IR 05000346/2015007

IR 05000346/2015007; 03/23/2015 - 04/10/2015; Davis-Besse Nuclear Power Station; Biennial Problem Identification and Resolution (Pi&R) Inspection

ML15127A262
Person / Time
Site:	Davis Besse
Issue date:	05/06/2015
From:	Jamnes Cameron Division Reactor Projects III
To:	Lieb R FirstEnergy Nuclear Operating Co
References
IR 2015007
Download: ML15127A262 (24)

Text

May 6, 2015

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION-NRC PROBLEM

IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2015007

Dear Mr. Lieb:

On April 10, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Davis-Besse Nuclear Power Station.

The enclosed report documents the results of this inspection, which were discussed on April 10, 2015, with you and other members of your staff.

Based on the inspection sample, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety. Discussed in the enclosed report is an identified weakness associated with the review of 10 CFR 21 reports.

Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects

Docket Nos. 50-346 License No. NPF-3

Enclosure:

Inspection Reports 05000346/2015007 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-346 License No:

NPF-3

Report No:

05000346/2015007 Licensee:

FirstEnergy Nuclear Operating Company (FENOC) Facility:

Davis-Besse Nuclear Power Station

Location:

Oak Harbor, OH Dates:

March 23 through April 10, 2015

Inspectors:

J. Rutkowski, Project Engineer, Team Lead M. Jones, Reactor Inspector, DRS R. Telson, Reactor Operations Engineer, NRR T. Briley, Resident Inspector

Approved by:

J. Cameron, Chief Branch 4 Division of Reactor Projects

SUMMARY OF FINDINGS

Inspection Report (IR) 05000346/2015007; 03/23/2015-04/10/2015; Davis-Besse Nuclear

Power Station; Biennial Problem Identification and Resolution (PI&R) Inspection This inspection was performed by two NRC regional inspectors, one headquarters inspector, and the Davis-Besse Nuclear Power Station resident inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Problem Identification and Resolution On the basis of the sample selected for review, the team determined that implementation of the corrective action (CA) program at the Davis-Besse Nuclear Power Station was generally good. The licensee demonstrated a low threshold for identifying problems and entering them in the CA program. Items entered into the CA program were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns directly into the CA program or through their supervisors.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through.4 constituted one biennial sample of

problem identification and resolution as defined in Inspection Procedure 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspector reviewed the licensees corrective action (CA) program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CA program since the last NRC Problem Identification and Resolution (PI&R) inspection in August 2013. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self assessment, licensee audits, operating experience (OE) reports, and NRC documented findings as sources to select issues.

Additionally, the inspectors reviewed condition reports (CRs) generated as a result of facility personnels performance in daily plant activities. The inspectors also reviewed a selection of work orders, self-assessment results, audits, performance indicator reports, system health reports, and completed investigations from the licensees various investigation methods, which included root cause, full apparent cause, limited apparent cause, and human performance investigations.

The inspectors selected the auxiliary feedwater system to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of this system through effective implementation of station monitoring programs. A 5-year review on the auxiliary feedwater system was also undertaken to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the component cooling water system to determine if there were readily identifiable issues with the system and if any identified issues were adequately described in the CA program and system health documents.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys corrective action program and Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying station issues at the proper threshold, entering the station issues into the stations CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations (NCVs).

Documents reviewed are listed in the Attachment to this report.

b.

Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and interviews, the inspectors determined that the licensee has a low threshold for initiating CRs, and from the CRs reviewed, the threshold was appropriate. Some of the non-supervisory personnel interviewed stated that the CA program was not effective for low-level issues but also stated that they would report nuclear safety issues. The inspectors did not identify any safety significant item that was not entered into the CA program. The inspectors assessed the effectiveness of problem identification as adequate.

Observations The inspectors found that issues were being identified and captured in the licensees programs and particularly in the CA program. During non-outage months of 2014, licensee documents indicated an initiation rate of about 300 to 370 CRs per month. In Year 2013 non-outage periods, CR generations were about 350 to 500 CRs per month.

The licensee classified greater than 95 percent of 2014 CRs as low-level CRs and classified them as close to a work order or trending or to a fix category. No formal cause determination is required for low-level CRs by the licensees programs.

The inspectors also noted that the licensees procedures allowed specific low-level non-safety issues to be addressed through the work order notification/request system without initiating a CR. A licensee Nuclear Maintenance Screening Committee screens equipment work order notifications/requests to determine if CRs should have been generated. The inspectors reviewed the functioning of that committee by observing a committee meeting. The inspectors did not identify any instances where CRs should have been written and were not.

