IR 05000346/2019003
| ML19317E451 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/12/2019 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR 2019003 | |
| Download: ML19317E451 (25) | |
Text
November 12, 2019
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2019003
Dear Mr. Bezilla:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On October 8, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Davis-Besse.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Davis-Besse. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects
Docket No. 05000346 License No. NPF-3
Enclosure:
As stated
Inspection Report
Docket Number:
05000346
License Number:
Report Number:
Enterprise Identifier: I-2019-003-0064
Licensee:
FirstEnergy Nuclear Operating Company
Facility:
Davis-Besse Nuclear Power Station
Location:
Oak Harbor, OH
Inspection Dates:
July 01, 2019 to September 30, 2019
Inspectors:
J. Cassidy, Senior Health Physicist
T. Go, Health Physicist
J. Harvey, Resident Inspector
D. Mills, Senior Resident Inspector
V. Myers, Senior Health Physicist
J. Rutkowski, Project Engineer
Approved By:
Billy C. Dickson, Jr., Chief
Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Davis-Besse Nuclear Power Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Recognize and Correct Fisher Controls Butterfly Valve Taper Pin Defects Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000346/2019003-01 Open/Closed
[P.5] -
Operating Experience 71111.12 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings for the licensees failure to prescribe instructions and procedures appropriate to the circumstances for an activity affecting quality. Specifically, the licensee failed to accomplish repairs to a safety-related butterfly valve in accordance with appropriate instructions and procedures. The inspectors identified that actions taken by the licensee to address loose taper pins associated with the safety related component cooling water system were performed without appropriate instructions and procedures that incorporated appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000346/2018-001-00 LER 2019-001-00 for Davis-Besse, Unit 1, Borated Water Storage Tank Level Transmitter Out of Tolerance Due to Reaching End of Expected Life 71153 Closed
PLANT STATUS
The unit began the inspection period operating at full power. On September 7, 2019, during scheduled testing of the main turbine stop valves, the unit tripped from 95 percent power. The licensee determined that the cause of the unit trip was a faulty fast-acting solenoid valve in the main turbine electrohydraulic control system which caused a second stop valve to close while the number two valve was closing as planned per the test. The plant operators started up the unit on September 10, 2019. The unit reached full power operations on September 11. The licensee continued to operate the unit at or near full power through the remainder of the inspection period.
On April 25, 2018, FirstEnergy Solutions (FES) / FirstEnergy Nuclear Operating Company (FENOC) notified the U.S. Nuclear Regulatory Commission (NRC) that they intend to shut down all four of their operating nuclear power plants (ADAMS Accession Number ML18115A007). On March 21, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and FENOC filed for bankruptcy. On July 26, 2019, FES/FENOC submitted a letter to the NRC withdrawing the April 25, 2018, certification of permanent cessation of power operations for Davis-Besse Nuclear Power Station and Perry Nuclear Power Plant (ADAMS Accession Number ML19207A097). The NRC continues to maintain focus on public health and safety and the protection of the environment. This will include a continuous evaluation by inspectors to determine whether the licensee's financial condition is impacting safe operation of the plant.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas:
- Plant site and service water tunnel flooding due to lake wave run-up and local heavy precipitation
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Low Pressure Injection 2 while Low Pressure Injection 1 was inoperable due to oil sample tube stuck in the outboard pump bearing sump during the week ending July 27, 2019
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
- (1) Fire Brigade drill involving simulated fire at Startup Transformer X01 during the week ending August 3, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Emergency Feedwater Facility, Fire area EF, on September 18, 2019
- (2) Service Water Pipe Tunnel, Fire area BG, on September 18, 2019
- (3) Electrical Penetration Room 1, Fire area DG, on September 17, 2019
- (4) Control Room and Adjacent Support Rooms, Fire area FF, on September 20, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Auxiliary Building Rooms 300, 304, 310, 312, 313, 314, 404, and 411 due to roof loading of rain or snow and a feedwater line break
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during the performance of control rod exercising, turbine valve testing, reactor trip, Mode 3 operation, reactor startup, and reactor power ascension during the week ending September 14, 2019
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated operator performance during the quarterly emergency response integrated drill on September 17, 2019
