IR 05000346/2020010
| ML21021A018 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  (NPF-003) |
| Issue date: | 01/21/2021 |
| From: | Jim Beardsley Engineering Branch 3 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2020010 | |
| Download: ML21021A018 (11) | |
Text
January 21, 2021
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - TRIENNIAL INSPECTION OF EVALUATION OF CHANGES, TESTS AND EXPERIMENTS BASELINE INSPECTION REPORT 05000346/2020010
Dear Mr. Brown:
On December 23, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station and discussed the results of this inspection with Mr. G. Michael, Site Engineering Director 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; and was determined to be Severity Level IV. 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, James D. Beardsley, Acting Chief Engineering Branch 3 Division of Reactor Safety
Docket No. 05000346 License No. NPF-3
Enclosure:
As stated
Inspection Report
Docket Number:
05000346
License Number:
Report Number:
Enterprise Identifier: I-2020-010-0049
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Davis-Besse Nuclear Power Station
Location:
Oak Harbor, OH
Inspection Dates:
November 16, 2020 to November 20, 2020
Inspectors:
B. Daley, Senior Reactor Inspector
I. Hafeez, Reactor Inspector
A. Shaikh, Senior Reactor Inspector
Approved By:
James D. Beardsley, Acting Chief
Engineering Branch 3
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial inspection of evaluation of changes, tests and experiments baseline 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 Perform a 50.59 Evaluation for a Change to a TRM Surveillance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000346/2020010-01 Open/Closed
[H.7] -
Documentation 71111.17T The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.59, "Changes,
Tests, and Experiments," and an associated finding of very low safety significance (Green) for failing to perform a safety evaluation in accordance with 10 CFR 50.59 before making changes to the Technical Requirements Manual (TRM). Specifically, the licensee changed surveillance tasks associated with TRM TVR 8.8.1.2 without performing a safety evaluation to evaluate the adverse effects.
Additional Tracking Items
None.
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, 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 (COVID-19), regional inspectors were directed to begin telework. During this time regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. In some cases, portions of an IP were completed remotely and on-site. The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.
REACTOR SAFETY
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from November 16, 2020 to November 20, 2020.
(1)50-59 Evaluation 18-02371, Component Cooling Water System Procedure
- (2) RAD 09-03188, New Design Deutsch AC Relays
- (3) Screen 19-00689, Install Voltage Dropping Resistor for Relay Coil FIS1476
- (4) Screen 19-00719, Test Method for Setting SW38 Position
- (5) Screen 19-092, Technical Requirements Manual, TVR 8.8.1.2, Change Notice 19-092
- (6) Screen 19-01880, A and B Bus Static Synchronism Check Relay (25-1/A & 25-1/B)
Replacements (7)50.59 Evaluation 18-02753, UFSAR Section 18, "Managing the Effects of Component Aging" Changes Necessary Following Commencement of the Period of Extended Operation
- (8) Screen 20-01191, Specification A-024N Revision 11 Change Notice
- (9) Screen 20-01001, Door 494 Core Bore
- (10) Screen 20-00873, Seasonal Plant Preparations
- (11) Screen 20-00749, Pipe Stress Analysis Report
- (12) Screen 20-00627, Pipe Stress Analysis Report
- (13) Screen 18-01213, Emergency Diesel Generator Day Tank Level
- (14) Screen 18-02027, Specification for Field Coating Outside Containment
- (15) Screen 18-02341, Structures Monitoring
- (16) Screen 19-00929, Service Water System Operating Procedure
- (17) Evaluation 11-04731, Shield Building Core Bores
- (18) Evaluation 18-02417, Control Rod Survivability Analysis During a LOCA (19)50.59 Evaluation 19,02195, Extension of Steam Turbine Valve Test Intervals
- (21) RAD 20-01229, Containment Leakage Rate Testing Program and ISTB4 Updates for Addition of MU60D
- (22) Screen 19-00641, POD/Compensatory Measure for Results of Ultimate Heat Sink Bathymetric Survey
- (23) Screen 19-00780, Diesel Generator Operating Procedure
- (24) Screen 19-02078, Replace BE1116 with 15 Amp Circuit Breaker
INSPECTION RESULTS
Failure to Perform a 50.59 Evaluation for a Change to a TRM Surveillance Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems
Green Severity Level IV NCV 05000346/2020010-01 Open/Closed
[H.7] -
Documentation 71111.17T The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.59, "Changes, Tests, and Experiments," and an associated finding of very low safety significance (Green) for failing to perform a safety evaluation in accordance with 10 CFR 50.59 before making changes to the Technical Requirements Manual (TRM). Specifically, the licensee changed surveillance tasks associated with TRM TVR 8.8.1.2 without performing a safety evaluation to evaluate the adverse effects.
Description:
During implementation of the Improved Technical Specifications (ITS) at Davis-Besse Nuclear Station, certain requirements that were originally a part of the Current Technical Specifications (CTS) were removed from the Technical Specifications and relocated to the TRM. The TRM was incorporated by reference into the UFSAR and were subject to the controls of 10 CFR 50.59.
On August 26, 2019, the licensee changed TRM surveillance requirement TVR 8.8.1.2. The surveillance requirement originally stated, "For each EDG, perform inspections in accordance with procedures prepared in conjunction with its manufacturer's recommendations." The new wording for TVR 8.8.1.2 was changed through Change Notice (CN)19-092 to state, "For each EDG, perform inspections in accordance with procedures prepared in conjunction with its manufacturer's recommendations or industry practices." The licensee screened this issue out in Screen 19-01414 as not requiring a safety evaluation; therefore, no evaluation under 10 CFR 50.59 was performed.
