IR 05000346/2021004

Integrated Inspection Report 05000346/2021004 and Exercise of Enforcement Discretion

ML22038A130
Person / Time
Site:	Davis Besse  (NPF-003)
Issue date:	02/09/2022
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Tony Brown Energy Harbor Nuclear Corp
References
EA-21-172 IR 2021004
Download: ML22038A130 (24)

Text

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2021004 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Brown:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On January 28, 2022, 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.

No findings or violations of more than minor significance were identified during this inspection.

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, 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:

05000346/2021004

Enterprise Identifier:

I-2021-004-0080

Licensee:

Energy Harbor Nuclear Corp.

Facility:

Davis-Besse Nuclear Power Station

Location:

Oak Harbor, OH

Inspection Dates:

October 01, 2021 to December 31, 2021

Inspectors:

D. Mills, Senior Resident Inspector

R. Baker, Senior Operations Engineer

S. Bell, Health Physicist

R. Cassara, Resident Inspector

J. Cassidy, Senior Health Physicist

M. Garza, Emergency Preparedness Inspector

G. Hansen, Sr. Emergency Preparedness Inspector

T. Ospino, Resident Inspector

G. Roach, Senior Operations Engineer

R. Ruiz, Project Engineer

J. Steffes, Senior Resident 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EA-21-172 Failure to Comply with 10 CFR Part 37 71124.08 Closed

PLANT STATUS

The unit began the inspection period at rated thermal power. On December 1, 2021, the unit was down powered to 50 percent to allow condenser inspection and plugging of leaking condenser tubes. The unit was returned to rated thermal power on December 7, 2021 and remained at or near rated thermal power for the remainder of the 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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

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

(1) The inspectors completed evaluations that flood protection barriers, mitigation plans, procedures, and equipment were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 31, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Containment spray train 2 during the week ending December 25, 2021

(2) Emergency diesel generator 1 during the week ending November 27, 2021

(3) Station blackout diesel generator while emergency diesel generator 2 was out of service for monthly surveillance run during the week ending December 25, 2021

(4) Emergency feedwater pump while emergency diesel generator was out of service for monthly surveillance run during the week ending December 25, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the high-pressure injection system during the week ending December 18, 2021.

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) No. 2 Mechanical penetration room, fire area A during the week ending October 16, 2021

(2) No. 1 Mechanical penetration room and pipeway area, fire area AB during the week ending October 23,2021

(3) High voltage switchgear room A and B, fire area S and Q during the week ending November 27, 2021

(4) Component cooling water heat exchanger and pump room rooms, fire area T, with component cooling water pump 1 out of service for maintenance during the week ending December 4, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during three fire drills during November 8 - 10, 2021.

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 1

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Emergency core cooling room 2 cooler during the week ending October 30, 2021

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 annual operating tests administered from October 18, 2021 through December 10, 2021.

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 reactor power escalation from 50 percent to 100 percent after condenser work on December 7, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated a simulator-based requalification examination on October 20, 2021.

(2) The inspectors observed and evaluated the NRC annual operating test examination for crew 1 on November 17-18, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 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) Service water pump 3 replacement

(2) Train 1 component cooling water pump rotor replacement

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Operation at reduced power (~50 percent) for condenser tube leak repairs during the week ending December 11, 2021

(2) Post maintenance testing of component cooling water pump 1 following rotor replacement during the week ending December 11, 2021

(3) Inspection and repairs of spent fuel pool fuel handling equipment including bridge and fuel assembly up-enders during the week ending December 18, 2021

(4) Scheduled testing of safety related D1 4160-volt bus during the week ending December 25, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

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

(1) Service water pump 3 excessive packing leak off, CR-2021-08266

(2) Emergency diesel generator 1 room ventilation recirculation damper failure, CR-2021- 07222

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Train 1 component cooling water pump rotor replacement

(2) Emergency diesel generator 1 room ventilation recirculation damper temporary repair

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

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

(1) Service water pump 3 following replacement of stuffing box bearing during the week ending October 30, 2021

(2) Service water pump 3 following shaft bearing replacement and repacking during the week ending November 27, 2021

(3) Component cooling water pump 1 following replacement of pump rotor during the week ending December 11, 2021

