IR 05000346/2022010
| ML22306A121 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/02/2022 |
| From: | Karla Stoedter NRC/RGN-III/DORS/EB1 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2022010 | |
| Download: ML22306A121 (15) | |
Text
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000346/2022010
Dear Terry Brown:
On September 26, 2022, 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. K. Zellers and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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.
November 2, 2022 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, Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000346 License No. NPF-3
Enclosure:
As stated
Inspection Report
Docket Number:
05000346
License Number:
Report Number:
Enterprise Identifier:
I-2022-010-0052
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Davis-Besse Nuclear Power Station
Location:
Oak Harbor, OH
Inspection Dates:
August 15, 2022 to September 26, 2022
Inspectors:
K. Barclay, Reactor Inspector
M. Jones, Reactor Inspector
J. Park, Reactor Inspector
Approved By:
Karla K. Stoedter, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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. A licensee-identified non-cited violation is documented in report section: 71111.21N.0
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.
REACTOR SAFETY
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a.
Determined whether the sampled power-operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
b.
Determined whether the sampled POVs are capable of performing their design-basis functions.
c.
Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d.
Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
- (1) CC1467, Decay Heat Cooler 1 Component Cooling Water Isolation Valve
- (2) CC1495, Component Cooling Water to Auxiliary Building Non-Essential Header Isolation Valve
- (3) SW1424, Component Cooling Water Heat Exchanger Service Water Outlet Temperature Control Valve
- (4) CC5095, Component Cooling Water Line 1 Discharge Header Cross-Tie Valve
- (5) AF-3870, Auxiliary Feedwater Pump 1 to Once Through Steam Generator 1 Stop Valve
- (6) AF-6451, Auxiliary Feedwater Pump 2 Discharge Flow Control Valve
- (7) MS-100, Main Steam Isolation Valve
- (8) MS-5889B, Auxiliary Feedwater Pump Turbine 2 Steam Admission Valve
- (9) DH-1A, Decay Heat Pump 2 Discharge to Reactor Coolant System Isolation
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.21N.02 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 of the Code of Federal Regulations (10 CFR), Subsection 50.55a(b)(3)(ii)required, in part, that licensees must establish a program to ensure that motor operated valves (MOVs) continue to be capable of performing their design basis safety functions.
Contrary to the above, through September 20, 2022, the licensee had not established a program that ensured MOVs CF-5A and CF-5B, Core Flood Tank Vent Containment Isolation Valves, were capable of performing their design basis safety function to close. Specifically, the licensee did not meet the acceptance criteria for the alternate MOV periodic verification approach they credited as their plant-specific program for valves CF-5A and CF-5B.
The licensee evaluated CF-5A and CF-5B in February 2010, and concluded that the unbalanced globe valves were Class D valves because the valves nitrogen flow rate exceeded the 86 feet per second limit of the Joint Owners Group (JOG) MOV Periodic Verification Program. The JOG MOV Program excluded the high flow rate valves from applicability because side loading on the valve disk could be affected and result in increased disk-to-guide friction. Licensees were required to develop their own plant-specific program for MOVs within the scope of Generic Letter 96-05 but outside the JOG MOV Periodic Verification Program. The licensee implemented a method contained within BWROG-TP-09-033, "Generic Methodology for JOG MOV Periodic Verification Program - Category D MOV Evaluations," as their periodic verification program for CF-5A and CF-5B.
The BWROG-TP-09-033 methodology required, in part, that one of the valves undergo an in-body inspection to verify that no internal degradation had occurred. On June 10, 2022, the licensee-identified that they had not performed the required in-body inspection on valve CF-5A or CF-5B.
The licensees fourth 10-year Inservice Testing (IST) interval ended on September 20, 2022.
The licensee, in their fifth IST interval, transitioned to the 2017 edition of ASME OM, "Operation and Maintenance of Nuclear Power Plants," which contains Mandatory Appendix III, "Preservice and Inservice Testing of Active Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants."
Significance/Severity: Green. The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, "Barrier Integrity Screening Questions, the finding screened as having very low safety significance (Green) after the inspectors answered No to question C.1 and C.2. The inspectors, in consultation with an Office of Nuclear Reactor Regulation mechanical engineer and MOV specialist, concluded that the licensees basis for continued operability was reasonable. The licensees basis included consideration of several valve configuration attributes including the fact the nitrogen flow was over the valve seat, and the valves safety direction was to close; the valve was not subject to a flashing differential pressure; and the licensees calculation conservatively used a value of zero for differential pressure in the closing direction, when in fact the value was greater than zero and would assist the valve in the closing direction. The licensee also cited Electric Power Research Institute Technical Report 3002008055, "Evaluation Guide for Valve Thrust and Torque Requirements,"
August 2016, Section 5.4.4.5, which considered the disk-to-body (guide) friction for the licensees configuration to be negligible.
