IR 05000346/2010005

IR 05000346-10-005, 07200014-10-001, on 10/1/10-12/31/10, Davis-Besse Nuclear Power Station, Routine Integrated Inspection Reports

ML110250747
Person / Time
Site:	Davis Besse
Issue date:	01/25/2011
From:	Jamnes Cameron NRC/RGN-III/DRP/B6
To:	Allen B FirstEnergy Nuclear Operating Co
References
IR-10-001, IR-10-005
Download: ML110250747 (51)

Text

January 25, 2011

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION INTEGRATED INSPECTION REPORT 05000346/2010005 AND REPORT 07200014/2010001

Dear Mr. Allen:

On December 31, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on January 18, 2011, with Mr. B. Boles 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. Based on the results of this inspection, no findings of significance were identified.

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 System (PARS)

component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects

Docket No. 50-346 and 72-014 License No. NPF-3

Enclosure:

Inspection Reports 05000346/2010005 and 07200014/2010001 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-346 and 72-014 License No:

NPF-3 Report Nos:

05000346/2010005 and 07200014/2010001 Licensee:

FirstEnergy Nuclear Operating Company (FENOC)

Facility:

Davis-Besse Nuclear Power Station Location:

Oak Harbor, OH Dates:

October 1, 2010, through December 31, 2010 Inspectors:

J. Rutkowski, Senior Resident Inspector

D. Kimble, Senior Resident Inspector

A. Wilson, Resident Inspector

M. Bielby, Senior Operations Engineer

J. Cassidy, Senior Health Physics Inspector

R. Edwards, Reactor Inspector

T. Go, Health Physics Inspector

L. Jones, Reactor Engineer

B. Palagi, Senior Operations Engineer

Approved by:

Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects

Enclosure

Enclosure

SUMMARY OF FINDINGS

IR 05000346/2010005, 07200014/2010001; 10/1/10-12/31/10; Davis-Besse Nuclear Power

Station; Routine Integrated Inspection Reports This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period operating at full power. On November 5, 2010, during a planned maintenance activity to inspect control rod drive (CRD) system fuses associated with its normal rod drive power supply, control rod 3-4 was in the process of being transferred to the CRD systems auxiliary power supply when the control rod unexpectedly ratcheted into the reactor core. The control rod went from its normal position of 100 percent withdrawn to a final position of 72 percent withdrawn. In response to the transient, plant operators rapidly ramped unit power down to approximately 50 percent in accordance with operating procedures.

Following troubleshooting, control rod 3-4 was recovered on November 7, 2010, and a slow power ascension commenced to return the unit to full power operation. Operation at full power was restored on November 11, 2010, and the unit remained operating at or near full power for the remainder of the inspection period.

1R01 Adverse Weather Protection

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of the licensees preparations for winter conditions to verify that the plants design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.

Specific documents reviewed during this inspection are listed in the Attachment. The inspectors reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues:

• service water system; and

• borated water storage tank and associated piping.

The inspectors review constituted one preparation for winter weather readiness inspection sample, as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness for Adverse Weather Condition - Severe Thunderstorm Warning and

Tornado Watch

a. Inspection Scope

With severe thunderstorms, high winds, and tornados forecast in the vicinity of the facility, the inspectors reviewed the licensees overall preparations and response strategy for the anticipated weather conditions. On the morning of October 26, 2010, just before the scheduled arrival of the inclement weather, the inspectors conducted several physical inspections of outdoor plant areas where wind-generated missiles and debris could affect plant equipment or pose a threat to offsite electrical power. In addition, the inspectors walked down the facilitys emergency diesel generators (EDGs)and the station blackout (SBO) diesel generator to verify that these components were lined up properly if needed.

The inspectors evaluated the licensees preparations to verify that they were adequate and in accordance with site procedures, and also reviewed the licensees CAP to ensure that any weather-related issues were appropriately entered into the system and dispositioned at an appropriate threshold. Specific documents reviewed during this inspection are listed in the Attachment.

The inspectors review of this adverse weather condition and the licensees response actions constituted one inspection sample as defined in IP 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• emergency diesel generator 1 during testing of EDG 2 that rendered it inoperable during the period of testing on October 10, 2010;

• auxiliary feedwater (AFW) train 2 during a maintenance outage of AFW train 1 on October 26, 2010;

• high pressure injection (HPI) train 1 during inoperability of HPI train 2 for room cooler preventive maintenance on November 9, 2010; and

• HPI train 2 during inoperability of HPI train 1 for pump, motor, and valve planned preventive maintenance on December 21, 2010.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

During November 2010, the inspectors performed a complete system alignment inspection of the instrument and control air system to verify the functional capability of the system. This system was selected because it was considered important to plant operation and failures in the system could lead to plant transient initiation. The inspectors walked down the system to review mechanical and electrical equipment lineups, electrical power availability, system pressure and temperature indications, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program (CAP) database to ensure that system problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report.

