IR 05000346/2023001

Integrated Inspection Report 05000346/2023001 and 07200014/2022001

ML23116A173
Person / Time
Site:	Davis Besse
Issue date:	05/01/2023
From:	Billy Dickson NRC/RGN-III/DORS/RPB2
To:	Tony Brown Energy Harbor Nuclear Corp
References
IR 2022001
Download: ML23116A173 (1)

Text

April 26, 2023

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION-INTEGRATED INSPECTION REPORT 05000346/2023001 AND 07200014/2022001

Dear Terry Brown:

On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On April 7, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding 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.

No NRC-identified or self-revealing findings were identified during this inspection.

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. 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, Signed by Dickson, Billy on 04/26/23 Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket Nos. 05000346; 07200014 License No. NPF3

Enclosure:

As stated

Inspection Report

Docket Number: 05000346, 07200014 License Number: NPF-3 Report Number: 05000346/2023001, 07200014/2022001 Enterprise Identifier: I2023001-0057, I-2022-001-0113 Licensee: Energy Harbor Nuclear Corp.

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Inspection Dates: January 01, 2023 to March 31, 2023 Inspectors: S. Bell, Health Physicist R. Cassara, Resident Inspector M. Domke, Reactor Inspector D. Mills, Senior Resident Inspector Approved By: Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Enclosure

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

Low Pressure Injection Pump 2 Outboard Oil Bearing Leak Past Operability Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152A NCV 05000346/202300101 Open/Closed A self-revealed Severity Level IV non-cited violation (NCV) of Technical Specification (TS)limiting condition for operation (LCO) 3.0.4 was identified when the licensee discovered an oil leak on decay heat/low pressure injection (DH/LPI) pump 2 outboard bearing. The licensee determined that DH/LPI pump 2 was not operable when the unit entered Mode 3 on April 4, 2022.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000346/2022002-00 LER 2022002-00 for Davis- 71153 Closed Besse Nuclear Power Station, Unit 1, Strong Winds Result in Ultimate Heat Sink Low Water Level LER 05000346/2022001-00 LER 2022001-00 for Davis- 71153 Closed Besse Nuclear Power Station, Unit 1, Plant Heat up with Inoperable Decay Heat Pump due to Oil Leak Induced by Constant Level Oiler

PLANT STATUS

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

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite 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

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending high winds and a lakeshore flood warning during the week ending March 8, 2023.

71111.04 - Equipment Alignment

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

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

(1) Emergency diesel generator (EDG) 2 while EDG 1 was inoperable due to scheduled maintenance during the week ending February 04, 2023

(2) Auxiliary feedwater (AFW) train 1 while AFW train 2 was inoperable due to performance of a surveillance run during the week ending February 18, 2023.

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) Diesel generator 11 room, rooms 318 and 318UL, fire area K, following scheduled maintenance during the week ending February 4, 2023

(2) Emergency core cooling system pump room 12, room 115, fire area A04, during low pressure injection pump 2 maintenance on February 14, 2023

(3) Lube oil filter room, oil drum storage area, lube oil storage tank room and duct chase, rooms 347, 337, 249, and 249DC, fire area 2, while the room sprinkler system was secured for repairs during the week ending March 11, 2023

(4) AFW train 2 room, room 238, fire area F, during maintenance on AFW 1 during the week ending March 25, 2023

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

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced drill on February 17, 2023.

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 low pressure injection pump train 1 quarterly surveillance, steam feed rupture control system surveillance, and control room emergency ventilation testing during the week ending March 18, 2023.

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

(1) The inspectors observed and evaluated simulator-based training during the week ending March 18, 2023.

