IR 05000346/2021010
| ML21280A112 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/07/2021 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2021010 | |
| Download: ML21280A112 (13) | |
Text
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2021010
Dear Mr. Brown:
On August 20, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Davis-Besse Nuclear Power Station and 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
October 7, 2021 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:
Report Number:
Enterprise Identifier:
I-2021-010-0051
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Davis-Besse Nuclear Power Station
Location:
Oak Harbor, OH
Inspection Dates:
August 02, 2021 to August 20, 2021
Inspectors:
B. Boston, Emergency Response Coordinator
R. Cassara, Resident Inspector
R. Elliott, Senior Resident Inspector
V. Myers, Senior Health Physicist
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 a biennial problem identification and resolution 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
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, 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 (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review including a 5-year time period for the Decay Heat Removal-Low Pressure Coolant Injection, Component Cooling Water (CCW), and Service Water systems.
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment of the Corrective Action Program Based on the activities that the inspectors selected for review, the inspection team concluded that the implementation of the problem identification and resolution process (the corrective action program) was adequate to appropriately protect the health and safety of the public and the environment. The plant staff had a low threshold for identifying problems and entering them, in a timely manner, in the condition report (CR) system. Items entered into the corrective action program (CAP) were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed Operating Experience (OE)for applicability to station activities. Audits and self-assessments appeared to be performed at an appropriate level to identify deficiencies. In interviews conducted during the inspection, workers at the site expressed freedom to bring up nuclear safety concerns and were encouraged to enter items in the CAP system.
Effectiveness of Problem Identification Overall, the station effectively identified issues at a low threshold and was properly entering them into the CAP as required by station procedures. The team determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. For the areas reviewed, the team did identify one issue in the area of problem identification. During the team's review of one condition report and the associated corrective action, the team observed that the licensee did not specify a valve and related piping had been over-pressurized until after the licensee had installed the valve into the decay heat removal system (Valve DH210 in CR-2016-05753). Condition Report-2016-05753 addressed leakage from valve DH210, which led to the discovery that the valve and associated piping had been over-pressurized during bench testing. The licensee evaluation noted that although the 3000 psig test failure led to appropriately changing the testing pressure to 97 psi, the licensee did not write a condition report to identify they were testing at the incorrect pressure for the valve and associated piping. The team determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant issues from developing. Trends for open CRs and work orders appeared reasonable. The licensee used the CAP to document instances in which previous corrective actions were ineffective or were inappropriately closed.
Effectiveness of Prioritization and Evaluation of Issues Based on the samples reviewed, the team determined that licensee performance was adequate. The Management Review Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. The team observed a healthy dialogue between the members of this committee when dispositioning condition reports. Generally, the licensee completed the evaluations in a timely manner. While the team did not identify issues with the effectiveness of prioritization and evaluation of issues, the team determined that the licensee coded various CRs related to radiation protection as NC (non-CAP),including one related to an intake of radioactive material. Governing procedures are high level and allow for flexibility in coding items not covered by 10 CFR 50 Appendix B. The inspection team determined this flexibility can lead to inconsistency in how the licensee addressed these types of issues. For example, it appears all contamination found in clean areas are maintained in the CAP, but contamination found in a person may not. However, a review of actions taken in response to these CRs indicates that the corrective actions (CAs)are being performed appropriately outside the CAP.
Effectiveness of Corrective Actions Based on the samples reviewed, the team determined that the licensee was adequately implementing CAs with some licensee-identified opportunities for improvement in CA implementation. In general, the licensee implemented CAs for deficiencies that were safety-significant in an adequate and timely manner. The team sampled CA assignments developed for selected NRC documented violations, selected licensee event reports, some license self-assessments, and some licensee-identified issues. Where either enough time had elapsed, and/or the licensee had performed effectiveness reviews, the team also looked at the effectiveness of the CAs (i.e., was there a recurrence of the issues). The team did not identify problems of the efficacy of CAs.
Safety Conscious Work Environment The team found no evidence of challenges to the licensee's safety-conscious work environment (SCWE). Plant employees appeared willing to raise nuclear safety concerns through at least one of the several means available. The team observed various station meetings, including those in which new CRs were reviewed, and interviewed a representative cross-section of multiple station personnel, including individual and group interviews.
Additionally, the team assessed the annual SCWE evaluations. Specifically, during SCWE interviews, it was brought to the team's attention that anonymous CRs via the Employee Concerns Program (ECP) were not accurately addressing the individual's concern. The team reviewed the survey results from 2018-2020 and recognized moderate negative staff responses regarding the belief that issues reported through the ECP will be thoroughly investigated and objectively dispositioned, the use of ECP without fear of retaliation, and keeping the identity of individuals confidential at the individual's request. The survey results also identified high negative responses in Chemistry, Maintenance, and Security regarding the confidence in the CR process to properly prioritize, investigate, and resolve issues reported and effectively resolve conditions adverse to quality in a timely manner.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 20, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Terry Brown, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2016-05753
DB EFW / FLEX Project - Valve DH210 Over-Pressurized
and Over-Torqued.