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Emergent maintenance on Low Pressure Injection Pump 1 requiring disassembly of bearing housing to remove foreign material in the outboard bearing during the week ending July 27, 2019
- (2) Reactor Protection System calibration during the week ending July 27, 2019
Quality Control (IP Section 02.02) (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:
- (1) Replacement of Component Cooling Water Heat Exchanger 2 outlet isolation valve, Service Water 38, during the week ending August 31, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Emergent maintenance on Low Pressure Injection Pump 1 due to foreign material in the outboard bearing and planned testing during the week ending July 27, 2019
- (2) Control Room Emergency Air Temperature Control System out of service for planned maintenance during the week ending August 3, 2019
- (3) Replacement of Service Water 38, Component Cooling Water Heat Exchanger 2 Outlet Isolation Valve during the week ending August 31, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (3 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Intake canal sediment buildup, CR 2019-02869
- (2) Component Cooling Water Heat Exchanger 2 outlet isolation valve leaks by in the closed position, CR 2019-00817
- (3) Core Flood Tank 1 fill and pressurization isolation valve leak by, CR 2019-06314
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Reactor Protection System Channel 1 calibration of overpower, power/imbalance/flow, and power/pumps trip functions after flux/delta flux/flow bistable replacement during the week ending July 20, 2019
- (2) Reactor Protection System/Safety Features Actuation System Channel 2 Containment Pressure Switches Isolation Valve after planned work during the week ending July 27, 2019
- (3) Reactor Trip Breaker response time test after breaker swap of Control Rod Drive System primary trip breaker 2 during the week ending August 31, 2019
- (4) Electro Hydraulic turbine control system and Anticipatory Reactor Trip System functional testing following reactor trip and maintenance activities during the week ending September 14, 2019
- (5) Station Blackout Diesel testing after replacement of the speed selector switch during the week ending July 13, 2019
- (6) Component Cooling Water 2 after replacement of Component Cooling Water Heat Exchanger 2 Outlet Isolation Valve during the week ending August 31, 2019
- (7) Station Emergency Ventilation System Train 1 following replacement of Pressure Differential Transmitter PDT5000 during the week ending July 27, 2019
- (8) Reactor Protection System Channel 3 after replacement of Channel 3 power supplies during the week ending September 21, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated forced outage activities from September 7 to September 10, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Channel functional test of Steam Feed Rupture Control System Actuation Channel 1 logic for Mode 1 during the week ending July 27, 2019
- (2) Low Pressure Injection/Decay Heat Pump 1 quarterly surveillance test during the week ending July 27, 2019
- (3) Control Rod exercising and Turbine Valve testing during the week ending September 14, 2019
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Emergency Feedwater Pump quarterly surveillance testing following scheduled preventive maintenance during the week ending September 21, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Observation of licensee emergency response organization during the integrated drill on September 17,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:
- (1) Station Vent Normal Range Radiation Monitors Waste Gas System Outlet Radiation Monitors Miscellaneous Waste Radiation Monitors Clean Waste Discharge Radiation Monitors
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
- (1) Gaseous - RE-4598 - Station Vent Normal Range Radiation Monitors Liquid - RE-1822 - Waste Gas System Outlet Radiation Monitors Liquid - RE-1878 - Miscellaneous Waste Radiation Monitors Liquid - RE-1770 - Clean Waste Discharge Radiation Monitors
Sampling and Analysis (IP Section 02.03) (1 Sample)
The inspectors reviewed the following:
- (1) Radioactive Effluent Sampling and Analysis Activities
Effluent Discharges
- 19-M0022G
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
- (1) Work Order 200709102 - Emergency Ventilation Systems (EVS) TRAIN 1 Refueling Interval or Special Test Work Order 200621820 - Emergency Ventilation Systems (EVS) TRAIN 2 Refueling Interval or Special Test
Dose Calculations (IP Section 02.05) (1 Sample)
The inspectors reviewed the following to asses public dose:
- (1) Liquid and Gaseous Discharge Permits
[List 1-3 of each type of permit reviewed (i.e. liquid discharge permit and gaseous discharge permit)]
- Gaseous, 19-0022G
- Gaseous, 18-B0006G
- Liquid, 18-B0024L
- Liquid, 18-B0023L
Annual Land Use Census Reports
- Completed October 2018
- Completed October 2017
Abnormal Gaseous or Liquid Tank Discharges
- None were available for review during this inspection]
71124.07 - Radiological Environmental Monitoring Program
Site Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the radiological environmental monitoring program implementation.
