IR 05000346/2020004

Integrated Inspection Report 05000346/2020004

ML21043A444
Person / Time
Site:	Davis Besse
Issue date:	02/12/2021
From:	Billy Dickson Division Reactor Projects III
To:	Tony Brown Energy Harbor Nuclear Corp
References
IR 2020004
Download: ML21043A444 (27)

Text

February 12, 2021

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2020004

Dear Mr. Brown:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On January 28, 2021, 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 the 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 Nuclear Power Station.

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 Nuclear Power Station. 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 Title 10 of the Code of Federal Regulations 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:

NPF-3

Report Number:

05000346/2020004

Licensee:

Energy Harbor Nuclear Corporation

Facility:

Davis-Besse Nuclear Power Station

Location:

Oak Harbor, OH

Inspection Dates:

October 1, 2020 to December 31, 2020

Inspectors:

S. Bell, Health Physicist

J. Cassidy, Senior Health Physicist

M. Garza, Emergency Preparedness Inspector

J. Harvey, Resident Inspector

D. Mills, Senior Resident Inspector

J. Neurauter, Senior Reactor Inspector

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 Maintain the Effectiveness of the Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000346/2020004-01 Open/Closed

[H.11] -

Challenge the Unknown 71114.04 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.54(q)(2) for the licensees failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, on August 11, 2020, the Davis-Besse Nuclear Power Station experienced a phone outage that affected the licensees ability to receive calls from offsite. Since they could not receive calls and an alternate notification method was not available, they could not receive notifications per Emergency Action Level (EAL) HA 1.2. During the communications outage, the licensee did not maintain the emergency plan due to EAL HA 1.2 being rendered ineffective. The licensee did not establish compensatory actions until after inquiry from the Senior Resident Inspector.

The licensees corrective actions included:

• establishing compensatory measures

• updating their procedures to incorporate these actions

• entering this issue into their CAP as CR 2020-06343

Additional Tracking Items

None.

PLANT STATUS

The plant operated at or near rated thermal power for the entire inspection period.

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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of winter for the following systems:

• Borated water storage tank

• Emergency feedwater system

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 5, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Core spray train 2 during the week ending December 19, 2020

(2) High pressure injection train 2 after planned testing during the week ending December 26, 2020

Complete Walkdown Sample (IP Section 03.02) (2 Samples)

(1) The inspectors evaluated system configurations during a complete walkdown of the emergency feedwater system during the week ending January 2, 2021.

(2) The inspectors evaluated system configurations during a complete walkdown of the emergency diesel generator system during the week ending December 19, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Mechanical penetration room 1 (room 208), fire area AB, during the week ending November 7, 2020

(2) Control room and control room support rooms (rooms 502-513), fire area FF, during the week ending December 12, 2020

(3) Service water pump room (room 52), fire area BF, during the week ending December 19, 2020

(4) Emergency core cooling system pump room 2 (room 115), fire area A-04, during the week ending December 19, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Emergency core cooling system pump room 2 (room 115)

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification program biennial written examination and annual operating test administered between October 19 and December 11, 2020.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Partial)

(1)

(Partial)

Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on 12/4/2020.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test

Due to the COVID-19 PHE, the inspectors could not by direct observation, evaluate the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives. Specifically, the inspectors did not observe the administration of simulator scenarios and JPMs during the conduct of an annual requalification operating test required by 10 CFR 55.59(a)(2).

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution

The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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 power changes, turbine valve testing, and control rod drive exercise during the week ending December 12, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator license requalification simulator scenarios on December 9, 2020 and December 10, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Repeat failure of containment air cooler 2 service water outlet, SW1357 during the week ending September 5, 2020

(2) Borated water storage tank level transmitter replacement due to water intrusion during the week ending June 27, 2020

(3) Programmatic review of the periodic maintenance effectiveness assessment report for May 9, 2018, to March 3, 2020

(4) Emergency diesel generator 1 scheduled 2-year preventive maintenance during the week ending November 14, 2020

(5) Low pressure injection/decay heat pump 2 bearing replacement and constant level oiler installation during the week ending October 31, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR 2020-05932: Incorrect comparison of borated water storage tank concentration to upper technical specification limit

(2) CR 2020-04688: Reactor coolant pump 2-2 seal return flow high

(3) CR 2020-09055: Storm damage to shield building scaffold

(4) CR 2020-05473: AF6451 close mVdc does not meet the minimum value specified in test procedure during minimal time period of power being applied

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Emergency feedwater testing following installation of automatic start function during the week ending November 21, 2020

(2) Component cooling water pump 1 following overhaul during the week ending October 31, 2020

(3) Emergency diesel generator 1 following planned maintenance during the week ending November 14, 2020

(4) Low pressure injection/decay heat pump 1 following planned maintenance during the week ending December 12, 2020