04/22/2016
CR-2017-03328
NRC 2017 UHS Inspection: Vulnerabilities Identified with
ECCS Room Cooler Clean/Inspection Strategy.
03/23/2017
CR-2019-00225
Crack Detected on MSIV-2 Bypass Piping Sockolet Weld
01/09/2019
CR-2019-00251
Procedure Non-Compliance: NOP-LP-4011-Work Hour
Controls
01/10/2019
CR-2019-00709
RP SCWE Survey Red Window Results Regarding
Effectiveness of CAP
01/23/2019
CR-2019-03102
Sink Hole Outside of Door 301
04/02/2019
CR-2019-03762
Potential to Implement Temporary Configuration Changes
Without Evaluation Under 50.59/72.48
04/22/2019
CR-2019-04914
SW38 New Valve Taper Pin as Found Condition
06/04/2019
CR-2019-05429
WANO Observation Review: Nuclear Safety Culture
Weaknesses in PI&R and WP
06/24/2019
CR-2019-05843
NRC Concern: Replacement SW38 Taper Pins
07/10/2019
CR-2019-05966
2019 WANO: AFI OR.2-Failure to Resolve Some Important
Vulnerabilities.
07/15/2019
CR-2019-05967
2019 WANO: AFI CY.1 - Inaccurate Results During
Laboratory Cross-Check Analysis
07/15/2019
CR-2019-05968
2019 WANO: AFI ER.4 - Deficiencies in Cathodic Protection
System
07/15/2019
CR-2019-06949
Door 215 Left Open for Extended Amount of Time Without
Permission Resulting in Loss of Safety Function
08/19/2019
CR-2019-07152
Part 21 for Fisher Butterfly Valves
08/27/2019
CR-2019-07154
2019 NRC Radioactive Effluents and REMP: Implementation
of Environmental Dosimetry ANSI N13.37-2014
08/27/2019
CR-2019-07769
Cognitive trending - Condition Reports Relative to
Contamination Found in Clean Area of Radiological
Controlled Area
09/20/2019
Corrective Action
Documents
CR-2019-07840
Cognitive Trending - Increase in Radiological
Instrumentation Condition Reports in Third Quarter of 2019
09/24/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2019-09729
ECCS Room 1 Sump Pump 1A Degraded Operation
11/18/2019
CR-2019-09924
NRC: NCV 2019003-01 on Inadequate Work Instructions for
a Valve Installation
11/25/2019
CR-2019-10379
NRC Inspection: Diving Dosimetry Enhancements
2/11/2019
CR-2020-00755
Valve Mispositioned (closed) During Oil Sampling
01/31/2020
CR-2020-01605
Failure to Follow NOP-LP-1002 Fitness for Duty Program
Requirements
2/29/2020
CR-2020-02195
21RFO Level 1 Personnel Contamination Event - Facial
Contamination
03/12/2020
CR-2020-02741
Unexpected Rod Insertion during FW Flow Calibration
04/28/2020
CR-2020-04095
A Level Schedule Deviation for AFW testing
05/08/2020
CR-2020-04235
REMP Air Monitor Loss of Power Trend
05/14/2020
CR-2020-04264
Revised Maintenance Rule Failure Determinations.
05/14/2020
CR-2020-05158
What is the Evidence/ Scientific Basis for Unvaccinated
Individuals Wearing Masks?
07/06/2021
CR-2020-05163-
ATA-01
Update MRPM for Makeup & Purification system
06/09/2020
CR-2020-06105
Corrective Action Exceeded Due Date - Emergency
Response
08/01/2020
CR-2020-06587
CCW Pump #1 Exceeded Maintenance Rule Unavailability
Limit.
08/21/2020
CR-2020-08112
Outer Cover Inadvertently Removed During Testing on
MS107A
10/20/2020
CR-2020-08586
Basis of Management Desired Staffing Levels
11/05/2020
CR-2020-0882
20 1st half NSCMP: Trait 4-Leadership Accountability,
Area in Need of Improvement.
11/13/2020
CR-2020-08948
Increase in REMP Air Monitor Gross Beta Results
11/19/2020
CR-2021-00542
NRC NCV: Failure to Perform a 50.59 Evaluation for a
Change to a TRM Surveillance
01/28/2021
CR-2021-01649
Performance Assessment Elevation: Emergency Response
Organization (ERO) Call-In Test / Drill Performance.
03/09/2021
CR-2021-02098
Trending of Chemistry Program CRs for
Sectional/Organizational Learnings
03/22/2021
CR-2021-02204
NRC NCV: Failure to Maintain the Effectiveness of the
03/25/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency Plan due to Telephone Issues.
