IR 05000346/2008008
| ML082100508 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/28/2008 |
| From: | Dave Hills NRC/RGN-III/DRS/EB1 |
| To: | Allen B FirstEnergy Nuclear Operating Co |
| References | |
| IR-08-008 | |
| Download: ML082100508 (20) | |
Text
July 28, 2008
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION,
EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000346/2008008(DRS)
Dear Mr. Mr. Allen:
On July 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications at the Davis-Besse Nuclear Power Station. The enclosed report documents the results of the inspection, which were discussed with Mr. Moul and others of your staff at the completion of the inspection on July 11, 2008.
The inspectors 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. Based on the results of the inspection, one NRC identified finding of very low safety significance was identified, which involved a violation of NRC requirements.
However, because this violation was of very low safety significance and because it was entered into your corrective action program, the NRC is treating the issue 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 an NCV, 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 Nuclear Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), 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/
David E. Hills, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 50-346 License Nos. NPF-3 Enclosure:
Inspection Report 05000346/2008008(DRS)
w/Attachment: Supplemental Information cc w/encl:
The Honorable Dennis Kucinich
J. Hagan, President and Chief
Nuclear Officer - FENOC
J. Lash, Senior Vice President of
Operations and Chief Operating Officer - FENOC
Manager - Site Regulatory Compliance - FENOC
D. Pace, Senior Vice President of
Fleet Engineering - FENOC
J. Rinckel, Vice President, Fleet Oversight - FENOC
P. Harden, Vice President, Nuclear Support
D. Jenkins, Attorney, FirstEnergy Corp.
Director, Fleet Regulatory Affairs - FENOC
Manager - Fleet Licensing - FENOC
C. OClaire, State Liaison Officer, Ohio Emergency Management Agency
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 FINDINGS
IR 05000346/2008008(DRS); 06/23/2008 through 07/11/2008; Davis-Besse Nuclear Power
Station; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.
The inspection covered a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by three regional based engineering inspectors. One Severity Level IV Non-Cited Violation (NCV)was identified. The significance of most findings is indicated by their color (Green, White,
Yellow, Red), using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply, may be Green, or may be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Severity Level IV. The inspectors identified a Severity Level IV NCV, having very low safety significance, of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to provide a documented basis for determining that changes to the service water system did not require prior NRC approval. Specifically, the licensee removed flow restricting piping orifices, which created an adverse change to the service water system, because the service water pumps could have insufficient net positive suction head during accident conditions. The licensee revised the service water system operating procedure to ensure that this change did not result in operation of the service water pumps with inadequate net positive suction head and entered this issue into the corrective action program.
Because the issue affected the NRCs ability to perform its regulatory function, this issue was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the change would not have ultimately required NRC prior approval. The finding was determined to be of very low safety significance because the licensee had not aligned the service water system in a configuration that could have damaged the pumps.
(Section 1R17.1.b.1)
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
.1 10 CFR 50.59 Evaluations and Screenings
a. Inspection Scope
From June 23 through July 11, 2008, the inspectors reviewed eight safety evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 23 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;
- the safety issue requiring the change, test or experiment was resolved;
- the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and
- the design and licensing basis documentation was updated to reflect the change.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.
This inspection constitutes eight samples of evaluations and 23 samples of changes as defined in Inspection Procedure 71111.17-05.
b. Findings
b.1 Failure to Perform a 10 CFR 50.59 Evaluation for Service Water System Modification
Introduction:
The inspectors identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments associated with a failure to document the basis for determining that changes to the service water (SW) system did not require prior NRC approval. Specifically, the licensee removed flow restricting piping orifices, which created an adverse change to the SW system in that, the SW pumps could have insufficient net positive suction head during accident conditions.
Description:
In August of 2005, the licensee performed a Regulatory Applicability Determination (RAD) No.05-03914 and concluded that 10 CFR 50.59 requirements did not apply to proposed changes in the SW system implemented by ECR 04-0216-01 Service Water 18-HBC-42 Return Header from CCW [Component Cooling Water]
Heat Exchanger Annubar Flowmeters. In ECR 04-216-01, the licensee proposed removing flowmeters and associated flow restricting orifices (FE 11210 and FE 11211)on the SW return header downstream of the CCW heat exchangers. In Revision 0 of RAD 05-03914, the licensee failed to recognize and evaluate the removal of the flow restricting orifice as a change to the plant as shown on the Updated Final Safety Analysis Report (UFSAR) figure 9.2-1. On April 15, 2006, the SW headers were returned to service with these orifices removed. On May 12, 2006, the licensee identified the error in RAD 05-03914, completed a 10 CFR 50.59 Screen No. 05-03914 and initiated a UFSAR revision to reflect this change to the plant as described in the UFSAR.