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) Station blackout diesel generator voltage regulator and motor operated controller replacement during the week ending January 14, 2023

(2) EDG 1 scheduled maintenance outage during the week ending February 4, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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) Auxiliary feedwater train 2 maintenance outage during the week ending February 18, 2023

(2) Plant risk due to a fire main pipe leak during the week ending March 11, 2023

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) Source range nuclear instrument channel 1 pre-amp out of calibration, CR 2023000219 during the week ending January 21, 2023

(2) Startup transformer 1 oil leak, CR 202301284 during the week ending March 4, 2023

(3) EDG 1 governor oil level found high out of sight, CR 202301638 during the week ending March 11, 2023

(4) High pressure injection pump 1 inboard motor oil bearing oil level high, CR 202301949 during the week ending March 18, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)

(1) Station blackout diesel generator run following replacement of motor operated controller during the week ending January 21, 2023

(2) High pressure injection pump 2 following scheduled maintenance during the week ending January 21, 2023

(3) EDG 1 following maintenance during the week ending February 4, 2023

(4) AFW train 1 following scheduled maintenance during the week ending

March 25, 2023 Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Steam feed rupture control channel 2 pressure input calibration during the week ending January 14, 2023

(2) Station blackout diesel generator monthly test during the week ending January 14, 2023

(3) Emergency ventilation system train 1 monthly test during the week ending

April 1, 2023 Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) Containment personnel air lock testing following containment entry for nuclear instrument pre-amp calibration during the week ending February 25, 2023

71114.06 - Drill Evaluation

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

(1 Sample)

(1) Hostile action-based drill at the emergency operations facility and alternate technical support facility on February 21, 2023

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

The inspectors evaluated:

(1) Hostile action-based tabletop drill on February 2,

71124.03 - InPlant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Unit 1 control room emergency ventilation system

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments:

(1) Internal dose assessment dated March 11, 2022

Special Dosimetric Situations (IP Section 03.04) (3 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker record dated March 21, 2022

(2) Declared pregnant worker record dated August 01, 2021

(3) Skin dose assessment record dated March 09,

OTHER ACTIVITIES-BASELINE

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

(1) Decay heat/low pressure injection pump 2 shaft seal oil leaks during refuel outage

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000346/2022002-00 for Davis-Besse Nuclear Power Station, Unit 1, Strong Winds Result in Ultimate Heat Sink Low Water Level. The inspection conclusions associated with this LER are documented in Inspection Report 05000346/2022004 under Inspection Results Section 03.04. This LER is Closed.

(2) LER 05000346/2022001 Plant Heat up with Inoperable Decay Heat Pump due to Oil Leak Induced by Constant Level Oiler (ML22228A152). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71152. This LER is Closed.

INSPECTION RESULTS

Low Pressure Injection Pump 2 Outboard Oil Bearing Leak Past Operability Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71152A Applicable NCV 05000346/202300101 Applicable Open/Closed A self-revealed Severity Level IV non-cited violation (NCV) of Technical Specification (TS)limiting condition for operation (LCO) 3.0.4 was identified when the licensee discovered an oil leak on decay heat/low pressure injection (DH/LPI) pump 2 outboard bearing. The licensee determined that DH/LPI pump 2 was not operable when the unit entered Mode 3 on April 4, 2022.

Description:

On March 23, 2022, while shut down for a refueling outage, an oil leak on decay heat/low pressure injection (DH/LPI) pump 2 outboard pump bearing was discovered. The licensee removed the pump from service and performed repairs including replacement of the outboard bearings and oil seals. The licensee performed several runs of the pump including a successful post maintenance test and no further oil leakage was noted. On April 4, 2022, the unit was started up and entered Mode 3. On April 6, 2022, the unit was shut down to allow repairs to be performed on a malfunctioning control rod drive mechanism. Once the unit exited Mode 3, DH/LPI pump 2 was placed in service to cool down the plant.

When DH/LPI pump 2 was placed in service, a new oil leak from the outboard bearing was identified. The licensee performed a past operability review of DH/LPI pump 2 and determined that new oil leak indicated that the pump was not operable when the unit entered Mode 3 on April 4, 2022.

Davis-Besse unit 1 TS LCO 3.0.4 states that "when an LCO is not met, entry into an applicable mode or other specified condition is not permitted unless the associated actions to be entered permit continued operation in the mode or other specified conditions for an unlimited period time." TS LCO 3.5.2 states, "two emergency core cooling system trains shall be operable in Modes 1, 2, and 3" and with DH/LPI pump 2 inoperable, condition A.1 requires "the LPI subsystem be restored to operable status in 7 days." This TS LCO was not met prior to transitioning to Mode 3 on April 4, 2022.

