately captured in the licensees corrective action program; and whether weaknesses, if any, in the ECP had a negative impact on the sites safety conscious work environment (SCWE). In particular, the inspectors reviewed the results of the most recent Davis-Besse SCWE survey and interviewed licensee employees to independently assess the SCWE at Davis-Besse. The interviews were conducted using the guidance provided in Appendix 1 of NRC Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R [Problem Identification and Resolution] Issues. The inspectors also reviewed licensee procedures and policies associated with the SCWE program, the ECP, and the Differing Professional Opinion Program. Licensee actions to publicize the corrective action and ECP programs were also reviewed.

b. Observations and Findings

No findings of significance were identified. The inspectors did not identify any weaknesses in the ECP that contributed to station performance deficiencies or adversely impacted the establishment of a SCWE. The nuclear safety concerns that had been identified through the ECP were appropriately addressed through the licensees corrective action program.

The inspectors identified that ECP procedures failed to reference 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Facilities, where actions to address CAQs were prescribed. Licensee personnel generated notifications to identify this issue.

4OA6 Exit Meeting Summary

On November 17, 2006, the inspectors presented the inspection results to Mr. M. Bezilla and other members of the licensees staff. The licensee acknowledged the findings presented. The inspectors confirmed that proprietary information was not provided or examined during this inspection.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Bezilla, Site Vice-President

B. Boles, Director, Site Maintenance

K. Byrd, Manager, Design Engineering

J. Grabnar, Director, Station Engineering

L. Harder, Manager, Radiation Protection

R. Hruby, Manager, Nuclear Oversight

V. Kaminskas, Director, Plant Operation

C. Price, Manager, Regulatory Compliance

R. Schrauder, Director, Performance Improvement

M. Trump, Manager, Training

NRC Personnel

E. Duncan, Chief, Branch 6, Division of Reactor Projects, Region III

J. Rutkowski, Senior Resident Inspector, Davis-Besse Site

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000346/2006007-01 NCV Failure to Initiate a Condition Report for Conditions Adverse to Quality

Closed

None.