Corrective Action References: CR-2022-04775; 2022 Pre-NRC POV DBAI: Incomplete Basis for JOG Class D Valves CF5A and CF5B
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
On September 26, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. K. Zellers and other members of the licensee staff.
On September 2, 2022, the inspectors presented the interim design basis assurance inspection (programs) inspection results to Mr. T. Brown, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
63B
Pipe Stress Analysis Report for Service Water &
Component Cooling Water Piping
209-TR-03
Seismic Evaluation of Neles-Jamesbury 12 QLM-D2CE
Valves SW1424, 1429, 1434
C-CSS-011.03-
001
Seismic Mounting for Accumulators for Valves SW1424,
SW1429, and SW1434
C-CSS-
016.04.040
Seismic Analysis for Valve CC-5095
C-EE-002.01-010
DC Calc - Battery and Charger Sizing, Short Circuit and
Voltage Drop
0, A08
C-EE-006.01-026
Voltage Drop for GL 89-10 Valve Operators
C-ME-011.01-
105
Maximum DP for Valves SW1424, SW1429, and SW1434
C-ME-011.01-
139
Component Level Review Calculation for AOVs
SW1424/1429/1434
C-ME-016.04-
007
EN-DP-01092 Calculation for CC5095 and CC5096
C-ME-016.04-
014
MOV Thrust/Torque Calculation for CC5095
C-ME-016.04-
031
Maximum Expected Differential Pressure for Valves
CC-1467 and CC-1469
C-ME-016.04-
034
System Level Review for Davis-Besse Component
Cooling Water System Air Operated Valves
C-ME-016.04-
035
Component Level Review Calc for AOV CC1467/1469
C-ME-016.04-
037
Component Level Review Calc for AOV CC1495
C-ME-049.02-
28
MOV Thrust / Thrust Calculation for DH1A and DH1B
C-ME-050.01-
004
Component Level Review Calculation for AOV
MS5889A/B
71111.21N.02
Calculations
C-ME-050.01-
Maximum Expected Differential Pressure for Valves
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
006
MS-5889A and MS-5889B
C-ME-050.03-
117
Limiting Differential Pressure for AF3870 and AF3872
0, A01-A03
C-ME-050.03-
20
MOV Thrust / Torque for AF3870
C-ME-050.03-
130
PPM Analysis for AF3869, AF3870, AF3871 and AF3872
C-ME-051.01-
084
MOV Thrust / Torque Calculation for CF5A and CF5B
C-ME-083.01-
238
Maximum Expected Differential Pressure for Valves
MS100 and MS101
C-ME-083.01-
240
Component Level Review Calculation for MS100/101
C-ME-083.01-
245
Accumulator Sizing Calc for AOV MS 100/101, ICS 11A/B,
and SP13AI-3B1-3
C-ME-099.16-
006
Weak Link Calculation - Velan Valves
C-ME-099.16-
007
Thrust/Torque Calculation Methodologies for Limitorque
Motor Operated Valves (MOV)
C-NSA-000.00-
2
AFW System Model
0, A01-A03
C-NSA-050.03-
29
AFW Recirculation and Bypass Flowrates
00, A01-A03
DB-SS-04005
Periodic Test Procedure Main Steam Isolation Valve Air
Leak Test
DR-2955
Design/Seismic/Weak Link Report
A
M-30
Stress Analysis for Air Assisted Accumulator Tanks
D1
MA25105
Design and Seismic Report for Enertech 16 Class 150 SP
R-Series Valve with Bettis NCBA Actuator
MA25107
Design and Seismic Report for Enertech 18 Inch - Class
150 SP R-Series Valve
VF14-B00-080
Air Assist Accumulator Tank for Main Steam Isolation
Valves
Corrective Action
10-79809
Loss of Control Power at ZC6451
07/17/10
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2014-06846
AF3870 Failed to Meet It's Expected Stroke Time
04/15/2014
2017-08882
Auxiliary Feed Pump Turbine #2 Water Accumulation
Greater than Expected when Draining Steam Lines
08/28/2017
22-01484
Complete a Past Operability Review as Requested by