On June 9, 2006, as documented in condition report (CR) 06-02521, the licensee identified that removal of these flow orifices created a condition where the SW pumps would be in pump run out with insufficient net positive suction head during accident conditions with the additional SW system flow diverted to the spare CCW heat exchanger. Specifically, for cold weather operations with fore bay water temperature below 50 degrees Fahrenheit, the licensee would divert SW system flow through the spare CCW heat exchanger. The licensee performed a calculation to demonstrate that SW pumps would still have sufficient net positive suction head if flow diversion to the spare CCW heat exchanger was limited to 20 psig below the maximum allowable SW header pressure (115 psig). On June 9, 2006, the licensee implemented a standing order 06-006 to limit SW header flow diversion until Revision 28 to procedure DB-OP-06261 Service Water System Operating Procedure was issued to incorporate this new restriction. The licensee confirmed that the fore bay temperatures had remained above 50 degrees Fahrenheit during the period of time the condition existed without operating procedure changes, so this issue did not impact past plant operability. However, the licensee failed to recognize that this change as implemented between April 15, 2006, and June 9, 2006, had adversely affected the function of the SW system for cold weather system alignments, and as such required a written safety evaluation in accordance with 10 CFR 50.59. Further, the inspectors determined that the change as implemented (e.g., without operator actions to limit SW flow diversion for cold weather conditions), would have required NRC prior approval (e.g., a license amendment).
Although the licensee staff had recognized and taken corrective measure for the errors associated with the original SW modification, they had failed to recognize that these errors resulted in the plant operating in a condition which required NRC prior approval.
Analysis:
The inspectors determined that this issue was a performance deficiency warranting a significance evaluation, because the licensee failed to recognize that the changes to the plant SW system to remove the flow orifices had placed the plant in a condition which required prior NRC approval (e.g., license amendment). The finding was determined to be more than minor because the inspectors could not reasonably determine that the change made would not have ultimately required NRC prior approval.
Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the significance determination process (SDP).
However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. The inspectors completed a significance determination of the underlying technical issue using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings. Under the Mitigating Systems Cornerstone Column of Table 4a, the inspectors answered Yes, that this was a design or qualification deficiency, confirmed not to result in loss of operability or functionality, because the licensee had not aligned the SW system in a configuration that could have damaged the pumps. Therefore, the finding screened as having very low safety significance, and in accordance with the Enforcement Policy, the violation was classified as a Severity Level IV violation. Because the performance errors, which led to this finding occurred during the approval of the SW system modification in 2005, this issue did not reflect current plant performance and therefore, no cross-cutting aspect was identified.
Enforcement:
During an NRC inspection conducted between June 23, 2008, and July 11, 2008, a violation of 10 CFR 50.59 Changes, Tests, and Experiments, was identified.
Title 10 CFR 50.59(d)(1) states, in part, that the licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments as described in the UFSAR. These records must include a written evaluation which provides a basis for the determination that the change, tests, or experiments does not require a license amendment.
Contrary to the above, from April 15, 2006 thru June 9, 2006, the licensee made changes pursuant to 10 CFR 50.59(c) to the plant as described in the UFSAR and had not performed a written evaluation which provided the bases for determining that the changes did not require a license amendment. Specifically, in accordance with ECR 04-216-01, the licensee removed annubar flowmeters and associated flow orifices in the SW system as identified on figure 9.2-1 of the UFSAR, which created an adverse change to the SW system function. Because this violation was of very low safety significance and it was entered into the licensees corrective action program (CR 08-43023), this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000346/2008008-01(DRS))
.2 Review of Permanent Plant Modifications
a. Inspection Scope
From June 23 through July 11, 2008, the inspectors reviewed 14 permanent plant modifications that had been installed in the plant during the last three years. The modifications were chosen based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
- the supporting design and licensing basis documentation was updated;
- the changes were in accordance with the specified design requirements;
- the procedures and training affected by the modification have been updated;
- the test documentation as required by applicable test programs has been updated; and
- post-modification testing specified was sufficient to ensure functionality of the component modified, its associated system, and any support systems.
This inspection constitutes 14 samples as defined in Inspection Procedure 71111.17-05.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Routine Review of Condition Reports
a. Inspection Scope
From June 23 through July 11, 2008, the inspectors reviewed Corrective Action Process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meeting(s)
.1 Interim Exit Meeting
The inspectors presented the inspection results to Mr. D. Moul and others of the licensees staff, on July 11, 2008. Licensee personnel acknowledged the inspection results presented. Licensee personnel were asked to identify any documents, materials, or information provided during the inspection that were considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Moul, Director Site Engineering
- K. Byrd, Manager Design Engineering
- D. Wuokko, Acting Manager, Regulatory Affairs
- K. Zellers, Supervisor, Analysis Group and Design
- J. Hook, Design Engineering Supervisor
- D. Duquette, Senior Nuclear Engineer
- S. Osting, Nuclear Engineer
- T. Chowdhary, Compliance
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000346/2008008-
01(DRS)
NCV Failure to Perform a 10 CFR 50.59 Evaluation for Service Water System Modification
Closed
- 05000346/2008008-
01(DRS)
NCV Failure to Perform a 10 CFR 50.59 Evaluation for Service Water System Modification