(5) Emergency core cooling system room cooler 4 following planned maintenance during the week ending December 12, 2020

(6) Auxiliary feedwater pump 1 following planned maintenance during the week ending September 12, 2020

(7) Low pressure injection/decay heat pump 2 following bearing replacement and constant level oiler installation during the week ending October 31, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Emergency diesel generator 1 184-day run during the week ending November 28, 2020

Inservice Testing (IP Section 03.01) (3 Samples)

(1) Emergency core cooling system train 1 quarterly valve testing during the week ending December 5, 2020

(2) Turbine valve testing during the week ending December 12, 2020

(3) Control rod drive exercise during the week ending December 12, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Emergency feedwater pump quarterly testing during the week ending November 28, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 31, 2020. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Integrated emergency preparedness/emergency response drill held on October 6,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) Shepherd Model 89 calibrator repair under RWP 120-1048. This work involved high activity sources and significant dose gradients.

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (11 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) MG Telepole, SN 2.7.338, calibrated on March 22, 2020

(2) Fluke 451B, SN 2.7.526, calibrated on April 3, 2020

(3) Canberra Cronos-4, SN 2.12.99, calibrated on November 4, 2019

(4) Tennelec S5XLB, SN 2.12.56, calibrated on November 17, 2019

(5) MG AMP 100, SN 2.7.501, calibrated September 9, 2020

(6) Eberline AMS-4, SN 2.8.183, calibrated on August 3, 2020

(7) Apex High Purity Germanium Gamma Spectroscopy Detector, SN 3, calibrated on September 11, 2019

(8) Ludlum Model 12, SN 2.7.667, calibrated on August 19, 2020

(9) Canberra Fastscan Whole Body Counter, calibrated on August 8, 2019

(10) Ludlum Model L177, SN 2.7.541, calibrated on April 23, 2020

(11) Hi Range Containment Radiation Monitor, RE4596B, calibrated on March 24, 2020

Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Radioactive Liquid Discharge Monitor, RE1770A

(2) Radioactive Gaseous Vent Stack Discharge Monitor, RE4598BA

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS09: Residual Heat Removal Systems (IP Section 02.08)===

(1) July 1, 2019 through September 30, 2020

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) October 1, 2019 through September 30, 2020

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) July 1, 2019 through June 30, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) October 1, 2019 through September 30, 2020

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) January 1, 2019 through September 30, 2020

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) July 1, 2019 through June 30, 2020

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 in communications systems that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1)2020 Inspection campaign as part of long-term monitoring for the shield building laminar cracking condition, EN-DP-01511

(2) Licensee effectiveness in maintaining minimum staffing levels

(3) Unintended power change during feedwater flow transmitter calibration

INSPECTION RESULTS

Failure to Maintain the Effectiveness of the Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness

Green NCV 05000346/2020004-01 Open/Closed

[H.11] -

Challenge the Unknown 71114.04 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.54(q)(2) for the licensees failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, on August 11, 2020, the Davis-Besse Nuclear Power Station experienced a phone outage that affected the licensees ability to receive calls from offsite. Since they could not receive calls and an alternate notification method was not available, they could not receive notifications per Emergency Action Level (EAL) HA 1.2. During the communications outage, the licensee did not maintain the emergency plan due to EAL HA 1.2 being rendered ineffective. The licensee did not establish compensatory actions until after inquiry from the Senior Resident Inspector.

The licensees corrective actions included:

• establishing compensatory measures

• updating their procedures to incorporate these actions

• entering this issue into their CAP as CR 2020-06343

Description:

On August 11, 2020, security staff at the Davis-Besse Nuclear Power Station discovered that offsite phone calls were not being received to onsite phone lines, including the NRC and Emergency Notification System phone lines. The unexpected outage began at approximately 1315 EDT and affected the inbound calling capability of all hardwired phones onsite. The outbound calling ability was not affected. The shift manager contacted the senior resident inspector (SRI) as a courtesy notification regarding the outage and provided a personal cell phone number. Upon receipt of the call, the SRI inquired about compensatory actions to allow the station to receive notifications from offsite entities, including the NRC Operations Center. The SRI noted that cell phone reception is deficient in the control room, making it an unreliable communication method for receiving notifications. Following this discussion, the licensee established compensatory measures to allow offsite communications with control room operators. The licensee informed the NRC Operations Center of the compensatory measures.

Corrective Actions: The licensee entered this issue into their corrective action program. The corrective actions included a revision to plant procedures governing equipment important to EP, and include appropriate compensatory actions in the event of a loss of phone lines.