These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• No. 4 mechanical penetration room (room 314, fire area A);

• No. 1 electrical penetration room (room 402, fire area DG); and

• Station blackout diesel generator building (rooms 001 through 004; no designated fire zone).

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events (IPEEE) with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.

These activities constituted three quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On November 10, 2010, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Facility Operating History

Completion of Sections

.2 through.10 below constituted one biennial licensed operator

requalification inspection sample as defined in IP 71111.11B.

a. Inspection Scope

The inspectors reviewed the plants operating history from September 2008 through October 2010, to identify operating experience that was expected to be addressed by the Licensed Operator Requalification Training (LORT) program. The inspector verified that the identified operating experience had been addressed by the facility licensee in accordance with the stations approved Systems Approach to Training (SAT) program to satisfy the requirements of 10 CFR 55.59(c). The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.3 Licensee Requalification Examinations

a. Inspection Scope

The inspectors performed an inspection of the licensees LORT test/examination program for compliance with the stations SAT program which would satisfy the requirements of 10 CFR 55.59(c)(4). The reviewed operating examination material consisted of six operating tests, each containing two or three (as appropriate) dynamic simulator scenarios and six job performance measures (JPMs). The written examinations reviewed consisted of two written examinations which were Part B, Administrative Controls and Procedure Limits. The station does not use Part A, Static Simulator examinations. Each written examination contained 40 questions, 35 of which were open reference, 5 closed reference, and 8 questions selected outside the 2-year sample plan. The inspectors reviewed the annual requalification operating test and biennial written examination material to evaluate general quality, construction, and difficulty level. The inspectors assessed the level of examination material duplication from week-to-week during the current year operating test. The examiners assessed the amount of written examination material duplication from week-to-week for the current written examinations administered in 2010. The inspectors reviewed the methodology for developing the examinations, including the LORT program 2-year sample plan, probabilistic risk assessment insights, previously identified operator performance deficiencies, and plant modifications. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.4 Licensee Administration of Requalification Examinations

a. Inspection Scope

The inspectors observed the administration of a requalification operating test to assess the licensees effectiveness in conducting the test to ensure compliance with 10 CFR 55.59(c)(4). The inspectors evaluated the performance of one shift crew (two simulator crews) in parallel with the facility evaluators during two dynamic simulator scenarios and evaluated various licensed crew members concurrently with facility evaluators during the administration of several JPMs. The inspectors assessed the facility evaluators ability to determine adequate crew and individual performance using objective, measurable standards. The inspectors observed the training staff personnel administer the operating test, including conducting pre-examination briefings, evaluations of operator performance, and individual and crew evaluations upon completion of the operating test. The inspectors evaluated the ability of the simulator to support the examinations. A specific evaluation of simulator performance was conducted and documented in the section below titled, Conformance with Simulator Requirements Specified in 10 CFR 55.46. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.5 Examination Security

a. Inspection Scope

The inspectors observed and reviewed the licensees overall licensed operator requalification examination security program related to examination physical security (e.g., access restrictions and simulator considerations) and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests.

The inspectors also reviewed the facility licensees examination security procedure, any corrective actions related to past or present examination security problems at the facility, and the implementation of security and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the examination process. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.6 Licensee Training Feedback System

a. Inspection Scope

The inspectors assessed the methods and effectiveness of the licensees processes for revising and maintaining its LORT Program up to date, including the use of feedback from plant events and industry experience information. The inspectors reviewed the licensees quality assurance oversight activities, including licensee training department self-assessment reports. The inspectors evaluated the licensees ability to assess the effectiveness of its LORT program and their ability to implement appropriate corrective actions. This evaluation was performed to verify compliance with 10 CFR 55.59(c) and the licensees SAT program. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.7 Licensee Remedial Training Program

a. Inspection Scope

The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous biennial requalification examinations and the training from the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans.

This evaluation was performed in accordance with 10 CFR 55.59(c) and with respect to the licensees SAT program. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

.8 Conformance with Operator License Conditions

a. Inspection Scope

The inspectors reviewed the facility and individual operator licensees' conformance with the requirements of 10 CFR Part 55. The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators and which control room positions were granted watch-standing credit for maintaining active operator licenses.