CR-2021-03208
Radiological Environmental Monitoring Program Air Sampler
T-7 Power Interruption
04/22/2021
CR-2021-04400
REMP Air Sampler T-1 Power Interruption
06/02/2021
CR-2021-04502
Trending of RP Instrumentation
06/07/2021
CR-2021-04857
COVID-19 Related Concerns/Questions
06/22/2021
CR-2021-05048
Radiological Environmental Monitoring Program Air Sampler
T-12 Power Interruption
06/30/2021
DB-MI-04241
String Check Of 45A-ISFSP02A2 Main Feedwater Flow Loop
(Periodic Test Procedure)
DB-MI-04243
String Check Of 45A-ISFSP02B2 Main Feedwater Flow Loop
(Periodic Test Procedure)
NOBP-LP-2502
Safety Culture Monitoring
OE-2019-0067-2
OE447550R20190221 Ultrasonic Inspection Indication on
Reactor Head Nozzle Penetration.
03/18/2019
OE-2019-0122-2
IN1901, Inadequate Evaluation of Temporary Alterations.
03/29/2019
OE-2019-0159-2
OE437513R20190419 Condition Prohibited by Technical
Specifications Due to Untimely Recognition of Failed
Laboratory Analysis of Ventilation Charcoal Sample.
05/30/2019
OE-2020-0072-2
OE468879R20200310 Auxiliary Feedwater System Declared
Inoperable Due to Check Valve Leakage.
04/13/2020
OE-2021-0063-1
DB Effectiveness Review for IER L2 12-14 Rev 1, Automatic Reactor Scram Resulting Form A Design Vulnerability in the
4.16-Kv Buss Undervoltage Protection Scheme, Rec. 3
2/04/2021
ATA-2020-15317
Evaluate Davis-Besse Condition Report Initiation Rate
2/14/2020
M-215-00095
Instruction Manual for 9100 Series Butterfly Control Valve
Bodies
M-215-00095
Instruction Manual for 9100 Series Butterfly Control Valve
Bodies
Nuclear safety
culture monitoring
panel
1st Half 2021 NSCMP Package
08/17/2021
Miscellaneous
SA-BN-2020-
28
2nd Half 2019 DBNPS Nuclear Safety Culture Monitoring
Panel
2/17/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Quality Assurance Program Manual
DB-CH-00002
Chemistry Laboratory Techniques and Practices.
Rev 01
07/24/2020
DB-CN-00013
Review and Evaluation of Radiological Environmental
Monitoring Program Sample Analysis Results
DB-MI-04240
String Check Of 45A-ISFSP02A1 Main Feed Water Flow
Loop 2 (Periodic Test Procedure)
DB-MI-04242
String Check Of 45A-ISFSP02B1 Main Feedwater Flow Loop
Periodic Test Procedure)
DB-MM-09317
Fisher Type 9100 Butterfly Control Valve Maintenance
DB-MM-09317
Fisher Type 9100 Butterfly Control Valve Maintenance
NOBP-LP-2001
Self-Assessment and Benchmarking
NOBP-LP-2003
Employee Concerns Program
03/30/2021
NOBP-LP-2008
Corrective Action Review Board
NOBP-LP-2011
Cause Analysis
NOBP-LP-2018
Integrated Performance Assessment
NOBP-LP-2022
Compliance Auditing
NOBP-LP-2100
Operating Experience Process
NOBP-LP-2502
Safety Culture Monitoring
NOP-LP-1002
Fitness for Duty Program
NOP-LP-2001
Corrective Action Program
NOP-OP-4204
Special External Exposure Monitoring
NOP-P-1009
Operability Determinations and Functionality Assessments
NOP-WM-0001
Work Management Process
NOPM-LP-0001
Personal Safety Manual
10/01/2020
NOPM-LP-2009
Human Performance Handbook
10/01/2020
Procedures
NORM-LP-2003
Analytical Methods Guidebook
Davis-Besse SCWE Survey Results for September 2019
10/01/2019
Davis-Besse SCWE Survey Results for September 2020
10/01/2020
ATA-2020-11612
20 Davis-Besse Mid-Cycle Assessment.
09/28/2020
ATA-2020-12956
Davis-Besse Nuclear Safety Culture Monitoring Panel 2020
1st Half.
11/16/2020
Self-Assessments
MS-C-19-08-03
Radiation Protection/Radwaste
09/12/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MS-C-20-05-07
Maintenance/Work Management Program
06/30/2020
MS-C-20-08-02
Chemistry/Environmental
09/18/2020
200691026
SS3145-001 05.001 CREVs Train 1 CTRM EVS Refuel/Spec
Test
04/04/2019
Work Orders
200764571
SS3146-001 05.001 CREVs Train 2 CTRM EVS Refuel/Spec
Test
06/29/2021