(4) Reactor protection system channel 2 reactor trip breaker 'A' following trip breaker replacement during the week ending December 18, 2021

(5) Decay heat / low pressure injection pump 2 following inspection and cleaning of pump borated water storage tank suction during the week ending December 25, 2021

(6) Safety features actuation system channel 2 following replacement of channel 2 borated water storage tank level sensor power supply and bistable during the week ending December 18, 2021

(7) Auxiliary feedwater pump 2 following replacement of turbine governor relays during the week ending December 18, 2021

(8) Safety features actuation system channel 1 following replacement of channel 1 containment pressure sensor power supply and bistables during the week ending December 4, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Emergency diesel generator 2 monthly surveillance run during the week ending December 25, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Turbine marine diesel FLEX generator quarterly run during the week ending November 20, 2021

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.

The licensee did not make any changes to the site's Emergency Action Level procedures or Emergency Plan during the period of this inspection (July 1, 2020 through June 30, 2021). The NRC inspectors independently reviewed the revisions of the site's Emergency Action Level procedures and Emergency Plan that were current for the inspection period to verify no changes were made.

This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Emergency preparedness integrated drill on October 5,

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:

(1) This included activities within the auxiliary, radioactive waste, and steam generator storage buildings

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

The inspectors walked down the accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) This included the components located with the auxiliary and radioactive waste buildings

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1)10 CFR Part 61 Data for Primary Resin Sampled July 16, 2020 (2)10 CFR Part 61 Data for Primary Resin Sampled June 17, 2019 (3)10 CFR Part 61 Data for Dry Active Waste Sampled December 20, 2018

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Radioactive Waste Shipment 2021-1005 of Dewatered Resin Transported in a Type A Package

(2) Radioactive Waste Shipment 2021-1001 of Dewatered Resin Transported in a Type A Package

(3) Radioactive Waste Shipment 2020-1002 of Dry Active Waste Transported in a General Design Package

(4) Radioactive Waste Shipment 2021-1003 of Dewatered Resin Transported in a Type A Package

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) April 1, 2020 through March 31, 2021

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) July 1, 2020 through June 30, 2021

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) July 1, 2020 through June 30, 2021

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) July 1, 2020 through June 30, 2021

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) October 1, 2020 through September 30, 2021

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

(1) October 1, 2020 through September 30, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) July 1, 2020 through September 30, 2021

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

(1) October 1, 2020 through September 30, 2021

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

(1) July 1, 2020 through September 30, 2021 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, 2020 through September 30, 2021

71152 - Problem Identification and Resolution (PI&R)

Semiannual Trend Review (IP Section 02.02) (2 Samples)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends related to missed surveillances that might be indicative of a more significant safety issue.

(2) The inspectors reviewed the licensees corrective action program for inconsistencies in condition reports 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) Failure of reactor coolant system boron trending to detect a diverging boron concentration trend caused by failed boron measurement equipment

(2) Service water valve 1429, component cooling water heat exchanger 3 service water outlet isolation valve failed air drop test (CR 2021-06913)

(3) Service water pump 3 rework due to bearing modification

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92709 - Licensee Strike Contingency Plans Licensee Strike Contingency Plans

(1) On November 15, 2021, at midnight, the contract extension between the International Brotherhood of Electrical Workers Local 245 and Energy Harbor expired. In preparation for a potential strike, the NRC inspectors evaluated the adequacy of the licensees contingency plan. The inspectors assessed the adequacy of the plan's post strike staffing levels, staff qualifications, safety conscious working environment, and site access in meeting operational and security requirements. No issues were identified. A new contract was agreed upon on January 14,

INSPECTION RESULTS

Enforcement Discretion Enforcement Action EA-21-172: Failure to Comply with 10 CFR Part 37 71124.08

Description:

On November 29, 2016, the licensee was issued NRC Inspection Report No.

05000346/2016403, which documented a licensee identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM)14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."

Subsequently, the inspectors re-evaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14-001.

Corrective Actions: As specified in EGM 14-001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action. Additional corrective actions are not required.

Corrective Action References: Not applicable.

Enforcement:

Violation: On November 29, 2016, a violation of 10 CFR Part 37 was documented in Davis-Besse Inspection Report No. 05000346/2016403. The inspectors determined that the previously identified violation remains.

Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."