The inspectors reviewed the facility licensee's LORT program to assess compliance with the requalification program requirements as described by 10 CFR 55.59(c). Additionally, medical records for six licensed operators were reviewed for compliance with 10 CFR 55.53(I). The documents reviewed during this inspection are listed in the

.

b. Findings

No findings were identified.

.9 Conformance with Simulator Requirements Specified in 10 CFR 55.46

a. Inspection Scope

The inspectors assessed the adequacy of the licensees simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements as prescribed in 10 CFR 55.46, Simulation Facilities. The inspectors also reviewed a sample of simulator performance test records (i.e., transient tests, malfunction tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy process to ensure that simulator fidelity was maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. The inspectors conducted interviews with members of the licensees simulator staff about the configuration control process and completed the IP 71111.11, Appendix C, checklist to evaluate whether or not the licensees plant-referenced simulator was operating adequately as required by 10 CFR 55.46(c) and (d). The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.10 Annual Operating Test Results

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the biennial written examination, the individual Job Performance Measure operating tests, and the simulator operating tests (required to be given per 10 CFR 55.59(a)(2)) administered by the licensee from October 11 through December 8, 2010, as part of the licensees operator licensing requalification cycle. These results were compared to the thresholds established in Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP)." The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG 1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated performance issues involving the following risk-significant systems:

• control rod drive system; and

• reactor coolant system.

The inspectors reviewed events such as where equipment maintenance had resulted or could have resulted in valid or invalid plant or equipment transients and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the emergent work activities affecting risk-significant equipment listed below to verify that the appropriate risk assessments were performed for the changed equipment issues and its influence on scheduled activities:

• work activities during the week of October 5 and October 11, 2010, with major emphasis on diagnosing issues with abnormal indications in the control rod drive system that potentially indicated issues with silicon controlled rectifier gating; and

• work activities during the period of November 5 through November 9, 2010, to respond to the unexpected ratcheting of control rod 3-4 from 100 percent withdrawn to approximately 72 percent withdrawn.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements to verify risk analysis assumptions were valid and applicable requirements were met.

These maintenance risk assessments and emergent work control activities constituted two samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR 10-73116, which documented a gas void located in decay heat removal system train 2 discharge piping inside containment;

• CR 10-78496 and CR 10-85289, which documented as-found setpoints being out of tolerance on PDS2685B, main feedwater to steam generator 2 pressure differential switch;

• CR 10-83726, which documented several operability questions relating to repairs and maintenance performed on the number 2 component cooling water heat exchanger to straighten an out-of-round deficiency;

• CR 10-84495, which documented the incorrect disc being found in auxiliary feedwater safety valve AF4979;

• CR 10-84685, which documented an issue with the qualifications for the auxiliary feedwater turbine exhaust structure;

• CR 10-85617, which documented a design basis issue with the pressurizer heater bundle closure;

• CR 10-85696, which documented a performance issue with door 509 for the control room habitability envelope; and

• CR 10-85898, which documented damage to the oil drain sleeve inside emergency diesel generator 1 overspeed trip mechanism housing.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and the UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.

The inspectors reviews of these operability evaluations constituted eight inspection samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• function test and time response test of reactor trip breaker D after replacement of original breaker with a refurbished breaker;

• function test of battery charger 2P after replacement of the units current transformers and walk-in card;

• idle start, overspeed trip test, and 184 day test of EDG 1 after four-year preventive maintenance activities which included relay replacements, overspeed trip adjustment, replacement of air start motor, fuel oil storage tank drain and clean, jacket water heat exchanger internal inspection, and other routine inspections;

• testing of control rod 3-4 to verify phase continuity in preparation for rod recovery from a partially dropped position to the normal full-out position and the subsequent recovery of the rod and verification of its functionality;

• service water pump 3 baseline performance test following motor replacement; and

• loaded run of the SBO diesel generator at the conclusion of scheduled preventive maintenance which included the engines 24-month required preventive maintenance activities, inspection and cleaning of the voltage regulators, replacement of a speed sensing switch, and replacement of numerous relays.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests (PMTs) to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• DB-SP-4159, Auxiliary Feedwater Pump 2 Monthly Test, on October 13, 2010 (routine);

• DB-PF-3023, Service Water Pump 2 Testing, on November 1, 2010 (IST); and

• DB-OP-1101, Containment Entry, on October 10, 2010 (routine).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted two routine surveillance testing samples, and one inservice testing sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on October 14, 2010, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program.

As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

The inspection activities supplement those documented in Inspection Report 05000346/2010002, and constitute one complete sample as defined in IP 71124.01-05.