- (1) The inspectors reviewed the following:
Walkdowns, Calibrations, and Maintenance Record Review
- T-1; Air Sampler Located at Site Boundary 0.6 mile ENE of the Station
- T-2; Air Sampler Located at Site Boundary 0.9 mile E of the Station
- T-3; Air Sampler Located at Site Boundary 1.4 miles ESE of the Station
- T-9; Air Sampler Located at Oak Harbor, OH; 6.8 miles SW of the Station
- T-27; Air Sampler Located at Crane Creek 5.3 miles WNW of the Station
- T-1; Thermoluminescent Dosimeter (TLD) Monitoring Station Located at Site Boundary 0.6 mile ENE of the Station
- T-2; TLD Monitoring Station Located at Site Boundary 0.9 mile E of the Station
- T-3; TLD Monitoring Station Located at Site Boundary 1.4 miles ESE of the Station
- T-27; TLD Monitoring Station Located at Crane Creek 5.3 miles ENE of the Station
Environmental Sample Collections and Preparation Observation
- T-3; Untreated Surface Water Location; Site Boundary 1.4 miles ESE of the Station
- T-19; Broad-leaf Vegetation and Fruit Locations; L. Bowyer, 1.0 mile W of the Station
- T-22B; Treated Surface Water Location at Carrol Water Treatment Plant
- T-11; Treated Surface Water Location at Ottawa County Regional Water Intake Facility; 9.5 miles SE of the Station
Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement
- During the walk-down, Location T-27 Air Sampler ODCM Control Location was found that Leaves near the Air Inlet Pathway Interfering with the Air Sampling Function and T-9 Air Sampler was found not Running for a week
- REMP Air Monitor Failure Trend from April 2018 through February 2019; REMP Air Monitors tripped; Manufacturer replaced defective motors
- Milk Sampling was eliminated due to unavailability this including the Control Sample Location, licensee replaced the unavailability with Broad Leaves Vegetation grown in the highest D/Q.
Sampling Program for the Potential of Licensed Material Entering Groundwater
- April 2018; a pipe containing Borated Water Storage Tank water found Leaking from Flange Connection onto a Concrete Pad and Reaching adjacent Area of Soil. Soil samples identified to contain mixed a Activation Products; however 2018 Groundwater Well Sample results and analysis did not Indicate a potential impact to the Groundwater to the surrounding Protected Area
- February 2015 Groundwater Monitoring Wells indicated that seven wells had higher than normal Tritium Concentrations, this was caused by Primary Water storage Tank construction activities
Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)
- (1) Inspectors Evaluated of Discharges from onsite water bodies that could have the potential to contain radioactivity and properly accounted all discharges.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) July 1, 2018 - June 30, 2019
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) July 1, 2018 - June 30, 2019
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 1 October 2018 - June 2019 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 2018 - June 2019
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends related to design drawing inaccuracy
===71153 - Follow-up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02)===
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000346 (ADAMS accession: ML19050A166), Borated Water Storage Tank Level Transmitter Out of Tolerance due to Reaching End of Expected Life
Personnel Performance (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated licensee performance during and following the unexpected reactor trip on September 7,
INSPECTION RESULTS
Failure to Recognize and Correct Fisher Controls Butterfly Valve Taper Pin Defects Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000346/2019003-01 Open/Closed
[P.5] -
Operating Experience 71111.12 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings for the licensees failure to prescribe instructions and procedures appropriate to the circumstances for an activity affecting quality. Specifically, the licensee failed to accomplish repairs to a safety-related butterfly valve in accordance with appropriate instructions and procedures. The inspectors identified that actions taken by the licensee to address loose taper pins associated with the safety related component cooling water system were performed without appropriate instructions and procedures that incorporated appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Description:
On June 4, 2019, the licensee was preparing to replace the Component Cooling Water heat exchanger #2 outlet isolation butterfly valve with a new valve received from the vendor, Fisher Controls International LLC, in 2017. Prior to installation the inspectors questioned the licensee as to why one of the three taper pins holding the disk to the butterfly appeared to be loose. In response to the inspectors question, the licensee performed repairs by resetting and staking the pins in accordance with mechanical maintenance procedure DB-MM-09317 Fisher type 9100 butterfly control valve maintenance. This resulted in the ends of the taper pins being flush with the surface of the disk.
Information Notice 2005-23, and Part 21 report 2005-42 described the issue of loose taper pins, with corrective actions to include the proper seating and staking of the pins. These references state that degradation of butterfly valves supplied by Fisher Controls and other manufacturers has occurred during plant operation as a result of the loss of taper pins used to connect the valve disc to stem. The degradation can involve leakage and affect valve operation. Taper pins lost from butterfly valves can also interfere with the operation of other plant components in fluid systems. The vendor manual details the requirement for the pin ends to be below the surface of the disk before peening. After review of the licensees actions taken to repair the valve, the inspectors noted that the pins were improperly set and staked and brought the concern to the licensee. Additionally, the inspectors identified the mechanical maintenance procedure, DB-MM-09317, included the vendor manual as a reference, but did not incorporate the vendor manual quantitative criteria ensuring the ends of the pins were below the surface of the disk before peening.