Corrective Action References: CR-2020-06343; Site Phones Experiencing Issues Receiving Outside Calls

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee failed to maintain the effectiveness of the Davis-Besse emergency plan due to an ineffective EAL because plant operators were unable to receive timely notifications from offsite entities including the NRC Operations Center. The inspectors also determined that this was a performance deficiency within the licensees ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. In this case the licensee may not have received a notification of a hostile threat with enough time to implement the required procedures and declare an Alert prior to the event. Inspection manual chapter 0612 Appendix E example 4.i is similar to this issue.

Significance: The inspectors assessed the significance of the finding using Manual chapter 0609 Appendix B, Emergency Preparedness Significance Determination Process.

Appendix B table 5.4-1 and figure 5.4-1 provide significance determination examples for an ineffective EAL. Since the licensee would not have received notifications and thus, would not have been able to be declare an Alert under HA1.2 during the time that the phone lines were out, this finding screens as GREEN.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. This finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because the licensee did not stop and assess all vulnerabilities when presented with the unexpected loss of inbound communications capabilities. Specifically, the licensee failed to fully evaluate and manage the risk presented by the inability to declare an emergency under HA1.2 and enter the proper response procedures due to the loss of inbound communications capability.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Contrary to the above, the licensee failed to maintain the effectiveness of the emergency plan. Specifically, on August 11, 2020, the licensee failed to maintain a standard emergency classification and action level scheme as the site could not receive incoming phone calls and there were no compensatory actions in place to receive notifications that would meet the initiating condition of the sites emergency action level, HA 1.2.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: 2020 Inspection Campaign as Part of Long-Term Monitoring for the Shield Building Laminar Cracking Condition 71152 As part of the continued long-term monitoring of the shield building laminar cracking condition, the licensee subjected a sample of existing shield building core bores to visual examination as prescribed by licensee procedure EN-DP-01511, "Structures Monitoring."

One purpose of the core bore visual examinations conducted under this procedure was to determine if any growth or change in the nature of the cracks had occurred by measurement of crack width and comparison to historical values. In areas of identified laminar crack planar propagation, the licensee performed additional impulse response mapping to provide a relative indication of the extent of propagation.

During this in-depth review, the inspectors verified the status of the licensee's core bore visual examinations and their evaluations and corrective actions resulting from shield building laminar cracking not identified by previous visual examinations. The inspectors reviewed the licensee's plans for follow-on examinations and corrective actions that they had established to verify that the classification, prioritization, focus, and timeliness of these actions were commensurate with the safety significance of the issue.

During the 2020 periodic examination, the licensee identified additional growth in laminar crack width. In some instances, the measured laminar crack width exceeded the crack widths induced during testing previously performed at selected universities referenced in IR 05000346/2014008 to credit full reinforcement capacity in those areas. The licensee documented measured laminar crack widths that exceeded the testing limit in the corrective action program. The licensee observed laminar crack propagation at some locations based on visual examination. The inspectors verified that the licensee determined the extent of laminar crack growth by a combination of additional impulse response mapping and confirmatory concrete cores. As a result of the increased crack widths, the licensee performed operability evaluations of the shield building and determined that the shield building remained operable because the increased crack widths were localized in nature.

The inspectors reviewed the licensee's operability determinations, engineering analyses, and assessment that the shield building remained capable of performing its intended safety functions and identified no concerns. The inspectors identified no findings.

Observation: Trend of Communication System Issues 71152 The inspectors reviewed the licensees corrective action program for potential adverse trends involving communication systems that might be indicative of a more significant safety issue.

During the review period for this inspection sample, the inspectors noted several phone system problems challenged the licensee. The inspectors determined that though these issues were identified and corrected by the licensee, several could have negatively impacted plant safety. Specific examples associated with this trend included but were not limited to:

• During the third quarter of 2020, the licensee was notified by an offsite employee that he could not reach anyone onsite by landline. The licensee identified that incoming calls could not reach any onsite phones even though they maintained the ability to call out and to call numbers onsite. Operators notified the NRC Resident Inspectors of the condition and provided personal cell phone number of an operator. The inspectors requested an alternate method of communication. The licensee provided an acceptable alternate communication method for the NRC emergency operations center to reach the unit control room in response to inspector requests. This issue is discussed in more detail in section 71114.04 of this report (ineffective EAL HA1.2).

(CR 2020-06343 - August 11, 2020)

• While performing a monthly walkdown of the Joint Information Center, the licensee discovered three phone lines and two fax lines were nonfunctional.

(CR 2020-06399 - August 13, 2020)

• The licensee discovered that five plant cell phones were not able to receive incoming phone calls. (CR 2020-08623 - November 3, 2020)

• The licensee discovered that hardwired phone lines were once again not able to receive incoming phone calls. (CR 2020-08623 - November 7, 2020)

• The licensee discovered that several security cell phones were not working.

(CR 2020-09147 - November 30, 2020)

Individually, none of these examples may suggest an ongoing problem, but the inspectors determined that they may indicate a potential weakness when viewed in the aggregate.