Minor Violation 71152 Minor Violation: The inspectors performed an in-depth inspection sample of unexpected boron sample results as detailed in condition report 2021-03645. On May 4, 2021, a daily reactor coolant boron sample, which indicated 26 parts per million (ppm) less than the previous days sample, occurred. An expected change in reactor coolant system (RCS)boron concentration is 1-4 ppm daily. Further analysis determined that the May 4 sample was valid and that samples between March 27 and May 3, 2021, had discrepancies in their results of 20 to 30 ppm higher than what was indicated by other reactivity parameters. Due to the inaccurate boron measurements, the licensee invoked technical specification surveillance requirement 3.0.3 and reperformed surveillances with updated procedures and chemistry equipment. The licensee determined that boron concentration in the RCS, borated water storage tank, core flood tanks, and waste receiver tanks was within technical specification required limits. The licensee performed an apparent cause analysis, which determined that instrument error was the most attributing cause. Licensee corrective actions include revised titrator procedure documents, newly purchased instrumentation, and improved training.

Screening: The inspectors determined the performance deficiency was minor. The licensees failure to provide adequate procedures for the sampling, analysis, and trending was a minor performance deficiency because during the period between March 27, 2021 and May 4, 2021, results from chemistry sampling diverged from actual and predicted trend values.

Enforcement:

Technical Specification Section 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February1978.

NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 8 addresses Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures and Calibrations and Section 8.a addresses Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, instruments, controls, and other measuring and testing devices are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy. Specific examples of such equipment to be calibrated and tested are readout instruments, interlock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective circuits, and laboratory equipment. The failure to comply with Technical Specification Section 5.4.1 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Minor Violation 71152 Minor Violation: The inspectors reviewed the licensees corrective action program for potential adverse trends related to missed surveillances that might indicate of a more significant safety issue.

CR 2020-04007, DB-SC-04200 overdue, describes the miscellaneous diesel generator and security uninterruptible power supply test unable to be performed before going overdue because of a maintenance condition on an inverter. This test is not a technical specification-required surveillance test, and the licensee was discovered the issue on its overdue date.

CR 2020-05248, Portions of monthly surveillance DB-ME-04009 for June 2020 incorrectly marked N/A, describes several portions of the surveillance test marked N/A and skipped.

CR 2021-08458, DB-MI-04014 not completed prior to overdue date, describes the failure to perform the surveillance test before the due date clean waste receiver tank hydrogen and oxygen sensor surveillance going overdue by more than a week and was discovered past the overdue date.

CR 2021-08760, Battery room B door 427A not inspected on correct frequency, describes the failure to inspect the normally open fire door on the required weekly frequency.

CR 2021-09697, DB-FP-04017 Acceptance criteria 5.1.2 went overdue on December 23, 2021 for #4 MPR water curtain spray system, describes the failure to perform the surveillance test before the overdue date and was discovered several shifts after the overdue date had passed.

CR 2021-01104, SR 3.3.1.3 Function 7 for RCP running not performed within 23 days, describes the failure to perform the technical specification surveillance high flux/number of reactor coolant pumps on within the required 23-day interval. This issue is documented below as a minor violation of technical specifications.

Though the inspectors did not identify any issue of greater than minor significance, the fact that the licensee missed multiple surveillances tests during the reviewed period could indicate a more significant underlying issue. The trend, if not arrested, may lead to a more significant safety issue.

Regarding the condition report 2021-01104, SR 3.3.1.3 Function 7 for RCP running not performed within 23 days, the license implemented a surveillance test risk-informed documented evaluation (STRIDE) to include the requirement for each of the four channels to be tested on a 92-day interval. Still, it failed to include the requirement for testing on a staggered 23-day frequency. This means that each channel is required to be tested every 92 days and that one channel is required to be tested at least once every 23 days. In this case, an engineering review of the STRIDES implementation discovered that the licensee had missed the 23-day requirement. Two channels were overdue for testing per the 23-day frequency but were not overdue per the 92-day frequency requirement.

Screening: The inspectors determined the performance deficiency was minor. The licensees failure to perform surveillance requirement 3.3.1.3 according to the interval required by technical specifications was a performance deficiency. The significance of this performance deficiency was minor because it did not negatively affect plant safety.