The licensee returned the valve to the vendor, who determined the pins were in fact improperly installed. This resulted in NRC Event Notification 54238, Part 21 report 2019-24, and Fisher (vendor) Information Notice 2019-01, which revised and clarified the steps necessary to achieve the quantitative criteria that the large end of the taper pins be driven below the surrounding surface and then the surrounding material peened over the heads.
Corrective Actions: The licensee entered this issue into their corrective action program. The Vendor, Fisher Controls International, submitted a Part 21 report (2019-21) detailing the issue. Additionally, mechanical maintenance procedure DB-MM-09317 Fisher type 9100 butterfly control valve maintenance was revised to include the updated vendor guidance regarding pin setting and peening.
Corrective Action References: CRs 2019-04914, 2019-05843, 2019-07152, 2019-06157, and 2019-07139
Performance Assessment:
Performance Deficiency: The inspectors determined that performing work on safety-related equipment without appropriate instructions and appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished was a performance deficiency that was reasonably within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The performance deficiency was more than minor because if left uncorrected, it has the potential to become a more significant safety concern. Specifically, attempting to repair and place into service the valve without prescribed instructions or procedures incorporating vendor recommended corrective actions would not have ensured the capability of the Component Cooling Water system to provide its mitigating function. Additionally, if left uncorrected, this performance deficiency could have led to failures in other safety-related fluid systems.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The finding had a cross-cutting aspect in the area of Problem identification and Resolution, cross-cutting area of Operating Experience, because the licensee did not systematically and effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner. Specifically, the licensee did not effectively evaluate and update the mechanical maintenance procedure even though the vendor manual was incorporated into it as a reference and included the necessary information. Additionally, there were multiple references available including recently updated vendor guidance, NRC Information Notice 2005-23, Part 21 report 2005-42 and other external operating experience. (P.5)
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, in August 2019, the licensee failed to include in instructions and procedures that include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, mechanical maintenance procedure DB-MM-09317 failed to provide appropriate criteria to ensure butterfly valve taper pins were seated correctly.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Review of Condition Reports Documenting Discovered Issues with Existing design Drawings 71152 The inspectors reviewed the licensee's corrective action program searching for condition reports that were coded with a cause code of CM.3 (Changes to plant configuration, design and licensing bases are evaluated, controlled, tested and implemented while consistency is maintained among the physical plant configuration, design and licensing requirements and the documented plant configuration). The inspectors were aware that some planned and scheduled plant work was held up because of differences between the physical plant and existing drawings that showed the current existing as-built plant. The inspectors wanted to determine the extent of the issue and licensee's actions to address any significant issues.
The inspectors' search encompassed condition reports initiated in 2019 to approximately September 1, 2019. The search identified seven condition reports that involved planned work where discrepancies were found between plant installed configurations and plant drawings.
The plant has four drawing categories/levels with each level reflecting the relative importance to safe and efficient operation. Level 1 drawings are used by plant operators and others to ensure safe and reliable operations. These drawings, that are in the operations Control Room, must be updated to reflect as-built configuration before a modified structure, system, or component is placed into service. Level 2 drawings are those that are critical to safe and effective operation, maintenance, and engineering but are not required in the Control Room.
Changes can be posted to these drawings with a Drawing Update Notice (DUN) but must have those changes incorporated in the drawing within 90 days of the third change being posted against the drawing.
Level 3 drawing are those deemed not critical to day-to-day operation, maintenance, and engineering of the plant but generally depict the as-designed plant and are retained for historical or regulatory purposes. DUNs are posted to the drawing but are not required to be incorporated in the drawing. Level 4 drawings depict a past configuration and do not need to be updated to display current plant configuration.
As of the end of August 2019, there 443 DUNs outstanding on Level 2 drawings and 1416 DUNs on Level 3 drawings. Also during August the licensee reported that 54 drawings were updated by incorporation of five Level 1 drawing DUNs, 19 Level 2 drawing DUNs, and 30 Level 3 drawings DUNs. The number of DUNs remained relatively flat with some small decrease in the total number of DUNs; the number of Level 2 DUNs in January 2019 was 468 and Level 3 DUNs totaled 1530.
The inspector's review of the backlog data and the results of the condition report search did not identify any safety significant issues. While the number of DUNs appears high, DUNs do represent corrections to the drawings that, for Level 2 drawings, will eventually be incorporated in the drawing. The licensee does have a program to control and process needed drawing changes and does require that Level 1 drawings in the Control Room are updated before a system with a new modification can be considered functional or operable.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 8, 2019, the inspectors presented the integrated inspection results to Mr. M. Bezilla, Site Vice President, and other members of the licensee staff.