The inspectors did identify that licensees corporate team model includes a FIN-SRO

[Fix-It-Now Senior Reactor Operator] which serves as the chairman of the screening committee but that Davis-Besse has not had a FIN-SRO for approximately 2 years.

The inspectors did note that the current FIN manager served as committee chairman and previously held a senior reactor operator license. The licensee initiated CR2015-04922, Notification Review Board is not staffed with a FIN-SRO.

The inspectors reviewed the licensees efforts and a licensee presentation on their efforts to address industry concerns regarding the cumulative impacts of regulation.

Part of the licensees actions include efforts to minimize the initiation of CRs for issues that are not safety related and can be addressed totally outside of the CA program.

The inspectors also noted through interviews that the majority of the 16 security officers interviewed stated that they do not directly generate CRs but, instead, bring issues to their supervisors.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensees overall performance in the prioritization and evaluation of issues was appropriate. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were being appropriately screened by supervisors of originators, the Management Review Board, and Operations shift management for items potentially impacting equipment operability. Evaluations in apparent cause and root cause reports reviewed by the inspectors were adequate. There were no items identified by the inspectors in the backlogs of the CA program or maintenance that were risk significant, either individually or collectively. The inspectors reviewed the licensees work order backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

Observations The inspectors reviewed CR2013-10934, Declining Trend in Station Human Performance, CR2013-08561, Use of a Questioning Attitude During Maintenance, CR2015-01246, DB Mechanical Maintenance Unit Safety Performance Review Required, and CR2014-18342, CNRB Executive Summary ItemRecent lapses in Operator Fundamentals are Resulting in Consequential Errors to review the licensees investigation of causes for human performance issues. The licensees multiple apparent cause investigations generally shared the conclusions that issues were due to one or several of the following issues:

• Multiple focus areas caused some human performance tools to be unintentionally overlooked;

• Lack of focus due to the numerous administrative requirements (pre-job briefs, meetings, etc.);

• There was a misalignment among management, supervisor, and worker expectations;

• Supervisors were not spending enough time in the field engaging workers effectively; and

• Lack of training on and effective use of management observations.

The inspectors questioned if the licensee looked at the commonality among the various identified issues. Specifically the inspectors questioned why the investigators did not look deeper into why supervisors and management were not spending more time in the field with crews and if there were some issue(s) preventing such action. There was in one apparent causes a statement that administrative requirements may be a contributor to the overall issues associated with human performance and oversight of activities.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the CAs appeared appropriate for the identified issues. Those CAs addressing selected NRC documented violations were also determined to be effective and timely. The inspectors review of the previous five years of the licensees efforts to address issues with the auxiliary feedwater system did not identify any negative trends or inability by the licensee to address long-term issues.

Observations The licensee had numerous CRs written to document human performance issues. The inspectors, as part of their review of human performance investigations, reviewed licensee performance indicator D-SPO-04A-Feb 15, Performance Errors &

performance Error Rate. That indicator of the monthly performance error rate (errors per hours worked) from September 2013 through February 2015 remained relatively stable with some decline in February of 2015. The number of performance errors had decreased consistent with the numbers of recorded work hours. The two largest counted departments (Operations and Security) were also the organizations which experienced the highest number of performance errors in February 2015 (10 and 7 respectively).

The inspectors performed numerous key word searches of the licensee corrective actions program system related to the auxiliary feedwater systems to search for repetitive/repeat issues. The inspectors did not identify any trends that would indicate an increase in the age related issues for the auxiliary feedwater (AFW) system.

The inspectors also noted that the licensee had two repeat NRC findings during the last 3 years. One was associated with failure to close trash gates in the containment and one associated with water in a manhole. For the second occurrence of each of these NRC findings, the licensee initiated corrective action that should prevent the occurrence of another repeat for the same issues.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys OE program.

Specifically, the inspectors reviewed OE program implementing procedures, attended CA program meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if CAs, as a result of OE, were identified and implemented in an effective and timely manner.

Assessment Overall, the inspectors determined that the licensee was adequately evaluating industry OE for relevance to the facility. Both internal and external OE was effectively disseminated across the various plant departments and was being incorporated into lessons learned for training, daily status meetings, and pre-job briefs. System Engineers utilized industry OE to resolve equipment operational problems. The inspectors also verified that the use of OE in formal CA program products such as root cause evaluations and apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to the facility was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Observations The inspectors noted that the licensee continued to exhibit weakness in maintaining the 10 CFR Part 21 notification database up-to-date to ensure appropriate screening and evaluations were performed in a timely manner. The NRC inspectors had originally identified the weakness in NRC Problem Identification and Resolution IR 2013007, dated August 9, 2013, which had resulted in backlogged 10 CFR Part 21 notifications when the Part 21 coordinator was transferred to another group. The licensee had initiated CR2013-12246 to review all backlogged 10 CFR Part 21 notifications and perform periodic reviews going forward on a monthly basis.