Enforcement:

The failure to comply with technical specification surveillance requirement 3.3.1.3 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Potential Trend Regarding Inconsistent Use of the Corrective Action Program 71152 The inspectors reviewed the licensees corrective action program for condition reports that might indicate a more significant safety issue. The inspectors noted multiple examples indicating that the threshold for writing a condition report may not be consistent among plant employees.

On July 30, 2021, during work on the fire protection system, the mechanical penetration room 4 water curtain was spuriously activated which caused a significant amount of water to run from the room into the passage outside. Following this condition, the inspectors observed standing water. The licensee determined that this standing water was caused by partially and completely blocked floor drains. A plant employee cleared the blockage and water drained as designed. Following discovery of this issue, the inspectors noted several additional floor drains that appeared to contain significant buildup of debris. The licensee did not generate a condition report until the inspectors intervened (CR 2021-07350).

A contributing cause of the July 8, 2021 reactor trip was the failure of the digital electrohydraulic control (DEHC) uninterruptible power supply (UPS) battery due to a degraded cell. The licensee replaced this cell, and the battery was thought to be restored. However, the inspectors noted that another cell appeared to show similar signs of degradation and brought the concern to the licensee over several months.

The licensee wrote no condition report until the inspectors brought their concern to the Plant Manager (CR 2021-07316). The licensee has since replaced the entire battery bank.

On several instances, the inspectors noted charging error messages on battery backup emergency lighting and brought these to the licensee's attention. Though the licensee fixed the issue every instance, the licensee wrote no condition report. This result was in contrast to multiple CRs written for similar conditions over the same period.

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, station personnel may not have a consistent standard for documenting condition reports for these and other issues. Because of this, some conditions may be tracked through the corrective action program and the station may be missing the opportunity to identify and trend deficiencies potentially resulting in an adverse impact on the plant. The inspectors provided these observations to the licensee and identified no findings or violations.

Observation: Service Water Valve 1429 Failed Air Drop Test 71152 The inspectors performed an in-depth inspection sample of service water valve 1429, component cooling water (CCW) heat exchanger 3 service water outlet isolation valve, which failed a scheduled air drop test as documented in condition report 2021-06913. This fail-open pneumatically actuated valve controls service water flow through CCW heat exchanger 3.

The licensee overhauls the valve on a 12-year preventive maintenance frequency. The licensee performed this air drop test to assess the condition of the valve and determine a maintenance strategy. This scheduled interval for the air drop test changed from 18 months to 24 months in 2006. The failed air drop test indicated reduced seal performance, but the licensee determined that the valve would fulfill its safety function until scheduled preventive maintenance. The inspectors identified no findings or violations.

Observation: Service Water Pump 3 Repetitive Failure of Packing Due to Bearing Design Change 71152 The inspectors performed an in-depth inspection sample of service water pump 3 (SWP3)rework following the scheduled pump replacement in July 2021. The initial post-maintenance testing of the new pump failed due to a lack of packing leak-by resulting in overheated packing. Plant operators tripped the pump manually as soon as the observed the condition, and maintenance personnel repacked the pump following troubleshooting. Once the licensee repacked SWP3, it passed post-maintenance testing with less than expected packing leak-by, and was declared operable on August 3, 2021, but maintained in spare status.

SWP3 was again declared inoperable for unrelated maintenance from August 26, 2021, until September 21, 2021, when it was declared operable but maintained in spare status. On September 30, 2021, SWP3 was declared inoperable pending completion of the quarterly test performed on 10/14/2021. During the quarterly test on October 14, 2021, the packing leak-by issue persisted, and the packing began to overheat. Troubleshooting identified that a change in the bushing type, from smooth bronze to axially grooved polymer, had led to the packing issues. The licensee replaced the axially grooved polymer bearings with conventional smooth bronze, and operators restored the pump to an operable condition with adequate packing leak-by. The inspectors identified no findings or violations.

EXIT MEETINGS AND DEBRIEFS

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

On January 28, 2022, the inspectors presented the integrated inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.

On December 13, 2021, 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 13, 2021, the inspectors presented the Review of Licensed Operator Annual Examination summary results inspection results to Mr. D. Witt, Operations Training Superintendent, and other members of the licensee staff.