- On August 22, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. D. Huey, General Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
Calc 54.22
Effect of Flooding from Water Treatment Building into Tunnel
Miscellaneous
Davis-Besse Focused Evaluation Regarding Near-Term
Task Force Recommendation 2.1 for Flooding
07/11/2017
UFSAR Section
2.4
Hydrology
Procedures
RA-EP-02830
Flooding
71111.04Q Drawings
OS-004 SH 1
Decay Heat Removal/ Low Pressure Injection System
Procedures
DB-OP-06012
DH Loop Normal Lineup Valve Checklist
DB-OP-06900
Plant Heatup
Miscellaneous
2-3-07/14/19-1
X01 Auxiliaries Fire
07/14/2019
2-3-08/01/19-1
X01 Auxiliaries Fire
08/01/2019
71111.05Q Fire Plans
Emergency Feedwater Facility
Procedures
No. 1 Electrical Penetration Room Room 402 Fire Area DG
Control Room and Adjacent Support Rooms, Rooms 502,
503, 504, 505, 506, 507, 510, 511, 512, and 513, Fire Area
Service Water Pipe Tunnel Room 250 Fire Area BG
Calculations
54.22
Effect of Flooding from Water Treatment Building into
Tunnel, Lowest Essential Valve Located at 574'6" in Valve
Room
Calc 05.039
Feedwater Flooding in Aux. Building
Miscellaneous
Davis-Besse Nuclear Power Station Emergency
Preparedness Integrated Drill
09/17/2019
UFSAR Section
3.6
Protection Against Dynamic and Environmental Effects
Associated with Postulated Rupture of Piping
Procedures
DB-OP-01001
Administrative Control of Containment Isolation Valves
RA-EP-02810
Tornado or High Winds
RA-EP-02830
Flooding
RA-EP-02880
Work Orders
2007088771
PM 5318 Cln-Insp Bldg Roof
71111.11Q Miscellaneous
Davis-Besse Nuclear Power Station Emergency
Preparedness Integrated Drill
09/17/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration
Records
FT-RC01A4
Reactor Coolant Loop 2 Hot Let Flow, RPS Ch 4 Flow
Transmitter
Corrective Action
Documents
CR 2018-02217
Reactor Coolant Loop 2 Hot Leg Flow Transmitter Found
Out-of-Tolerance
03/10/2018
CR 2018-03798
System Monitoring Identified Unexpected Increase in
Response Times for Reactor Protection System (RPS)
Channel 4
04/24/2018
CR 2018-07215
System Monitoring Identified Increased AC Ripple on ARTS
Channel 1 +10 VDC Power Supply
08/15/2018
CR 2019-05883
RPS Channel 1 Trip on Flux/Delta Flux/Flow
07/11/2019
CR G-201-2003-
272
Excessive Flow Through DH13B and/or DH14B - DB-SP-
04455 Driven CR
09/04/2003
CR G201-2002-
07065
F890 has Inaccurate Indication for Service Water Flow to
Collection Box
10/01/2002
CR G201-2003-
03385
Observed Degraded Condition of DH14B
05/01/2003
CR G201-2003-
07037
Missing Taper Pins
08/28/2003
CR G201-2003-
07066
DH13B and DH14B Degraded Seat Condition
08/29/2003
CR G201-2003-
07177
DH14A and DH13A Disc Pin Staking
09/01/2003
CR G201-2003-
07177
DH14A and DH13A Disc Pin Staking
09/01/2003
CR G201-2003-
07455
LPI Train 1 Flow Does not Meet LOCA Requirements
09/08/2003
CR G201-2003-
08626
DH14A Valve Seat is Damaged
10/09/2003
CR G201-2003-
10165
CAP/SA Deficiencies in the Generic Implications Evaluation
for CR 2003-7049
11/26/2003
CR-G201-2002-
07065
F890 has Inaccurate Indication for Service Water Flow to
Collection Box
10/01/2002
CR-G201-2003-
07698
Operability Evaluation 03-07177 Comments
09/12/2003
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
FIG. 7.4-1
CRDM Reactor Trip and Power Supply Configuration
Figure 7.2-1
Reactor Protection System M-536-1
M-041B
Primary Service Water System
Engineering
Changes
19-0069-001
Install Blind Flange at SW38
Miscellaneous
45554743
Quality Control Purchase Order Closeout Checklist
Instruction
Manual
Type 9100 Butterfly Control Valve Body
2/1972
LER 2005-002-00
Missing Taper Pins on CCW Valve Cause Technical