Specifically, for these and other issues, the station may be missing the opportunity to identify and resolve deficiencies before the failure manifests, potentially resulting in an adverse impact on the plant. The inspectors provided these observations to the licensee. The inspectors will continue monitoring the licensees actions to identify and correct similar issues.

Observation: Inspector verification of licensee minimum staffing levels 71152 The inspectors reviewed the licensee's pandemic response plan, condition reports, staffing plans, and licensee use of NRC exemption from certain portions of part 26 and part 73.

The inspectors verified that the licensee maintained sufficient staffing levels in key positions (e.g., operations, emergency response organization, security). Additionally, the inspectors evaluated for deferred maintenance and other activities, use of overtime, and the use of NRC enforcement discretion.

The inspectors also assessed licensee preparations and planning for potential staffing challenges at the facility or in the conduct of activities related to operations, emergency response organization, and security.

No issues were identified.

Observation: Unintended Power Change during Feedwater Flow Transmitter Calibration 71152 On March 29, 2020, as operators were starting up the reactor following the refueling outage, the control room received feedwater flow deviation alarms, and the operators halted the power ascension. The licensee determined that the issue was caused by the loop 1 feedwater flow instrument channel being out of calibration. The licensee commenced a calibration of the instrument channel using the approved calibration procedure. While performing the calibration, a plant transient resulted, during which the control rods automatically inserted and resulted in a 2.5 percent power reduction. The operators halted the transient by placing rod control and reactor demand hand/auto stations in hand (manual operation), and the calibration was completed. The licensee conducted an apparent cause evaluation that identified the apparent cause: the procedure failed to include steps to direct the operators to place the rod control and reactor demand hand/auto stations in hand before conducting the calibration. The licensee also identified that contributing causes included failures to identify the procedural deficiency. The licensee previously performed the procedure during plant conditions when control rod movement was not possible.

Inspectors reviewed procedures, logs, and the apparent cause evaluation. The inspectors identified no findings, but the licensee's failure to identify this issue before the performance of this work activity may indicate a weakness related to work planning and job preparation. The licensee had multiple opportunities to identify the issue during work planning, pre-job brief, and other work preparation activities. The inspectors will continue to monitor the licensee's focus on addressing work planning and work management issues.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 28, 2021, the inspectors presented the integrated inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.

• On November 4, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.

• On December 9, 2020, the inspectors presented the radiation protection inspection results to Mr. M. Sidoti, Radiation Protection Support Manager, and other members of the licensee staff.

• On December 17, 2020, the inspectors presented the Davis-Besse Biennial Licensed Operator Requalification Program Inspection Results inspection results to Mr. D. Huey, Operations Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Procedures

DB-OP-06913

Seasonal Plant Preparation Checklist

RA-EP-02870

Station Isolation

71111.04

Corrective Action

Documents

20-07572

Relay Failed as Found Testing for BF1141TD

10/29/2020

Drawings

M-017A

Diesel Generators

M-017B

Diesel Generators Air Start

M-017C

Fuel Oil

OS-003

High Pressure Injection System

Procedures

DB-OP-06011

High Pressure Injection Operating Procedure

DB-OP-06013

Containment Spray System

DB-OP-06234

Emergency Feedwater System

DB-OP-06316

Diesel Generator Operating Procedure

71111.05

Fire Plans

PFP-AB-115

ECCS Pump Room 1-2 Room 115

PFP-AB-208

No. 1 Mechanical Penetration Room and Pipe Way Area

Rooms 202, 208, and 208DC

PFP-AB-505

Control Room and Adjacent Support Rooms

PFP-IS-52

Service Water Pump Room

71111.06

Drawings

A-2111

Barrier Penetration Drawing Intake Structure

Procedures

NORM-ER-3208

Penetrations and Barriers

Work Orders

200720548

ECCS Sump 1-2 Pump B

08/25/2020

71111.11A Miscellaneous

Davis-Besse Annual Licensed Operator Requalification

Program Results Information

2/14/2020

71111.11B Corrective Action

Documents

2018-10895

Ops Training-Potential Exam Security Event, Cell Phone

2/12/2018

2019-03972

Negative Performance Trend with Respect to EAL

Classification

04/30/2019

20-02741

Unexpected Rod Insertion During FW Flow Calibration

03/29/2020

20-08032

Senior Reactor Operator May Have Not Have Met the

Minimum Watch Standing Requirements

10/16/2020

20-08446

ILT Exam Security - SCANNER

10/26/2020

ATL-2019-0015-

ATA-1 l

Effectiveness Evaluation for EAL Performance Gap

10/19/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Resulting from

Inspection

20-09464

20 NRC IP 71111.11 Issue of Concern; the Amount of

Overlap Between the 2018 and 2020 Written Exams.