.1 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors reviewed the licensees procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors assessed whether or not the licensee has established a de facto release limit by altering the instruments typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high-radiation background area.

The inspectors selected several sealed sources from the licensees inventory records and assessed whether the sources were accounted for and verified to be intact.

The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

b. Findings

No findings were identified.

.2 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors examined the licensees physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool.

b. Findings

No findings were identified.

2RS2 Occupational As-Low-As-Is-Reasonably-Achievable Planning and Controls

The inspection activities supplement those documented in Inspection Report 05000346/2010002, and constitute one complete sample as defined in IP 71124.02-05.

.3 Radiological Work Planning (02.02)

a. Inspection Scope

The inspectors selected the following work activities of the highest exposure significance.

• Reactor Head Repair Work;

• Alloy-600 Nozzle Overlay;

• Refueling Activities;

• Once-Through Steam Generator (OTSG) Work:

• Mobilizing and De-mobilizing of Scaffolds in Containment; and

• Let-down Cooler Replacement Work.

The inspectors compared the results achieved (dose rate reductions, person-rem used)with the intended dose established in the licensees As-Low-As-Is-Reasonably-Achievable (ALARA) planning for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the actual work activity time requirements, and evaluated the accuracy of these time estimates. The inspectors assessed the reasons (e.g., failure to adequately plan the activity, failure to provide sufficient work controls) for any inconsistencies between intended and actual work activity doses.

The inspectors determined whether post-job reviews were conducted and if identified problems were entered into the licensees corrective action program.

b. Findings

No findings were identified.

.4 Source Term Reduction and Control (02.04)

a. Inspection Scope

The inspectors used licensee records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors assessed whether the licensee had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

b. Findings

No findings were identified.

Cornerstones: Public Radiation Safety

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

This inspection constituted one complete sample as defined in IP 71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

The inspectors reviewed the radiological effluent release reports issued since the last inspection to determine if the reports were submitted as required by the Offsite Dose Calculation Manual (ODCM)/TS). The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the corrective action program, and were adequately resolved.

The inspectors identified radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, to review these issues during the onsite inspection, as warranted, given their relative significance and determine if the issues were entered into the corrective action program and adequately resolved.

b. Findings

No findings were identified.

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

a. Inspection Scope

The inspectors reviewed Final Safety Analysis Report descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they can be evaluated during inspection walkdowns.

The inspectors reviewed changes to the ODCM made by the licensee since the last inspection against the guidance in NUREG-1301, 1302, and 0133, and Regulatory Guides 1.109, 1.21 and 4.1. When differences were identified, the inspectors reviewed the technical basis or evaluations of the change during the onsite inspection, to determine whether they were technically justified and maintain effluent releases ALARA.

The inspectors reviewed licensee documentation to determine if the licensee has identified any non-radioactive systems that have become contaminated as disclosed either through an event report or the ODCM since the last inspection. This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations and allowed a determination if any newly contaminated systems have an unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways and whether the associated effluents were reported in accordance with Regulatory Guide 1.21.

b. Findings

No findings were identified.

Groundwater Protection Initiative Program

a. Inspection Scope

The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

b. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

a. Inspection Scope

The inspectors reviewed Licensee Event Reports, event reports, and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations.

The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensees program and aid in selecting areas for inspection review (smart sampling).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge systems to verify that equipment configuration and flow paths align with the documents reviewed in Section 02.01 above and to assess equipment material condition. Special attention was made to identify potential unmonitored release points (such as open roof vents in boiling water reactor turbine decks, temporary structures butted against turbine, auxiliary or containment buildings), building alterations, which could impact airborne, or liquid, effluent controls, and ventilation system leakage that communicates directly with the environment.

For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable.

The inspectors walked down filtered ventilation systems to verify there are no conditions, such as degraded high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance, or the effluent monitoring capability, of the effluent system.

As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent (including sample collection and analysis) to verify that appropriate treatment equipment was used and the processing activities align with discharge permits.

The inspectors determined if the licensee has made significant changes to their effluent release points, e.g., changes subject to a 10 CFR 50.59 review or require NRC approval of alternate discharge points.

As available, the inspectors observed selected portions of the routine processing and discharge liquid waste (including sample collection and analysis) to verify that appropriate effluent treatment equipment is being used and that radioactive liquid waste is being processed and discharged in accordance with procedure requirements and aligns with discharge permits.

b. Findings

No findings were identified.

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and assess whether adequate controls have been implemented to ensure representative samples were obtained (e.g., provisions for sample line flushing, vessel recirculation, composite samplers, etc.).