On December 14, 2021, the inspectors presented the EP Inspection Exit Meeting inspection results to Mr. R.W. Oesterle, Manager, Regulatory Compliance and Emergency Response, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2021-08640

DFP Room Watertight Door 217 Hinges Degraded, and

Latch Pins are at Maximum Adjustment

11/11/2021

Corrective Action

Documents

CR-2021-09473

Door 217 Upper Latch Found Degraded

2/14/2021

NORM-LP-7221

Davis Besse Flooding Mitigating Strategy Assessment

Support Document

2/19/2016

NORM-LP-7222

Davis Besse Nuclear Power Station Flooding Focused

Evaluation

10/13/2017

71111.01

Procedures

RA-EP-02830

Emergency Plan Off Normal Occurrence Procedure

CR-2021-01043

EDG RM 1 Heater E48-1 Not Maintaining Desired

Temperature

2/17/2021

Corrective Action

Documents

CR-2021-09576

SBODG DC Ground Meter Swinging During Monthly Run

Miscellaneous

Notification

601304770

Emergency Diesel Generator Room 1 Ambient

Temperature 68-69 Degrees F

2/17/2021

DB-OP-06011

High Pressure Injection System

DB-OP-06013

Containment Spray System

DB-OP-06234

Emergency Feedwater System

DB-OP-06316

Diesel Generator Operating Procedure

71111.04

Procedures

DB-OP-06334

Station Blackout Diesel Generator Operating Procedure

PFP-AB-208

No 1 Mechanical Penetration Room and Pipeway Area

Rooms 202, 208 and 209 DC Fire Area AB

71111.05

Fire Plans

PFP-AB-236

No 2 Mechanical Penetration Room, Room 236 Fire Area A

71111.11A

Miscellaneous

Requalification

Program Annual

Testing Summary

Results

Licensed Operator Annual Performance Records for 2021

2/13/2021

OPS-JPM-042

In Plant Job Performance Measure

OPS-JPM-238

Simulator Job Performance Measure

OPS-JPM-257

In Plant Job Performance Measure

OPS-JPM-284

Simulator Job Performance Measure

OPS-JPM-293

Administrative Job Performance Measure

ORQ-EPE-S103

Simulator Scenario Guide

71111.11Q

Miscellaneous

ORQ-EPE-S114

Simulator Scenario Guide

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ORQ-EPE-S129

Simulator Scenario Guide

200817776

Auxiliary Feedwater Pump Turbines

11/08/2021

71111.12

Work Orders

200866466

Service Water Pumps, Strainers, and PIPI

10/22/2021

Corrective Action

Documents

CR-2021-07736

Service Water Pump 3 Manually Tripped

10/14/2021

200866466

Service Water Pump 1-3 Minor Maintenance

10/22/2021

71111.13

Work Orders

200866740

Service Water Pump 1-3 Install Leak Collection and

Drainage Equipment

10/20/2021

CR-2021-07222

HV5329B EDG Room 1 Recirc Damper Not Modulating

10/26/2021

CR-2021-07257

EDG 1 Ventilation Recirc Damper has a Crack in the Shaft

10/27/2021

71111.15

Corrective Action

Documents

CR-2021-08257

EDG Room 2 Vent Fan Recirc Supply Damper HV5336B

Not Fully Open with Hydromotor De-Energized

11/24/2021

Procedures

DB-PF-03572