In December 2014, the licensee identified through a focused self-assessment that the 10 CFR Part 21 database was not adequately kept up-to-date due to several notifications that had not been listed, numerous notifications that were listed with no documented resolution, and reviews only being performed several times per year.

Condition report 2015-00282 was generated to update the database, track monthly reviews via the notification tracking process, and develop a new performance indicator to monitor performance. While updating the database, the licensee identified one example where a 10 CFR Part 21 notification was received but an evaluation had not been performed for approximately 18 months. The notification did involve equipment installed in the stations safety-related auxiliary feedwater system. Condition report 2015-03210 was generated to document the issue and an evaluation was performed which concluded there were no impacts on auxiliary feedwater system operability.

b. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.

Observations The inspectors reviewed the licensees assessment of their self-assessment and benchmarking program. The two provided assessments appeared to review and assess the compliance of their programs with existing procedural requirements and did not generally look at the effectiveness of the programs. However, the inspectors overall assessment of the self-assessment process did indicate that the programs appeared to meet licensee intended requirements for identifying issues.

b. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with the coordinator of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2013 and a 2014 SCWE survey.

As part of the overall inspection effort, inspectors discussed department and station programs with a variety of people. In addition, the inspectors held scheduled interviews with 31 non-supervisory individuals, in groups of 3 to 7 people, from various departments to assess their willingness to raise nuclear safety issues. Additionally at least 21 personnel were randomly interviewed on their views of the effectiveness of the CA program.

The individuals for the scheduled interviews were randomly selected to provide a distribution across the various departments at the site and in particular departments in which approximately 20 to 40 percent of people did not express positive responses to 2014 survey questions on CA program effectiveness or interactions with management or the ECP. In addition, to assessing individuals willingness to raise nuclear safety issues, the interviews also included discussion on any changes in the plant environment over the last 18 months. Other items discussed included:

• knowledge and understanding of the CA program;

• effectiveness and efficiency of the CA program;

• willingness to use the CA program; and

• knowledge and understanding of ECP.

Assessment The inspectors did not identify any issues of concern regarding the licensees safety conscious work environment. Information obtained during the interviews indicated that an environment was established where the majority of licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CA program and other processes, including the ECP and the NRC, through which concerns could be raised; safety significant issues could be freely communicated to supervision. The inspectors did not observe and were not provided any examples where there was retaliation for any raising of nuclear safety issues. Documents provided to the inspectors regarding SCWE surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.

Observations While all interviewees stated that they would discuss issues with their supervisors and would bring up any and all nuclear safety issues, several interviewees voiced opinions that the CA program is not effective for low-level issues. Several of the interviewed security officers indicated that they did not interface with CA program and that the program was not effective in addressing issues within their department.

Other general themes mentioned by interviewees were previously identified and discussed in licensee apparent causes and investigations. These included the interviewees expressed beliefs that the station craft manning should be larger and that craft supervision was burdened with excessive administrative requirements.

The majority of interviewed personnel stated that they had not used the ECP program or saw no need to use the program because they had other avenues to address their concerns. Two of the interviewed personnel said they would not use the ECP program because of some past perceived issues with the program maintaining confidentially.

The inspectors concluded that the interview results appeared consistent with SCWE survey results. The inspectors noted that the licensee had documented and investigated the concerns identified in the SCWE surveys.

b. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting Summary

On April 10, 2015, the inspectors presented the inspection results to the Site Vice President, Mr. R. Lieb, 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.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Lieb, Site Vice President

K. Byrd, Director, Site Engineering

G. Cramer, Manager, Site Protection

J. Cuff, Manager, Training

J. Cunnings, Manager, Site Maintenance

J. Hook, Manager, Design Engineering

D. Imlay, Director, Site Performance Improvement

G. Laird, Manager, Technical Services Engineering

B. Matty, Manager, Plant Engineering

P. McCloskey, Manager, Site Regulatory Compliance

D. Noble, Manager, Radiation Protection

R. Oesterle, Superintendent, Nuclear Operations

R. Patrick, Manager, Site Work Management

D. Saltz, Director, Site Maintenance

J. Sturdavant, Regulatory Compliance

L. Thomas, Manager, Nuclear Supply Chain

Nuclear Regulatory Commission

D. Kimble, Senior Resident Inspector, Davis-Besse

J. Cameron, Branch Chief

LIST OF ITEMS

Opened

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Closed

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