2/15/2020

Miscellaneous

20 CT List

Davis-Besse Licensed Operator Critical Task List

2/03/2020

20 DB Biennial

Written Exam 1

20 Davis-Besse Biennial Written Exam 1

09/29/2020

20 DB Sample

Plan

20 Davis-Besse Examination Sample Plan and Outlines

Various

20 JPM Crew 1

20 Davis-Besse Annual Operating Test Job Performance

Measures Crew1 (001, 045, 227, 285, 308)

11/30/2020

20 JPM Crew 2

20 Davis-Besse Annual Operating Test Job Performance

Measures Crew 2 (027, 166, 120, 283, 193)

10/19/2020

20 Scn Crew 1

20 Davis-Besse Annual Operating Test Crew 1 Scenarios

(S109R14, S132R8, S137R5)

11/30/2020

20 Scn Crew 5

20 Davis-Besse Annual Operating Test Crew 5 Scenario

(S134R12)

11/09/2020

CREW

EVALUATION

ANNUAL EXAM

FORM (from

NOBP-TR-1112)

Scenarios #1 - #3: for Crew 1

2/02/2020

CYCLE 22 TAB

MANUAL REACTOR TRIP

Simulator Transient Test

11/23/2020

DB 2020 Biennial

Exam 2

LORT Biennial Written Exam Failed by an Applicant

08/27/2020

DB 2020 Biennial

Exam 3

LORT Remedial Biennial Written Exam Passed by an

Applicant

11/18/2020

DBBP-TRAN-

21 for Scenario

ORQ EPE S101

Simulator Scenario Based Testing Documentation

07/13/2020

Procedures

DBBP-OPS-1013

Control of Time Critical Actions

DBBP-TRAN-

Conduct and Development of Job Performance Measures

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

0501

NOP-TR-1010

Requal Exam Development and Administration

71111.12

Corrective Action

Documents

2017-10018

SW1357 Failed to Close During Air Drop Test due to

SV1357B Continuously Venting

10/01/2017

2018-02603

SW1357, CAC 2 Service Water Outlet, Would Not Stroke

Closed during Test

03/18/2018

20-01255

Difficulty Installing Split Ring on New Cartridge Style Seals

for the Decay Heat Pump

2/17/2020

20-01305

P42-2, Decay Heat Pump 2, Seal Leakage

2/19/2020

20-01363

BACC: Decay Heat Pump 2 Inboard Seal Package Leakage

DPM

2/21/2020

20-01382

Oil Sample on Decay Heat Pump 2 O.B. Pump Bearing

Grayish in Color

2/21/2020

20-01458

Decay Heat Pump 2 Mechanical Seal Replacement Post Job

Comments

2/25/2020

20-01909

1R21 BACC Boric Acid Build Up on 2 Decay Heat Pump

Inboard Pump Seal

03/07/2020

20-02616

Minor Oil Leakage from Decay Heat/Low Pressure Injection

Pump 2 Outboard Bearing Inside Cover

03/25/2020

20-02856

Vibration Point on Decay Heat Pump 1 is in the Alert Range

04/01/2020

20-03031

Required Actions Not Completed for HPI Pump 2 D-H

Vibrations in Alert Range from 1R21 Comprehensive Test

04/09/2020

20-05230

SFAS Channel 4 BWST Level Erratic

06/24/2020

20-06179

Suction Pressure Spike Following LPI Pump 2 Jog

08/05/2020

20-06619

SW1357 Would Not Stroke Closed

08/23/2020

20-07101

Alpha Level 3 Contamination Found Inside RCS Piping

09/11/2020

20-07724

EDG FOST 1 Internal Oxidation at Top of Tank

10/06/2020

20-07821

EDG Week Tank 1 Refill Delayed Retest and Operability

Determination

10/08/2020

20-07826

EDG 1 FOST Fuel Found with Water/Sediment Post

Maintenance

10/08/2020

20-07844

High Pressure at P12987 (1 Emergency Diesel Generator

South Air Start)

10/09/2020

20-08296

As Found Thrust on P42-2 Found Outside the Procedural

10/26/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Specifications in DB-MM-09174