Component Cooling Water Pump 1 Baseline Test

71111.19

Work Orders

200817776

Auxiliary Feed Pump Turbine 1-2 Replace Agastat Relay

10/19/2021

200809037

SFAS Channel 1 Functional Test

11/30/2021

200809710

SFAS Channel 2 Functional Test

2/14/2021

200810139

Channel Functional Test of Reactor Trip Breaker A, RPS

Channel 2 Reactor Trip Module Logic and Arts Channel 2

Output Logic

2/15/2021

71111.22

Work Orders

200816776

Determination of MTC - Rod Swap

10/12/2021

DBNPS Emergency Plan

DBRM-EMER-

1500A

Davis Besse Emergency Action Level Basis Document

71114.04

Miscellaneous

RA-EP-01500

Emergency Classification

71114.06

Miscellaneous

Davis-Besse

Nuclear Power

Station Emergency

Preparedness

Integrated Dill

Drill Guide

10/05/2021

Calibration

Records

Tennelec Proportional Counter Model S5XLR Serial

Number 2.12.56 Calibration

11/18/2019

CR-2020-00306

Periodic Low PH Conditions in Liquid Radwaste System

01/16/2020

CR-021-03087

Waste Oil Drum

04/19/2021

71124.08

Corrective Action

Documents

CR-2021-04312

Source Paperwork

05/28/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2021-06693

MS-C-08-03: Gaps in Shipping Package Checklists

09/03/2021

Davis-Besse Nuclear Power Station Part 37 Radioactive

Materials Security Plan

467716004

CFR Part 61 Analysis for Dry Active Waste

2/20/2018

483034001

CFR Part 61 Analysis for Primary Resin

06/17/2019

23959001

CFR Part 61 Analysis for Primary Resin

07/16/2020

DBBP-LP-1601

Davis-Besse Nuclear Power Station Part 37 Radioactive

Materials Security Plan Guidance

G-RP-

10CFR37_FEN_00

10CFR37 Control of Cat 1 and Cat 2 RAM

Miscellaneous

SE-

PART37WKR_FEN

Radioactive Materials Part 37 Plan Worker Training-DB

Security

Process Control Program

DB-HP-01511

Low Level Radioactive Waste Storage Facility (LLRWSF)

DB-HP-01702

Transfer, Handling and Storage of Radioactive Material

Procedures

NOP-OP-5201

Shipment of Radioactive Material-Waste

Radiation

Surveys

WO 200783224

Licensed Sources Leak Testing and Inventory

05/27/2021

20-1002

Radioactive Waste Shipment of Dry Active Waste

03/19/2020

21-1001

Radioactive Waste Shipment of Dewatered Resin

08/14/2021

21-1003

Radioactive Waste Shipment of Dewatered Resin

08/28/2021

Shipping Records

21-1005

Radioactive Waste Shipment of Dewatered Resin

11/20/2021

Reactor Coolant System Activity Dose Equivalent Iodine

Data (07/01/2020 - 09/30/2021)

Various

Reactor Coolant System Dose Equivalent Analysis

11/03/2021

Miscellaneous

Gaseous and Liquid Radioactive Effluent Radiological Dose

Summary Reports, July 2020 through September 2021

Various

DB-CH-01815

Dose Equivalent I-131 Determination

DB-HP-01116

Canberra Genie 2000Counting System with Apex Gamma

Software

71151

Procedures

NOBP-LP-4012

Industry Reporting and Information System (IRIS)