The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to verify that controls are in place to ensure compensatory sampling is performed consistent with the radiological effluent TS/ODCM and that those controls are adequate to prevent the release of unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility is routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory comparison program to verify the quality of the radioactive effluent sample analyses and assessed whether the inter-laboratory comparison program includes had-to-detect isotopes as appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

The inspectors reviewed the methodology the licensee uses to determine the effluent stack and vent flow rates to verify that the flow rates are consistent with radiological effluent TS/ODCM or Final Safety Analysis Report values, and that the differences between assumed and actual stack and vent flow rates do not affect the results of the projected public doses.

b. Findings

No findings were identified.

Air Cleaning Systems

a. Inspection Scope

The inspectors assessed whether surveillance test results since the previous inspection for TS required ventilation effluent discharge systems (high-efficiency particulate air and charcoal filtration), such as the Containment/Auxiliary Building Ventilation System, meet TS acceptance criteria.

b. Findings

No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

The inspectors reviewed all significant changes in reported dose values compared to the previous radiological effluent release report (e.g., a factor of 5, or increases that approach Appendix I criteria) to evaluate the factors, which may have resulted in the change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.

Inspectors evaluated the methods used to determine the isotopes that are included in the source term to ensure all applicable radionuclides are included, within detectability standards. The review included the current 10 CFR Part 61 analyses to ensure hard-to-detect radionuclides are included in the source term.

The inspectors reviewed changes in the licensees offsite dose calculations since the last inspection to verify the changes are consistent with the ODCM Manual and Regulatory Guide 1.109. Inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to ensure appropriate factors are being used for public dose calculations.

The inspectors reviewed the latest Land Use Census to verify that changes (e.g.,

significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public or critical receptor, etc.) have been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) are within the 10 CFR Part 50, Appendix I and TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

No findings were identified.

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to determine if the licensee has implemented its program as intended, and to identify any anomalous results. For anomalous results or missed samples, the inspectors assessed whether the licensee has identified and addressed deficiencies through its corrective action program.

The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75

(g) records. The inspectors reviewed evaluations of leaks or spills, and reviewed any remediation actions taken for effectiveness. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:

• Assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term and assessing whether a survey/evaluation has been performed to include consideration of hard-to-detect radionuclides.

• Determining whether the licensee completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contain or potentially contain radioactivity, and the potential for ground water leakage from these onsite surface water bodies. The inspectors assessed whether the licensee is properly accounting for discharges from these surface water bodies as part of their effluent release reports.

The inspectors assessed whether on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year are documented in the Annual Radiological Environmental Operating Report for the radiological environmental monitoring program or the Annual Radiological Effluent Release Report for the radiological effluent TS.

For significant, new effluent discharge points (such as significant or continuing leakage to ground water that continues to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

Inspectors assessed whether problems associated with the effluent monitoring and control program are being identified by the licensee at an appropriate threshold and are properly addressed for resolution in the licensee corrective action program. In addition, they evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index

- Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Heat Removal System performance indicator for the period from the fourth quarter 2009 through the third quarter 2010. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator narrative logs, condition reports, event reports, MSPI derivation reports, and NRC Integrated Inspection Reports for the period of October 2009 through September 2010 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI heat removal system sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index - Residual Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal System performance indicator for the period from the fourth quarter 2009 through the third quarter 2010. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports for the period of October 2009 through September 2010 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI residual heat removal system sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - Cooling Water Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems performance indicator for the period from the fourth quarter 2009 through the third quarter 2010. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports for the period of October 2009 through September 2010 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI cooling water system sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific activity PI for Davis-Besse Nuclear Power Station for the period from the first quarter 2009 through the third quarter 2010. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees reactor coolant system chemistry samples, TS requirements, issue reports, event reports, and NRC Integrated Inspection Reports for the period of the first quarter 2009 and through the third quarter of 2010 to validate the accuracy of the submittals.

The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one reactor coolant system specific activity sample as defined in IP 71151-05.

b. Findings

No findings were identified

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six month period of July 1, 2010, through December 31, 2010, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted a single semi-annual trend inspection sample as defined in IP 71152-05.

b.