Specification Required Shutdown
04/12/2005
M-215-0095
Instruction Manual 9100 Series Butterfly Control Valve
Bodies
04/30/2007
Quality Control
Receiving
Inspection Report
Valve-Butterfly
1/11/2017
TRM 8.3.1
Reactor Protection System Instrumentation Parameters
Procedures
DB-ME-03020
Reactor Trip Breaker Response Time Test
DB-MI-09024
Installation and Removal of Foxboro I/A Series Differential
Pressure Transducers
DB-MM-09097
Limitorque Manual Actuator Maintenance
DB-MM-09266
Torquing
DB-MM-09317
Fisher Type 9100 Butterfly Control Valve Maintenance
3, 4
DB-MM-09330
Installation of Stud Type Expansion Anchors
DB-MS-09253
Application of Protective Coatings Outside Containment
DB-SC-03077
Emergency Diesel Generator 2 184 Day Test
NA-QC-01191
Liquid Penetrant Examination
NOBP-LP-2100
Operating Experience Process
NOP-CC-1003
Vendor Technical Information
NOP-ER-3900
Equipment Reliability Common Definitions and Structure
NOP-LP-2020
Quality Control Receipt Inspection
18, 20
NOP-LP-2601
Procedure/Work Instruction Use and Adherence
NOP-WM-4006
Conduct of Maintenance
Work Orders
200777472
CCW Heat Exchanger 2 Outlet Isolation
08/26/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR 2019-06415
CREATCS Train 2 Compressor Replacement Under Order
200582815 was not Identified as Yellow Nuclear Safety and
Generation Risk
07/30/2019
CR 2019-06472
Failure to Initiate an ICES Report for CR 2019-05091
07/31/2019
CR 2019-06496
Unsat Electrical Terminations Found in S33-2
08/01/2019
Drawings
M-041B
Primary Service Water System
Engineering
Changes
19-0069-001
Install Blind Flange at SW38
Miscellaneous
LER 2005-002-00
Missing Taper Pins on CCW Valve Cause Technical
Specification Required Shutdown
04/12/2005
M-215-0095
Instruction Manual 9100 Series Butterfly Control Valve
Bodies
04/30/2007
P 42 - 1,2; MP 42
- 1,2
Lubrication Data Sheet, Decay Heat Pumps and Motors
07/23/2019
Procedures
DB-MI-09024
Installation and Removal of Foxboro I/A Series Differential
Pressure Transducers
DB-MM-01009
Lubricant Sampling Methods
DB-MM-09097
Limitorque Manual Actuator Maintenance
DB-MM-09266
Torquing
DB-MM-09317
Fisher Type 9100 Butterfly Control Valve Maintenance
3, 4
DB-MM-09330
Installation of Stud Type Expansion Anchors
DB-MS-09253
Application of Protective Coatings Outside Containment
NA-QC-00191
Liquid Penetrant Examination
NOP-OP-1007
Risk Management
Work Orders
200777472
CCW Heat Exchanger 2 Outlet Isolation
08/26/2019
Corrective Action
Documents
CR 2019-06097
CV5000A, EVS Fan 1 Discharge Damper not Operating
Properly
07/19/2019
CR 2019-06314
CF 1544 Leaking By
07/26/2019
CR 2019-06322
ROCA Zone 95 Damaged Detection Wire
07/27/2019
CR 2019-06613
EVS Train 1 Past Operability
08/06/2019
Work Orders
200715407
EVS Train 1 Monthly Test
04/27/2019
Corrective Action
Documents
CR 2019-05707
C30205 SBODG Ground Meter Low mAMPs
07/03/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
C-ICE-058.01-
008
RPS Reactor Power Related Field Trip Sepoints
Corrective Action
Documents
CR 2017-10465
Recent Hope Creek EDG OE: Failure of New Dynalco Speed
Switch
10/16/2017
CR 2017-10873
CFR Part 21 Notice from Engine Systems Inc. for EDG
Speed Switch
10/30/2017
CR 2019-05707
C30205 SBODG Ground Meter Low mAMPs
07/03/2019
CR 2019-05883
RPS Channel 1 Trip on Flux/Delta Flux/Flow
07/11/2019
Drawings
M-041B
Primary Service Water System
OS-033F
Containment Vessel Isolation and Vacuum Relief Systems
Engineering
Changes
19-0069-001
Install Blind Flange at SW38
Miscellaneous
LER 2005-002-00
Missing Taper Pins on CCW Valve Cause Technical
Specification Required Shutdown
04/12/2005
Letter to NRC
from Engine
Systems, Inc.