20-08671

Pitting Noted n EDG 1-1 HX E10-1 Tubing

11/09/2020

20-08678

As-Found Visual Inspection for Piston Oil Piping was

Discovered Out Alignment

11/10/2020

20-08705

EDG 1 Jacket Water Hose Replacement Parts Not Correct

Size

11/11/2020

20-08740

EDG 1 Exhaust Temp Thermocouples Read Outside of

Required Value

11/11/2020

20-08742

EDG 1 Outage Critical Path Delay

11/11/2020

20-08743

EDG 1 Failed the Overspeed Trip Test

11/11/2020

20-08826

Control Room Annunciator 1-1-K EDG 2 Trouble Failed to

Alarm

11/15/2020

20-09073

Old Removed EDG 1 Speed Switch Signs of Overheating

11/25/2020

Corrective Action

Documents

Resulting from

Inspection

20-09755

Maintenance Rule Program Missed Condition Monitoring

Failure CR in Periodic Assessment Cycle 21

2/30/2020

Miscellaneous

MRPM

Maintenance Rule Program Manual

Procedures

NOBP-LP-2001

Self-Assessment and Benchmarking

NOP-ER-3004

Maintenance Rule Program

Self-Assessments ATA-2020-9407

Cycle 21 Periodic Maintenance Effectiveness Assessment

Report (PMEAR)

Cycle 21

SA-BN-2018-

1138

Cycle 20 Periodic Maintenance Effectiveness Assessment

Report (PMEAR)

Cycle 20

Work Orders

200700254

PM 8878 GK5-1 Check Slip Ring Runout

11/09/2020

200709265

Decay Heat Pump Outboard Bearing Housing Interior

Coating

10/26/2020

200755711

Replace Decay Heat Pump Seals with Cartridge Type Seals

2/16/2020

200759589

PM 10851 Engine Analysis on EDG 1

11/09/2020

200766360

PM 0723 K5-1 24-Month Check EDG 1

11/08/2020

200767926

Emergency Diesel Generator 1 Static Exercise

11/09/2020

200771879

Diesel Generator and Auxiliary

11/08/2020

200772284

EDG 1 Overspeed Trip Test

11/08/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

200772284

Emergency Diesel Generator 1 Overspeed Trip Test

11/08/2002

200784743

Recommendations from EDG 1 Engine Analysis

11/09/2020

200784759

Borated Water Storage Tank Level SFAS Channel 4 Level

TA

06/24/2020

200826241

Borated Water Storage Tank Level SFAS Channel 4 Level

TA

06/24/2020

71111.15

Corrective Action

Documents

2012-18810

DB-SP-03161 AF6451 Closed Voltage Out of Spec

2/02/2012

20-04688

RCP 2-2 Seal Return Flow High

05/31/2020

20-05473

AF6451 Close mVdc Does Not Meet the Minimum Value

Specified in Test Procedure During Minimal Time Period of

Power Being Applied

07/05/2020

20-05932

Incorrect Comparison of BWST Concentration to Upper Tech

Spec Limit

07/24/2020

20-09055

Storm Damage to Shield Building Scaffold

11/24/2020

G201-2008-

36648

Boron Concentrations Do Not Include Sample Accuracy

03/11/2008

Procedures

DBBP-OPS-0011

Protected Equipment Posting

Work Orders

200683357

Auxiliary Feedpumps and Piping

09/09/2020

200684824

Auxiliary Feedpump 1 to Steam Generator

09/09/2020

200714135

Auxiliary Feedwater Pump Turbines

09/09/2020

200765006

AFW Train 1 Valve Testing

09/09/2020

71111.19

Procedures

DB-MM-09180

Component Cooling Water Pump Maintenance

DB-PF-03572

Component Cooling Water Pump 1 Baseline Test

DB-PF-03572

Component Cooling Water Pump 1 Baseline Test

Work Orders

200683357

Motor for AFP 1 Discharge to SG 1

09/09/2020

200684824

Auxiliary Feed Pump 1-1 to SG 1-2 Stop Valve

09/09/2020

200714135

Main Steam Line 1 to AFPT 1 Isolation Valve Motor

09/09/2020

200765030

AFP 1 Quarterly Test

09/08/2020

200770852

Decay Heat Train 2 Pump and Valve Test

2/26/2020

200770857

Emergency Feedwater Pump Monthly Test

10/29/2020

200772760

Monthly PMT Order

11/18/2020

200775489

Emergency CR RM CLR FAN 4

2/03/2020

200776052

ECCS Room 105 Cooler Fan 4 Motor Refurbish

2/04/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

200837784

CCW Pump 1 Quarterly Test

11/23/2020

71111.22

Procedures

DB-SS-04201

Emergency Feedwater Pump Quarterly Test

Work Orders

200764576

MTSV Main Turbine Stop Valves Test

2/05/2020

200764577

Main Turbine Control Valve

2/05/2020

200764578

Main Turbine CIV Test

2/05/2020

200772722

EDG 2 184 Day Test

11/25/2020

200773169

CRD Exercise Test

2/05/2020

200774425

DH14B Mech Stop POS Test

11/30/2020

200840154

Quarterly PMT Test

11/18/2020

71114.04

Corrective Action

Documents

2019-08756

Need to Perform 50.54(q) Reviews on Three Procedures

That Were Revised and Made Effective Without These

Reviews

10/22/2019

20-06343

Site Phones Experiencing Issues Receiving Outside Calls

08/11/2020

Miscellaneous

DB-2019-022-01

CFR 50.54(q)(2) Analysis

11/15/2019

DB-2019-026-00

CFR 50.54(q)(3) Screen/Evaluation

10/22/2019

DBRM-EMER-

5003

Equipment Important to Emergency Response

DBRM-EMER-

5003

Equipment Important to Emergency Response

NOBP-OP-1015

Event Notification 71124.01

ALARA Plans

20-1048

Repair of Gamma Irradiator Shepherd Model 89

Radiation Work

Permits (RWPs)