Observations The inspectors identified an adverse trend related to the licensees management of TS and Limiting Conditions for Operations (LCOs):

• On August 26, 2010, licensee personnel identified that spent fuel was being stored in the spent fuel pool in a manner contrary to the pattern requirements set forth in TS 3.7.16. An initial condition report, CR 10-81824, generated by licensee personnel classified the issue as administrative, and failed to properly identify the TS compliance issue. On August 27, 2010, the licensee revisited the issue following discussions with the inspectors, and ultimately submitted an LER (05000346/2010-004-00) under 10 CFR 50.73(a)(2) (i)(B) for the operation of the facility in a condition prohibited by TS. The licensee had entered the TS compliance issue into the CAP as CR 10-83814.

• On November 18, 2010, while restoring from an EDG 1 work window, the licensee identified that the load sequencer for EDG 1 had been declared operable prior to the performance of required post maintenance testing for the component. The licensee documented this issue in their CAP as CR 10-86284.

• On November 22, 2010, a licensee Senior Reactor Operator (SRO) identified a degraded condition with a terminal lug connection associated with AFW Pump No. 1 during review of CR 10-86147, and the pump was declared inoperable.

This was over 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> after the initial identification of the degraded condition by licensee craft workers on November 21, 2010, but no CR was generated until the following day. The licensee entered the TS compliance issues into their CAP as CRs 10-86191 and 10-86284.

In each of these cases, the safety significance of the errors was minimal as a matter of coincidence. However, taken collectively they represent an adverse trend that requires mitigation.

c. Findings

No findings were identified.

.4 Selected Issue Follow-Up Inspection Associated with Temporary Instruction 2515/177,

Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems: Gas Voids Detected in High Pressure Injection Discharge Piping

a. Inspection Scope

During a review of items entered in the licensees CAP, the inspectors recognized a corrective action item documenting voids discovered in HPI discharge piping.

CR 10-82372 documents a small void (approximately 38 cubic inches) discovered immediately below HP2B, HPI train 2 discharge isolation valve. The void was detected during the performance of a monthly void monitoring PM on September 8, 2010.

CR 10-81409 evaluated a similar small void in HPI train 2 discharge piping near HP66, discharge line vent valve, discovered on August 18, 2010. In addition, on October 4, 2010, a follow-up void inspection documented a void on the discharge line near vent valve HP40A (CR 10-83609). Davis-Besse engineering determined that in all cases, the void sizes remained below the critical void size and did not have the potential to create an adverse water hammer event. Follow-up void inspections determined that the void size was not increasing, therefore, gas intrusion from a gas source was not considered as a credible cause. The most likely cause of gas intrusion was determined to be from inadequate draining/refilling of the system following maintenance activities performed earlier in August 2010. Specifically, there was less than adequate procedural guidance for refilling the system. A corrective action was created to revise the HPI system operating procedure to incorporate appropriate guidance for performing venting of the HPI discharge branch beneath the discharge valves for both trains of HPI. A corrective action is also tracking completion of the HPI comprehensive and check valve forward flow test during an upcoming outage, which will ensure that the HPI piping is swept free of any residual voids.

The inspectors verified that the selected CAP entry acceptably addresses the areas of concern associated with the scope of GL 2008-01, Managing gas accumulation in emergency core cooling, decay heat removal, and containment spray systems (Temporary Instruction (TI) 2515/177, Section 04.01).

This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05. In addition, this inspection effort counts towards the completion of TI 2515/177 which will be closed in a later Inspection Report.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Loss of the Oak Harbor Power Feeder

a. Inspection Scope

At 7:48 a.m. on October 5, 2010, the inspectors observed the licensees response to the loss of a 480 VAC transformer supplying power to various licensee facilities outside the stations main power block. The transient, which was caused by an animal-induced short, resulted in short duration power interruptions to several Emergency Preparedness facilities and components. Power to the stations Emergency Operations Facility and Technical Support Center was restored within minutes from the backup diesel generator supporting those facilities, and power to all facilities and components was reestablished by 10:30 a.m.

The inspectors reviewed the appropriateness of the licensees actions against the requirements of applicable procedures, and independently reviewed the event against the reporting requirements in 10 CFR 50.72 and 50.73. Documents reviewed by the inspectors as a part of this inspection are listed in the Attachment.

This event follow-up review constituted one inspection sample as defined in IP 71153-05.

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report 05000346/2010-002-01, Control Rod Drive Nozzle

Primary Water Stress Corrosion Cracking and Pressure Boundary Leakage On September 30, 2010, the licensee submitted Revision 1 of the subject LER.

Previously, the inspectors had reviewed and closed Revision 0 of the LER in Inspection Report 05000346/2010008 (ADAMS Accession No. ML102930380).