10CFR21 Reporting of Defects and Non-Compliance -
Engine Systems, Inc. Report No. 10CFR21-0118, Rev. 0
10/26/2017
M-215-0095
Instruction Manual 9100 Series Butterfly Control Valve
Bodies
04/30/2007
Procedures
DB-ME-03020
Reactor Trip Breaker Response Time Test
DB-MI-03057
RPS Channel 1 Calibration of Overpower,
Power/Imbalance/Flow, and Power/Pumps Trip Functions
DB-MI-09024
Installation and Removal of Foxboro I/A Series Differential
Pressure Transducers
DB-MM-09097
Limitorque Manual Actuator Maintenance
DB-MM-09266
Torquing
DB-MM-09317
Fisher Type 9100 Butterfly Control Valve Maintenance
3, 4
DB-MM-09330
Installation of Stud Type Expansion Anchors
DB-MS-09253
Application of Protective Coatings Outside Containment
DB-PF-03272
Post Maintenance Valve Test
DB-PF-09301
Preventive Maintenance for Type SMB and SB Limitorque
Operators
DB-PF-09307
Operation of Motor Monitoring Equipment
NA-QC-00191
Liquid Penetrant Examination
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
200607286
PM 7919 - Replace RPS Channel 3 Power Supplies
200637629
PM 0747 MV2001 Inspect RPS/SFSAS 2
07/22/2019
200707506
PM 7369 C4606 Swap Breaker
200724974
RPS Channel 1 Calibration of Overpower,
Power/Imbalance/Flow and Power/Pumps Trip Functions
07/12/2019
200777472
CCW Heat Exchanger 2 Outlet Isolation
08/26/2019
Corrective Action
Documents
CR 2019-00296
MFPT 2 Failed to Trip in Response to a Manual Trip Initiated
from the Control Room
01/12/2019
CR 2019-05397
Failed MFPT 1 HP Stop Valve Test
06/23/2019
CR 2019-07441
ARTS Failed to Receive Trip Input from MFPT #2 Following
09/08/2019
CR 2019-07832
MFPT #2 Trip Relay Valve As-Found Condition
09/24/2019
Miscellaneous
Outage Control Center Shift Turnover Report
09/08/2019
Outage Control Center Shift Turnover Report
09/09/2019
Automatic Reactor Trip During Main Turbine Valve Testing
09/07/2019
Corrective Action
Documents
CR 2019-07705
Water was Flowed from the EFWST to OTSG1 While
Running the EFW Pump to Recirc Engine Coolant
09/18/2019
CR 2019-07722
EFWP Recirculation Line Flow not Within Desired Band
09/19/2019
Drawings
E-18 SH 1
SFRCS Logic Diagram Logic Channels 1 and 3 and
Actuation Channel 1
OS-062 SH1
SF-003E SH 1
Power Distribution Logic Cabinet
SF-003E SH 2
SFRCS Power Distribution Relay Cabinet
SF-006A SH 1
SFRCS Logic Module Logic Channel 1
Procedures
DB-MI-03211
Channel Functional Test of SFRCS Actuation Channel 1
Logic For Mode 1
DB-SS-04201
Emergency Feedwater Pump Quarterly Test
Work Orders
200725747
MI3211-001 08.000 SFRCS ACH1 Functional SFRCS ACH
Logic Functional FA Normal
07/22/2019
Corrective Action
Documents
CR-2019-02900
Liquid Scintillation Detector (LI.0.11.32) Daily QC Source
Check Adverse Trend
03/28/2019
CR-2019-04592
Series 28 Dosimeter Calibrator Fails Standardization
05/22/2019
Corrective Action
CR-2019-07027
Mobile Shielded Particulate Iodine Samplers for Station Vent
08/21/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Accident Range Monitors are Currently Bolted Down to
Structure
Miscellaneous
Offsite Dose Calculation Manual
Davis-Besse Nuclear Power Station Meteorological and
Atmospheric Dispersion Report
11/06/2017
Combined Annual Radiological Environmental Operating
Report and Radiological Effluent Release Report for the
Davis-Besse Nuclear Power Station - 2017
05/10/2018
Combined Annual Radiological Environmental Operating
Report and Radiological Effluent Release Report for the
Davis-Besse Nuclear Power Station - 2018
05/14/2019
DB-CN-04060
2017 Effluent MDAs
DB-CN-04060
2018 Effluent MDAs
Procedures
DB-CN-04060
A Priori Minimum Detectable Activity for HPGe Gamma