SRO and Document or Attach the Results
03/26/2022
22-03807
SW1434 (Component Cooling Water Heat Exchanger 2
Outlet Temperature Control Valve) - Tested Friction
Higher Than Allowable Value Per C-ME-011.01-139
Component Level Review Calculation
05/03/2022
Documents
22-04775
22 Pre-NRC POV DBAI: Incomplete Basis for JOG
Class D Valves CF5A and CF5B
06/10/2022
22-06356
22 NRC POV DBAI: Missing Documentation Required
by Design Specification
08/17/2022
22-06391
Potential Augmented IST Program Deficiency Identified
08/18/2022
22-06494
22 NRC POV DBAI: Obsolete Information in IST Valve
Bases Document
08/23/2022
22-06524
22 NRC POV DBAI: AFW Valves Incorrectly Identified
as Locked Open in System Description
08/24/2022
22-06709
22 NRC POV DBAI: 0074, CC5095 Thrust Limits on
Valve Data Sheet and PF106 Evaluation
08/31/2022
Corrective Action
Documents
Resulting from
Inspection
22-07141
22 NRC POV DBAI: Non-Conservative Issues Identified
in AFW Discharge MOV DP Calculations
09/20/2022
40102-1
Certified Dimensional Drawing: MS5889
T2
E-624B Sheet 43
Connection Diagram: AFP 2 Modulating Solenoid Valve
FV6451
M-003A
Piping & Instrument Diagram Main Steam and Reheat
System
M-003C
P&ID Main Steam and Reheat System
M-006D
Auxiliary Feedwater System
M-007B
Piping & Instrument Diagram Steam Generator Secondary
System
M-033B
P&ID Decay Heat Train 1
Drawings
M-309AQ-3-1
Target Rock: Installation DWG Modulating Valve Models
09/15/1987
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
M-309AQ-33
Sheet 1
Target Rock: AC/DC - DC Power Converter Assembly with
Indication
M-309AQ-33
Sheet 2
AC/DC - DC Power Converter Assembly with Indication
M-309AQ-4-1
Installation DWG Modulating Valve 87J-001 & 87J-002
09/14/1987
M-309AQ-7-2
Target Rock: Solenoid Operated Valve Energize to Close
03/09/1982
M-525-28
10" - 12" Forged Bolted Bonnet Nuclear Gate Valve
T3
M-658
Motor Operated Valves Sh. 3
M-658, Sheet 1
Motor Operated Valves
PD-423882
Flite - Flow Balanced Stop Valve
T4
SD-042
System Description for Decay Heat Removal
10/21/2020
10-0539-000
Modify Motor Operated Valves AF3869, AF3870, AF3871,
and AF3872
10-0539-002
Modify Motor Operated Valve AF3870
11-0510-001
Install Higher Rate Actuator Spring in HV5889A
(MS5889A)
11-0614-001
CC1467 Valve and Actuator Replacement
14-0306
Update DWG M-0659 for AOV Component Level Review
Calculation Updates
15-0138-000
Target Rock Auxiliary Feedwater Power Supply Isolation
15-0138-001
Target Rock Auxiliary Feedwater Power Supply Isolation
Engineering
Changes
88-0646
Revise Design Documents to Reflect the New Locked
Valve List Developed Per PCAQ 87-0384
01/27/1999
DB-2955
Vendor Report: Velan Design/Seismic/Weak Link Report
03/05/2012
DB-PF-10058
Auxiliary Feedwater Level Control System Response Test
09/09/1988
DB-PF-10059
AFW System Auxiliary Steam Test
Design
Specification M-
2Q
Nuclear Gate, Globe, Check Valves, 2 1/2 Inches and
Larger
Miscellaneous
Design
Specification M-
319BQ
Service Water Nuclear Ball Control Valves
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Design
Specification M-
766Q
Replacement Butterfly Valves with Actuators for: Decay
Heat Exchanger CCW Isolation Valves CC-1467 and
CC-1469 and CCW Auxiliary Building Non-Essential
Isolation Valve CC-1495
EQP: DB1-084
Environmental Qualification Package: Target Rock;
ISTB1
Pump and Valve Basis Document, Volume I - Valve Basis
ISTB3
Pump and Valve Basis Document Volume III Stroke Time