20-1048

Repair and Maintenance of the Shepherd Model 89

Work Orders

200833345

Source Rod of JL Shepherd Model 89 Calibrator has

Become Detached

11/17/2020

71124.05

Calibration

Records

Canberra Fastscan Whole Body Counter Calibration

08/08/2019

DB-MI3401-001

Radioactive Liquid Discharge Monitor, RE1770A, Calibration

06/17/2019

DB-MI3408-001

Hi Range Containment Radiation Monitor, RE4596B,

Calibration

03/14/2020

DB-MI3413-001

Radioactive Gaseous Vent Stack Discharge Monitor,

RE4598BA, Calibration

05/14/2019

RE4596B

Hi Range Containment Radiation Monitor Calibration

03/24/2020

SN 2.12.56

Tennelec S5XLB Calibration

11/17/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SN 2.12.99

Canberra Cronos-4 Calibration

11/04/2019

SN 2.7.338

MG Telepole Calibration

03/22/2020

SN 2.7.501

MG AMP 100 Calibration

09/09/2020

SN 2.7.526

Fluke 451B Calibration

04/03/2020

SN 2.7.541

Ludlum Model 177 Calibration

04/23/2020

SN 2.7.667

Ludlum Model 12 Calibration

08/19/2020

SN 2.8.183

Eberline AMS-4 Calibration

08/03/2020

SN Number 3

Apex High Purity Germanium Gamma Spectroscopy

Detector Calibration

09/11/2019

Corrective Action

Documents

2018-08094

JL Shepherd Model 89 Requires Repair

10/12/2020

2019-09708

Shepherd Model 89 Gamma Irradiator Failure

11/16/2019

2019-09708

Shepherd Model 89 Gamma Irradiator Failure

11/16/2019

20-00942

Incorrect Alarm Setpoints in RE8406, Miscellaneous Waste

Evaporator Room Area Monitor

2/07/2020

20-01010

Initial Part 21 Notification from Fluke Regarding to

Compliance Gap on Nickel Seal Rings for Victoreen CTMT

High Range (Model 977) Ion Chamber Area Radiation

Monitors

2/10/2020

20-01025

Telepole 2.7.343 Taken Out of Service

2/20/2020

20-04503

JL Shepherd 89 Gamma Irradiator Failure

05/24/2020

20-05419

CFR 21 Notice of Deviation for Victoreen Model 876A-1,

P/N 3649559, Radiation Monitor

07/01/2020

20-06066

Stop Work Criteria for Shepherd was Met

07/30/2020

20-06730

Telepole 2.7.339 Failed Daily Check

08/26/2020

71151

Corrective Action

Documents

2019-10166

Elevated Dose Rates Identified in Dry Shielded Container

Drain Port

2/05/2019

Miscellaneous

Cycle 21 Chemistry Dose Equivalent Iodine Data

Undated

Cycle 22 Chemistry Dose Equivalent Iodine Data

Undated

Radiological Effluent Dose Summary Information from

07/01/2019 through 06/30/2020.