The inspectors reviewed Revision 1 of the subject LER, which documented information regarding the results of the licensees root cause analysis performed in response to the subject event. This root cause analysis was still in progress at the time Revision 0 of the LER was required to be submitted. The inspectors determined that the licensees new information neither altered the conclusions drawn during the closure of Revision 0, nor constituted information that would lead to the identification of any new violations of NRC requirements. As a result, Revision 1 of this LER is closed. Documents reviewed by the inspectors as a part of this inspection are listed in the Attachment.

This LER review constituted one inspection sample as defined in IP 71153-05.

4OA5 Other Activities

.1 Licensee Activities and Meetings

In addition to regularly attending daily plant status meetings, the inspectors observed select portions of other licensee activities and meetings and met with licensee personnel to discuss various topics. The activities that were sampled included:

• Davis-Besse Monthly Performance Review meeting with First Energy Nuclear Operating Company (FENOC) executives on October 22, 2010;

• Fleet Oversight audit exit on October 8, 2010, of findings from a review of Chemistry Department activities at Davis-Besse and other FENOC nuclear plants;

• Plant supervisor periodic briefing on November 8, 2010; and

• Corporate Nuclear Review Board exit meeting on December 3, 2010.

.2 (Open) NRC Temporary Instruction 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01)

High Pressure Injection System Walkdown

a. Inspection Scope

On March 17 and 22, 2010, the inspectors conducted a walkdown of the HPI system inside containment in sufficient detail to reasonably assure the acceptability of the licensees walkdowns. The licensees documented walkdown results were not available to the inspectors at the end of that inspection interval. During this inspection interval the inspectors verified that the licensees documented results were consistent with the isometric drawings and results from the inspectors walkdown documented in Davis-Besse Inspection Report 05000346/2010-002 (TI 2515/177, Section 04.02.d).

Documents reviewed are listed in the Attachment to this report.

b. Findings

This inspection effort counts towards the completion of TI 2515/177 which will be closed in a later inspection report.

Review of High Pressure Injection Piping Void As documented in Section 4OA2, the inspectors confirmed the acceptability of the described licensees actions. This inspection effort counts towards the completion of TI 2515/177 which will be closed in a later Inspection Report.

.3 Operation of an Independent Spent Fuel Storage Installation (60855.1)

a. Inspection Scope

The inspectors conducted document reviews, held discussions with licensee staff, and performed a walkdown of the Independent Spent Fuel Storage Installation (ISFSI) to assess compliance with the applicable Certificate of Compliance, TSs, and the Site

Safety Analysis Report. During the walkdown, the condition of the Horizontal Storage Modules was evaluated and the inspectors observed the licensee perform routine surveillance activities, including inspections of the vent screens and taking thermocouple readings.

Plant procedures were reviewed to determine whether the licensee had adequate controls in place to monitor the radiation dose resulting from the operation of the ISFSI.

The inspectors reviewed several routine radiation surveys performed by the licensee around the pad, and conducted independent surveys to verify dose rates. Additionally, the inspectors reviewed the licensees procedures for control of special nuclear material, and the most recent annual inventory as it related to the ISFSI, to verify that the fuel in the Dry Storage Canisters was accounted for and controlled. The inspectors determined if the site had an unloading procedure and reviewed the control of transient combustible material procedure, emergency procedures, and the Emergency Plan for their adequacy in regard to the ISFSI.

Condition reports, and the associated follow up actions, were reviewed to assess the adequacy and timeliness of the licensees corrective actions. A number of 10 CFR 72.48 screenings were reviewed, focusing on those associated with the temporary storage of Sea-Land containers on the ISFSI pad, for compliance with the transient combustible procedure, the 72.212 report, and the Site Safety Analysis Report.

b. Findings

No findings were identified

.4 (Closed) Violation,05000346/2009007-01; Inappropriate Change of Fuel Transfer Tube

Seal Configuration: Follow up on Traditional Enforcement Actions Including Violations (92702)

In a letter dated February 19, 2010, (ML100501213) and a final enforcement letter, dated April 30, 2010, (ML101200649), violations of 10 CFR Part 50, Appendix B, Criterion III, Design Control, and 10 CFR 50.71(e) were issued to the licensee for the failure to implement design control measures, which assured that the design basis, as specified in the license application, was correctly translated into specifications, drawings, procedures, and instructions and failed to correctly update the USAR to reflect the safety analyses associated with License Amendment 240. As a result of these failures, the fuel transfer tube blind flange seal configuration was contrary to the licensing basis.