71152

Corrective Action

CR-2020-00200

DB-FP-04017 Not Able to be Completed by Overdue Date

01/11/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2020-02157

PRA Analysis Assessment Not Performed in Support of

STRIDE 2019-0001

03/12/2020

CR-2020-04007

DB-SC-04200 Overdue

05/05/2020

CR-2020-05248

Portions of Monthly Surveillance DB-MI-04009 for June

20 Incorrectly Marked N/A

06/24/2020

CR-2021-01104

SR 3.3.1.3 Function 7 for RCP Running Not Performed

Within 23 Days

2/18/2021

CR-2021-01506

TRM TVR 8.8.1.2 Not Met for EDG 1 and EDG 2 Due to

PM Frequency From 6 Years to 18 Years Not Being

Evaluated by an Acceptable 50.59

03/04/2021

CR-2021-02729

Surveillance and Periodic Test Program Change Form Not

Submitted as Required

04/09/2021

CR-2021-03645

Unexpected Boron Results for the Daily Reactor Coolant

System

05/04/2021

CR-2021-03693

Unexpected Boron Results - Investigation in Progress

05/05/2021

CR-2021-03709

Reactivity Anomaly Surveillance Missed due to

Performance with Potentially Erroneous RCS Boron

Concentration

05/06/2021

CR-2021-05633

SW Pump 3 Full Flow Testing Stopped Due to Loss of

Pump Packing Gland Leak Off

07/24/2021

CR-2021-05658

Entry into Abnormal Procedure for Loss of Service Water

Secondaries

07/26/2021

Cr-2021-05760

Lantern Ring Dimensions per Vendor Recommended

Clearances Not in Tolerances

07/29/2021

CR-2021-05789

Water curtain Activation

07/30/2021

CR-2021-05793

HPI Pump 2 Sprayed with Fire Protection Water

07/30/2021

CR-2021-05795

Low Pressure Injection Pump 2 Sprayed with Fire

Protection Water

07/30/2021

CR-2021-06913

SW1429 (Component Cooling Water Heat Exchanger 3

Service Water Outlet Isolation Valve) Air Drop Test

09/14/2021

Documents

CR-2021-07350

Backed Up Floor Drain Encountered During Water Curtain

Actuation

10/01/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2021-07511

Untimely Initiation of Condition Report 2021-07350 (Backed

Up Floor Drain Encountered During Water Curtain

Actuation)

10/08/2021

CR-2021-07736

Service Water Pump 3 Manually Tripped

10/14/2021

CR-2021-08458

DB-MI-04014 Not Completed Prior to Overdue Date

11/05/2021

CR-2021-08760

Battery Room B Door 427A Not Inspected on Correct

Frequency

11/16/2021

CR-2021-09054

Low Oil Level SW Pump 3 Thrust Bearing

11/29/2021

CR-2021-09697

DB-FP-04017 Acceptance Criteria 5.1.2 went Overdue on

2/23/21 for '4' MPR Water Curtain Spray System

2/25/2021

CR-2021-01334

Degraded Cabinet Ground Strap Lug

03/26/2021

Cr-2021-01488

Conduit Elbow Cover Top Cover Bolt Missing

04/02/2021

CR-2021-01490

Flexible Conduit Has Ground Lugs on Each End but no

Ground Cable

04/02/2021

CR-2021-01573

NRC Identified Concern Regarding Potentially Inadequate

Part 21s Leading to EDG Failures

09/17/2021

CR-2021-02204

NRC NCV: Failure to Maintain the Effectiveness of the

Emergency Plan due to Telephone Issues

05/21/2021

CR-2021-02440

Containment Spray 1 Pump Outboard Bearing Oil Level

Below Sightglass Band

04/30/2021

CR-2021-02969

21 Cyber Inspection: Instruments for Reg Guide 1.97,

Post Accident Monitor, are Categorized as Indirect when

they Should be Direct CDAs

05/14/2021

CR-2021-03462

NRC Observation: Rust Discovered on Self-Contained

Breathing Apparatus Pack

05/26/2021

CR-2021-04641

NRC Question Regarding Functionality of Fire Suppression

Sprinkler in SW Valve Room

07/13/2021

CR-2021-04717

DFP Alternator Lower Mounting Nut is Loose

07/16/2021

CR-2021-04718

DFP Cooling Hoses Have Small Cracks Developing

07/16/2021

CR-2021-04720

DFP Alternator Positive Lug Questions

07/16/2021

CR-2021-04894

Service Water Tunnel Ceiling Leak Impacting Conduits

Below

07/23/2021

Corrective Action

Documents

Resulting from

Inspection

CR-2021-05395

NRC Identified: Vegetation Growth Around Radiological

Environmental Monitoring Program Air Sampling Stations

08/13/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2021-05419

NRC Identified: DB-HP-01702: Procedure Confusion on

Environmental Air Sampler Calibration

08/13/2021

CR-2021-05729

21 NRC SIT: Operational Impact for Not Replacing

ZS01B

09/15/2021

CR-2021-05919

21 NRC SIT: Maintenance Rule Evaluation for

CR-2021-05262 Required

09/03/2021

CR-2021-06024

NRC SIT: Maintenance Rule Failure Review for

CR-2021-05319 Defective Battery Cell Identified at D3201B

During Troubleshooting of DEHC UPS

09/08/2021

CR-2021-06134

21 NRC SIT: Incorrect AP-913 Classification for C3621

09/10/2021

CR-2021-06146

Switch DST for MUP time Delay Relay 2Y1 Isolation

Potentially Exposed to Similar Degradation Mechanisms as

EDG FFSS

09/10/2021

CR-2021-06212

Incorrect Value Recorded in Operator Rounds for

August 2020 DC MCC 2 Ground Indication

09/16/2021

CR-2021-06279

MPR 4 Housekeeping Issues

09/17/2021

CR-2021-06500

21 PI&R NRC Inspection: Observation for Appropriate

CR Category Assignments

09/24/2021

CR-2021-06582

21 NRC SIT: Calculation Contains Incorrect Value in

Table

09/30/2021

CR-2021-06845

BACC: Leak from Instrument Housing on PD16589

10/08/2021

CR-2021-07350

Backed up Floor Drain Encountered During Water Curtain

Actuation

10/29/2021

CR-2021-07458

NRC DBAI 2021 - Clarification of Result and Conclusions

Summary in C-EE-002.01-010

11/05/2021

CR-2021-07511

Untimely Initiation of condition Report 2021-07350 (Backed

Up Floor Drain Encountered During Water Curtain

Actuation)