This change allowed the licensee to use industry best practices instead of the manufacturer's recommendations. By changing the TRM to allow using the industry best practices, the licensee changed many of the maintenance and inspection tasks that were previously required by the TRM. This change allowed the licensee to no longer perform a number of the original manufacturer's recommended tasks, and it allowed a number of other tasks to be performed less frequently per the UFSAR (by reference). The inspectors determined that this change resulted in a number of adverse effects. For example, electrical panel thermography was removed from the tasks performed. This type of change could lessen the probability of detection of problems in a panel. In addition, decreasing the frequency of tasks could also increase the probability of failure by reducing the probability of detection of potential issues associated with the EDG. While the overall change associated with these tasks presented by the use of the industry best practices may ultimately, in their entirety, be allowable after a thorough safety evaluation is performed, the inspectors could not determine this result from the screen evaluation that was performed. Additionally, the inspectors determined that because the change had adverse effects associated with it (along with positive effects), a safety evaluation should have been performed to focus on these adverse effects to determine whether a license amendment was required.
Corrective Actions: The licensee will address this issue in their 50.59 process and will evaluate adverse changes in a safety evaluation.
Corrective Action References: CR 2020-09651
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to perform a safety evaluation for the change to TRM TVR 8.8.1.2 was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency. Specifically, the changes involved the deletion of tasks and the extension of manufacturer surveillance frequencies that had adverse effects for detecting potential failure mechanisms in the EDGs. Additionally, the finding met the criteria for a Level IV violation, because the violation was similar to the example in Section 6.1.d.2 of the NRCs Enforcement Policy.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This violation is associated with a finding that has been evaluated by the SDP and communicated with an SDP color reflective of the safety impact of the deficient licensee performance. The SDP, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding.
In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process." Using attachment 0609.04, Table 2 the inspectors determined that the finding affected the Mitigating Systems Cornerstone. As a result, the inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, for the Mitigating Systems Cornerstone. The finding was determined to be of very low safety significance (Green) because the performance deficiency did not affect the Operability of the EDGs.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. Specifically, the licensee failed to document and evaluate their rationale for why the TRM change did not require prior NRC approval.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was a Severity Level IV violation and was entered into the licensees corrective action program as CR 2020-09651.
Violation: Title 10 CFR Part 50.59, Changes, Tests, and Experiments, section (d)(1)requires the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant 10 CFR 50.59(c). These records must include a written evaluation which provides a basis for the determination that the change, test, or experiment does not require a license amendment.
Contrary to the above, the licensee failed to perform a written evaluation of changes made to TRM TVR 8.8.1.2. Specifically, the licensee did not evaluate these changes, which involved changing the TRM surveillance such that maintenance tasks and inspections originally a part of TRM TVR 8.8.1.2 were no longer required or were performed at a lessened frequency.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 23, 2020, the inspectors presented the Exit Meeting inspection results to Mr. G. Michael, Site Engineering Director and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.17T Calculations
BE1116 and OLH
Plot
Coordination Curves and Plot
C-NSA-011.01-
27
Test Method for Setting SW38 Position
Corrective Action
Documents
2019-09005
50.59 RAD/Screen 19-00929 Did Not Include Sufficient
Information in Conclusion
10/28/2019
CR 2018-04884
CV 5075 Failed to Stroke Closed
05/26/2018
CR 2020-09651
Screen 19-01414 Did Not Contain Sufficient Justification on
Why the Change to the TRM Was Not Adverse
2/23/2020
CR-2018-05955
UFSAR Description of CREVS and CREATCS Does Not
Match Technical Specifications
06/29/2018
Drawings
E49B SH50A
Elementary Wiring Diagrams Treated Water RC Let Down
CLRS in VLV
Engineering
Changes
18-01213
Emergency Diesel Generator Day Tank Level
18-02027
SPECIFICATION FOR FIELD COATING OUTSIDE
CONTAINMENT
18-02341
Structures Monitoring
19-0078-001
Install Voltage Dropping Resistor for Relay Coil FIS1476
19-00929
Service Water System Operating Procedure
19-0192-001
Replacement of Static Synchronism Check Relay for A Bus
19-0193-001
Replacement of Static Synchronism Check Relay for B Bus
20-00627
Pipe Stress Analysis Report
20-00749
Pipe Stress Analysis Report
20-00873
Seasonal Plant Preparations
20-01001
Door 494 Core Bore
20-01191
Specification A-024N, Revision 11 Change Notice 01
E-60B SH.29A
Elementary Wiring Diagram STA HTG VENTL & CLNG SYS
CCW PMP RM Vent Fan 1-1 (C75-1)
Engineering
Evaluations
11-04731
Shield Building Core Bores
18-02417
Control Rod Survivability Analysis During a LOCA
Miscellaneous
CN 19-135
Extension of Steam Turbine Valve Test Intervals
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PCN T-0479
Change to Containment Leakage Rate Testing Program and
ISTB4
09/09/2020
PERP 0178
New Design Deutsch AC Relays (4A-x-1603)
VENDOR
MANUAL
NUMBER E-005-
00169
General Electric Instructions for Static Synchronism Check
Relay Types SLJ12A AND 12SLJ21A
Operability
Evaluations
POD CR-2019-
2869
Ultimate Heat Sink Low Water Condition
Procedures
DB-OP-06262
Component Cooling Water System Procedure
DB-OP-06316
Diesel Generator Operating Procedure
DB-SC-04072
Emergency Diesel Generator 1 Maintenance Verification
DB-SP-04400
Spent Fuel Pool, Fuel Transfer Pit and Cask Pit Leak
Detection System Test
NOP-CC-2003
Engineering Changes
NOP-LP-4003
Evaluation of Changes, Tests, and Experiments
8