During this inspection, inspectors reviewed the licensees corrective actions as described in a letter dated March 22, 2010 (ML102520102). The inspectors verified that revisions had been made to the following procedures to address the violation:

• NOP-LP-4008, Revision 02, Licensing Document Change Process;

• NOP-CC-2007, Revision 02, Part and Component Equivalent Replacement Packages;

• NOP-CC-2004 Revision 07, Design Interface Reviews and Evaluations;

• NOP-CC-2003, Revision 14, Engineering Changes; and

• Procedure DB-MM-09186, Revision 06, Fuel Transfer Tube Blind Flange Removal and Reinstallation.

The inspectors also verified that the licensee installed, as described in the USAR and License Amendment (LA) 240, a double O-Ring configuration into the fuel transfer tube blind flange assemblies. With this configuration, the licensee is crediting the excellent testing history as described in LA 240. The licensee plans to conduct as-found testing on the double O-Ring configuration during the fall 2011 mid-cycle outage to confirm similar performance as described by the as-found test results from 1991-1998. This action is being tracked by CR 10-85444 and WO 200428110.

No additional findings were identified. This violation is closed.

.5 (Closed) Temporary Instruction 2515/179, Verification of Licensee Responses to

NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)

a. Inspection Scope

The inspectors confirmed that the licensee has reported the initial inventories of sealed sources pursuant to 10 CFR 20.2207 and verified that the National Source Tracking System database correctly reflects the Category 1 and 2 sealed sources in custody of the licensee. Inspectors interviewed personnel and performed the following:

• reviewed the licensees source inventory;

• verified the presence of any Category 1 or 2 sources, the licensee possessed 2 Category 2 sources;

• reviewed procedures for and evaluated the effectiveness of storage and handling of sources;

• reviewed documents involving transactions of sources; and

• reviewed adequacy of licensee maintenance, posting, and labeling of nationally tracked sources.

b. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting Summary

On January 18, 2010, the inspectors presented the inspection results to Mr. B. Boles and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material reviewed during the inspection was controlled in accordance with NRC policy, and annotated as proprietary in the List of Documents Reviewed.

.2 Interim Exit Meetings

Interim exit meetings were conducted for:

• the ISFSI operational inspection included an interim exit meeting on November 19, 2010. The inspectors presented the inspection results to members of the licensee management and staff. Licensee personnel acknowledged the information presented;

• the radioactive gaseous and liquid effluent treatment and a performance indicator under the public radiation safety cornerstone and under occupational radiation safety cornerstone with Mr. B. Boles, Director - Operations, on November 19, 2010;

• the closure of VIO 05000346/2009007-01 with Mr. J. Sturdavant, Senior Nuclear Specialist, Regulatory Compliance via telephone on December 10, 2010;

• the results of the licensed operator requalification training program inspection with the Site Vice President, Mr. B. Allen, on November 19, 2010;

• the licensed operator requalification training biennial written examination and annual operating test results with the Nuclear Compliance Supervisor, Mr. G. Wolfe, via telephone on December 8, 2010; and

• the radiological hazard assessment and exposure controls and occupational ALARA planning and controls under the Occupational Radiation Safety Cornerstone, and verification of licensee responses to NRC requirement for inventories of materials tracked in the National Source Tracking System with Mr. B. Allen, Site Vice President on December 17, 2010.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material reviewed during the inspection was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Allen, Site Vice President

P. Boissoneault; Chemistry Manager

B. Boles, Director, Site Operations

K. Byrd, Director, Site Performance Improvement

G. Chung, Radiation Monitor System Engineer

D. Dibert, Reactor Engineer, Plant Engineering

J. Dominy, Director, Site Maintenance

A. Garza, ALARA Specialist (Lead for Set Point Manual)

G. Hayes, Reactor Engineering Supervisor, Plant Engineering

R. Hovland, Training Manager

V. Kaminskas, Director, Site Engineering

P. McCloskey, Manager, Site Regulatory Compliance

D. Noble, Radiation Protection Manager

A. Percival, Sr. Chemistry Technologist (Liquid Radwaste and Effluent Analysis)

J. Scott, Supervisor RP

C. Steenbergen, Operations Training Superintendent

J. Sturdavant, Regulatory Compliance

S. Trickett, Superintendent Radiation Protection

J. Vetter, Emergency Response Manager

A. Wise, Technical Services Manager

G. Wolf, Supervisor, Regulatory Compliance

LIST OF ITEMS

Opened

None.

Closed

05000346/2010-002-01 LER Control Rod Drive Nozzle Primary Water Stress Corrosion Cracking and Pressure Boundary Leakage (Section 4OA3.2)

05000346/2009007-01 VIO Inappropriate Change of Fuel Transfer Tube Seal Configuration (4OA5)

TI 2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (4OA5)

Discussed

None.