Spectrometers
DB-HP-10000
Radiation Monitor Setpoint Control
NOP-OP-3202
FENOC Radiochemistry Quality Control Program
Self-Assessments MS-C-18-08-02
Multi-Site Chemistry and Environmental Fleet Oversight
Report
10/12/2018
Work Orders
200683191
CN3001-001 04.000 Liquid/Gaseous Radioactive Release
Dose Commitment
03/18/2018
200685288
CN3001-001 04.000 Liquid/Gaseous Radioactive Release
Dose Commitment
04/20/2018
200731127
CN3011-002 04.200 Station Vent Quarterly Radiolgical
Monitoring Analysis
08/22/2019
200731130
CN3011-002 04.200 Liquid Quarterly Radiolgical Monitoring
Analysis
08/22/2019
200731635
CN3001-001 04.000 Liquid/Gaseous Radioactive Release
Dose Commitment
07/25/2019
200765692
Station Vent Releases, Weekly Radiological Monitoring
Sampling and Analysis
08/20/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
200765692
Station Vent Releases, Weekly Radiological Monitoring
Sampling and Analysis
08/20/2019
200765739
Station Vent Releases, Weekly Radiological Monitoring
Sampling and Analysis
06/04/2019
Corrective Action
Documents
CR-2018-06245
REMP Air Monitor at Location T-11 Timer Discrepancy
07/12/2018
CR-2019-01163
REMP Air Monitor Failure Trend
2/07/2019
Corrective Action
Documents
Resulting from
Inspection
CR-2019-07022
2019 NRC REMP Inspection
08/21/2019
CR-2019-07038
Nuclear Regulatory Commission Observation Concern of
Meteorologic Tower Equipment Obsolescence
08/22/2019
Miscellaneous
CFR 50.75(g)
Contaminated Soil History at Davis Besse Nuclear Power
Plant Pursuant to 10 CFR 50.75(g)
08/17/2019
Annual REMP
Report
2018 Annual Radiological Environmental Operating Report
05/15/2019
Procedures
DB-CN-03023
Annual Land Use Census
DB-MI-04060
Met Towers Calibrations
NOBP-OP-2012
System/Work Practice Prioritization for NEI 07-07; Buried
Piping Integrity Program
71151
Miscellaneous
Selected Unit Log Entries - July 1, 2018 through
June 30, 2019
Mitigating System Performance Index Basis Document
NOBP-LP-4012-
Reactor Coolant System Specific Activity
11/4/2018
though
07/01/2019
NOBP-LP-4012-
RETS/ODCM Radiological Effluent Occurrence
11/04/2018
through
07/01/2019
Corrective Action
Documents
CR 2019-00691
Missing Weld Location on Drawing M-0246B
01/23/2019
CR 2019-03884
NRC 1Q2019 - Minor Violation of 10 CFR 50 App B Criterion
III, Design Control
04/26/2019
CR 2019-04156
Nitrogen Supply Piping Drawing Dispcrepancies
05/06/2019
CR 2019-06190
Unlabeled Support Near CD162 Discovered
08/22/2019
CR 2019-06635
Clearance Level 4 due to Drawing Dependency
09/06/2019
CR 2019-06788
Replacement Valve for CD5367 will not Fit
07/22/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2019-06832
Incorrect Quality Classification in SAP for PCV2398
08/14/2019
Miscellaneous
DUN Status
August 2019
Monthly - New as-Built-vs-Incorporated DUN's for 2019
09/03/2019
Procedures
DBBP-DBDE-
0004
Design Engineering Human Performance Practices
NOP-CC-1002
Drawing Control
NOP-CC-2003
Engineering Changes
Corrective Action
Documents
CR 2019-00296
MFPT 2 Failed to Trip in Response to a Manual Trip Initiated
from the Control Room
01/12/2019
CR 2019-05397
Failed MPFT 1 HP Stop Valve Test
06/23/2019
CR 2019-07441
ARTS Failed to Receive Trip Input from MFPT #2 Following
09/08/2019
CR 2019-07832
MFPT #2 Trip Relay Valve As-Found Condition
09/24/2019
Miscellaneous
Outage Control Center Shift Turnover Report
09/08/2019
Outage Control Center Shift Turnover Report
09/09/2019
Automatic Reactor Trip During Main Turbine Valve Testing
09/07/2019
LER 2018-001-00
Borated Water Storage Tank Level Transmitter Out of
Tolerance Due to Reaching End of Expected Life
2/14/2019