Various

71152

Corrective Action

Documents

2016-07491

Unit Load Demand Transferred to Manual Due to Feedwater

Flow Divergence

06/07/2016

2018-09568

Integrated Control System Unit Load Demand in Alarm Due

10/30/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

to Loop 2 Feedwater Flow Deviation

20-02414

Re-Evaluate Medical Screening of Ill Personnel for

Departments and Health Services

03/19/2020

20-02733

Unit Load Demand Transferred to Manual Due to Feedwater

Flow Divergence

03/29/2020

20-02741

Unexpected Rod Insertion During FW Flow Calibration

03/29/2020

20-02818

Hospital Inventories not Completed for 1st Quarter 2020 per

RA-EP-00600 due to Covid-19

03/31/2020

20-02854

Monthly JIC Walkdown/RA-EP-04010 Quarterly

Communication Test

04/01/2020

20-03386

Concern with How Range Masks are Cleaned/Disinfected

04/18/2020

20-03473

Recommendation for Hand Search PPE Requirements

04/21/2020

20-05090

Shield Building Inspection Results - Shoulders 3, 4, 5, 6, 8,

and 11

06/16/2020

20-05091

Shield Building Inspection Results - Shoulder 16

06/16/2020

20-05388

Telephone Lines Out of Service at Lindsey Emergency

Response Facility

06/30/2020

20-05400

New Alternate Davis-Besse 4-Way Phone Number Did Dot

Work

07/01/2020

20-05524

Telephone Lines Out of Service at Lindsey Emergency

Response Facility

07/07/2020

20-05546

Unsafe Mandatory Wearing of Face Masks

07/08/2020

20-05926

Knowledge and Ownership of Equipment Previously

Supported by FirstEnergy IT

07/24/2020

20-06004

Shield Building Inspection Results - Shoulder 1

07/28/2020

20-06019

Shield Building Inspection Results - Shoulder 2

07/29/2020

20-06055

Shield Building Inspection Results - Shoulder 15

07/30/2020

20-06224

First Half 2020 IPA Site Gap Identified for Equipment

Reliability

08/06/2020

20-06280

Evaluate the Effectiveness of Curtain on PSF Rooftop

08/09/2020

20-06343

Site Phones Experiencing Issues Receiving Outside Calls

08/11/2020

20-06399

Phones/Fax Lines Not Working at Joint Information Center

During Monthly Walkdown

08/13/2020

20-06481

Safety Condition Report Social Distancing Separation Not

08/17/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

being Maintained

20-06552

Covid-19 PHE Related Violation of 10 CFR 73 Appendix B,

VI.C.3.(I)(1) Subject to NRC Enforcement Guidance

Memorandum 20-002

08/20/2020

20-07727

Failure Analysis Report - 4 Control Valve Intermittently

Changes Position During Transfers of ICS SG/RX Demand

Station from Manual to Auto

10/06/2020

20-07764

EP Drill: Network and Miscellaneous Technical Issues

During 10/06/2020 ERO Drill

10/07/2020

20-07776

Post 1R21 Code Safety Valve RC13A As-Found Setpoint

Tested High

10/07/2020

20-07779

EP Drill: EOF Fax Did Not Receive Messages During

10/06/2020 Drill

10/07/2020

20-07834

Sprinkler Guard Hanging Improperly

10/08/2020

20-07840

Revised Reactor Vessel P-T Curves Limited to 43 EPY

10/09/2020

20-07851

Shield Building Inspection Results - Shoulder 13

10/09/2020

20-07929

Shield Building Inspection Results - Shoulder 14

10/13/2020

20-08032

Potential Licensed Operator Watch Standing Requirements

Not Met

10/16/2020

20-08039

Foreign Material/Obstruction Identified at the Bottom of the

West-Most Drainpipe of EDG 1 FOST (FME Unrecovered)

10/17/2020

20-08070

Post 4 Floor Degradation

10/19/2020

20-08076

Contraband Identified at Entrance

10/19/2020

20-08088

Hydrogen Orbisphere Will Not Communicate with Computer

Preventing Instrument Calibration

10/19/2020

20-08096

Received Unexpected Annunciator Alarm 5-1A CRD System

Fault

10/19/2020

20-08135

MS107A Static Test Not Performed

10/20/2020

20-08152

Security Radio Degradation

10/21/2020

20-08169

RPS Channel 2 Scaled Difference Amplifier Found Out of

Tolerance

10/21/2020

20-08211

Conduit to MS100-1 is Separated

10/23/2020

20-08215

Electrical Manhole Inspection Sump Pump Failures

10/23/2020

20-08222

Startup Transformer 01 Trouble

10/23/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20-08300

DB-FP-04035 Fire Suppression System 5-Year Test Not

Completed as Required

10/26/2020

20-08443

Emergency Plan Drills Not Conducted Due to Pandemic

10/30/2020

20-08519

Security B5b Phones Not Working as Designed

11/03/2020

20-08623

Site Phones Experiencing Issues Receiving Outside Calls

11/07/2020

20-09012

Inadequate Covid-19 prevention and Planning

11/21/2020

20-09036

Non-CDC Approved Disinfectant

11/23/2020

20-09147

CAS/SAS/SSS Cell Phone Failure Noted During

Computerized Automated Notification System Weekly Test

(CANS)

11/30/2020

Miscellaneous

Energy Harbor Pandemic Health Emergency Response Plan

Nuclear Generation Pandemic Health Emergency Response

Plan

DBRM-EMER-

1500A

Davis-Besse Emergency Action Level Basis Document

NDE Reports

Construction

Technology

Laboratories

(CTLGroup)

Project 263453

20 Shield Building Inspections

05/26/2020 -

10/09/2020

Procedures

EN-DP-01511

Structures Monitoring

Work Orders

200743529

Steam Room Work Online

05/26/2020

200743529

Shield Building Long Term Monitoring for the Laminar

Cracking Condition Under EN-DP-01511, Structures

Monitoring - 2020 Inspection Campaign

10/27/2020