11/05/2021

CR-2021-07512

NRC DBAI 2021 - Excessive Grease Identified on 1P

Battery Connector

11/05/2021

CR-2021-07515

NRC DBAI 2021 - Clarification of Output Documents to

Calculation C-EE-004.01-049 (4.16 kV Bus C1/D1

Degraded Voltage, Loss of Voltage, and 27X-6

11/05/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-2021-07904

NRC DBAI 2021 - Error in Previous Revision of 30 of

C-EE-002.01-010

11/19/2021

CR-2021-07914

Unable to Identify CRs Related to WO 200751566 and

WO 200679064 Regarding Instrument As-Found Out of

Tolerance

10/19/2021

CR-2021-09166

Failure to Appropriately Classify the DEHC UPS Supply

Battery Bank

11/19/2021

CR-2021-09167

Failure to Provide Procedural Instructions for Transferring

Gland Sealing Steam from Main to Auxiliary Steam

Following a Reactor Trip

11/19/2021

CR-2021-09278

NRC TI Inspection: Resources Not Established for

Performance of Calibration/Alarm Testing for Open Phase

Systems

2/09/2021

CR-2021-09282

NRC TI Inspection: DB-OP-06313 Procedure Enhancement

Observation for Open Phase Condition

2/09/2021

CR-2021-09636

Wasp Nest Identified on the SBODG Building

2/29/2021

CR-2021-09637

Bird Nest Identified on SBODG Radiator

01/03/2022

CR-2021-7464

NRC DBAI 2021 - HV5336B (EDG 2 Room HVAC Recirc

Damper Hydramotor Position Indicator Labels Incorrectly

Depict 'Open' and 'Shut'

11/05/2021

Drawings

N300214401

Model VITx-50 2G/28BHC - 2 STG

Engineering

Changes

EC 19-0041-001

Service Water Pump 3 Refurbishment

08/02/2019

Maintenance Plan

DB-TV1429 CCW Heat Exchanger

Maintenance Plan

DB-TV1429 CCW Heat Exchanger (Service Water Side

Various)

Miscellaneous

Maintenance Plan

Db-TV1429 SW Outlet Isolation Valve Op

Labor Contingency Plan - Energy Harbor

Labor Contingency Plan - Energy Harbor

Davis Besse Chemistry Department Management

Personnel Training Qualification Records

Various

2709

Miscellaneous

Davis Besse Chemistry Department Management

Personnel Training Exemption and Equivalent Qualification

Forms

11/05/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ANSI 18.1-1971

Selection and Training of Nuclear Power Plant Personnel

03/08/1971

Command SRO

Proficiency

Records

3rd Quarter 2021

11/16/2021

Command SRO

Proficiency

Records

4th Quarter 2021

11/16/2021

DBNPS

Emergency Plan

EMERGENCY PLAN

ORQ-EPE-S111

Simulator Scenario Guide

ORQ-EPE-S112

Simulator Scenario Guide

ORQ-EPE-S149

Simulator Scenario Guide

Shift Manager

Proficiency

Records

3rd Quarter 2021

11/16/2021

Shift Manager

Proficiency

Records

4th Quarter 2021

11/16/2021

TPD-CRP

Training Program Description - Fleet Radiation Protection

Common Training Program

01/27/2021

TPD-DBCH

Davis Besse Chemistry Training Program Descrption

TPD-DBRP

Davis-Besse Radiation Protection Training Program

Description

NOBP-TR-1112

Conduct of Simulator Training and Evaluation - Crew and

Individual Evaluation Forms

10/29/2021

Procedures

NOBP-TR-1271

Inactive License Retraining Program

13