Basis
ISTB3
Pump and Valve Basis Document, Volume III, Stroke Time
Basis
M-213A-00019
Vendor Manual: Velan Valves
M-314-00183
Vendor Manual: Composite Limitorque Instruction
Bulletins SMB, HBCI, SMCI, LM, FC
MA25629
Valve Data Sheet for 16-150 R-Series Wafer Lugged
Butterfly Valves w/ Bettis NCBA830-SR80-CW Actuator
A
MA25633
Valve Data Sheet for 18-150-R Series Wafer Lugged
Butterfly Valves w/ Betttis NCBA930-SR60-CCW-M3
Actuator
A
NOBP-ER-3601D
Motor Operated Valve Program Diagnostic Test
Preparation and Evaluation
PF106
Test Evaluation Sheet for Valve CC5095
08/20/2018
SD-012A
System Description for Main Steam System
SD-015
System Description for Auxiliary Feedwater System
SD-016
System Description for Component Cooling Water System
DB-OP-02528
Instrument Air System Malfunctions
DB-PF-03020
Service Water Train 1 Valve Test
DB-PF-03071
CCW Train 1 Valve Testing
DB-PF-03154
Surveillance Test Procedure AFW Train 1 Valve Testing
DB-PF-09301
Preventive Maintenance for Type SMB and SB Limitorque
Operators
DB-SC-03122
SFAS Component Tests
DB-SP-03160
AFP 2 Quarterly Test
Procedures
DB-SP-03161
AFW Train 2 Control, Interlock and Flow Transmitter Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DB-SP-03444
SFRCS Channel 1 Trip of MS100 and MS101
DB-SP-03445
SFRCS Channel 2 Trip of MS100 and MS101
NOBP-SS-1004
Request for Computer Assistance (RFCA)
NOP-SS-1001
Administrative Program for Computer Related Activity
200417484
SP3152-001 04.000 TRAIN 1
05/31/2012
200432014
AF3870 - Replace Valve/Operator ECP 10-0539-002
07/18/2012
200490447
SP3155-002 05.1&2 P14-1 AFW 1 REFUELING
06/03/2012
200504421
SP3152-001 04.000 AFW TRAIN 1
06/05/2012
200638287
ECP 15-0138-01 Install Target Rock Converter ZC6451
10/31/2016
200683357
PM 1710 MV3870 *INSP* AFP#1 > OTSG#1
09/10/2022
200724730
DB-MV3870: PM 11157 Perform Diagnostic Static Test
05/02/2022
200724730
PM 11157 Perform Diagnostic Static Test
05/02/2018
200728254
AFP 2 Quarterly Test
09/14/2019
200731661
SP3161-001 04.000 AFW TRAIN 2
09/25/2019
200731662
SP3161-002 05.200 K3-2 AFP2 SUCTION TRN2
09/25/2019
200745268
DB-FV6451: Replace Gasket and Damaged / Missing
Bolts
03/17/2018
200756127
SFAS Train 1 Integrated Response Time Test
03/20/2020
200756194
AFP 2 Response Time Test
03/23/2020
200756220
SP3445-001 05.000 SFRCS CH2 Trip 100/101
03/22/2020
200766434
PM 9242 Obtain Diagnostic Data MS100
03/22/2020
200780587
Inspect Fuses for Target Rock Controllers
2/07/2019
200809901
PF3076-001 05.100 Stroke/Check Valve
01/28/2022
200810126
AFP 2 Quarterly Test
2/16/2021
200811764
DH/LPI 1-2 Quarterly Test
04/03/2022
200821371
PF3076-001 05.100 Stroke/Check Valve
04/22/2022
200822533
AFP 2 Response Time Test
04/05/2022
200822560
SP 3445-001 05.000 SFRCS CH 2 Trip 100/101
04/02/2022
200822975
PM 5872 ZC6451 Replace Circuit Boards
04/05/2022
200825033
SW1424 Stroke Time, Position Indication, and Air Drop
Test
05/22/2020
200825397
SW1424 Stroke Time Test
06/13/2022
Work Orders
200825784
DH/LPI 1-2 Quarterly Test
06/07/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
200825815
SP3161-001 04.000 AFW TRAIN 2
06/05/2022
200826055
CC1467 and CC1495 Valve Stroke Test
06/15/2022
200829162
CCW Train 1 Valve Verification
07/20/2022
200830742
SP3160-001 05.00 P14-2 AFP 2 Quarterly
08/25/2022
200880514
Surveillance Test Procedure DB-SP-03137 Decay Heat
Train 2 Pump and Valve Test
DH1A Gate/Globe Valve Static Test Evaluation
08/02/2022