Corrective Actions: The licensee repaired the DH/LPI pump by rebuilding it with new outboard bearings, oil sleeve, oil slinger ring, and vring seal to correct the leakage. An engineering evaluation supported operation with the outboard bearing constant level oiler maintained empty to prevent overfeeding the bearing and possibly initiating a new oil leak.

Corrective Action References: LER 2022001-00, CR 202203165, CR 202202550, CR 202204943

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency. Prior to entering Mode 3 on April 4, the licensee took reasonable actions to correct the oil leak that was discovered on March 23.

These actions included replacement of the outboard bearing, oil slinger ring, and oil seal, vendor verification of oil level setting, and engineering analysis to allow operation of the pump with an empty constant level oiler. The licensee additionally ran the pump multiple times including a successful post maintenance test to verify correct operation of DH/LPI pump 2.

Enforcement:

Severity: This violation is characterized as a Severity Level IV NCV based on its similarity to SL IV example 6.1.d.1 in the Enforcement Policy. The inspectors also reviewed NRC Enforcement Policy, Section 2.2.1, "Factors Affecting Assessment of Violations," which states in part, in determining the appropriate enforcement response to a violation, the NRC considers, whenever possible, risk information in assessing the safety or security significance of violations and assigning severity levels. The inspectors determined the issue to be of very low safety significance because DH/LPI pump was not inoperable in Mode 3 for longer than the 7-day TS 3.5.2 condition A.1 LCO.

Violation: Davis Besse Nuclear Station, unit 1 TS Section 3.0, 'LCO Applicability', subsection LCO 3.0.4, requires, in part, when an LCO is not met, entry into a mode or other specified condition in the applicability shall only be made when the associated actions to be entered permit continued operation in the mode or other specified condition in the applicability for an unlimited period of time. Contrary to the above, on April 4, 2022, unit 1 entered a TS 3.5.2 applicable mode when LCO TS 3.5.2 required actions were not met.

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 April 7, 2023, the inspectors presented the integrated inspection results to Terry Brown, Site Vice President, and other members of the licensee staff.

On March 1, 2023, the inspectors presented the radiation protection baseline inspection results to A. Filipiak, Manager, Radiation Protection and Chemistry, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures RAEP02830 Flooding 6

RAEP02870 Station Isolation 7

RAEP02880 Internal Flooding 4

71111.04 Procedures DBOP06233 Auxiliary Feedwater System 45

DBOP06316 Diesel Generator Operating Procedure 70

71111.05 Fire Plans DBBP-OPS0043 Fire Brigade Administration 0

PFP-AB115 ECCS Pump Room 12, Rooms 115, Fire Area A04 6

PFP-AB238 Auxiliary Feed Pump 2 Room, Room 238, Fire Area F 5

PFP-AB318 Diesel Generator 11 Room, Rooms 318 and 318UL, Fire 8

Area K

PFP-TB249 Lube Oil Storage Tank Room and Duct Chase Rooms 249 5

and 249DC, Fire Area II

PFP-TB337 Oil Drum Storage Area, Room 337, Fire Area II 3

PFP-TB347 Lube Oil Filter Room, Room 347, Fire Area II 4

71111.11Q Procedures DBOP06505 Control Room Emergency Ventilation System Procedure 22

DBOP06511 Control Room Heating, Ventilation and Air Conditioning 20

System Procedure

DBSP03446 Decay Heat Train 1 Pump and Valve Test (Mode 13) 12

71111.12 Corrective Action 202300678 Foreign Material Found in DB5353, EDG 1 Duplex Fuel Oil 01/31/2023

Documents Strainer

2300689 Potential FME Issue with DO3671 02/01/2023

2300849 SBODG Voltage Regulator Swings 02/07/2023

Work Orders 200821553 Diesel Generator and Auxiliary 01/29/2023

200831601 Diesel Generator and Auxiliary, EDG 1 01/29/2023

200835518 EDG 1 and Auxiliary 02/03/2023

2008885078 Station Blackout Diesel 02/07/2023

71111.13 Corrective Action 202301677 Underground Fire Protection Leak Causes Electric Fire 03/07/2023

Documents Pump Auto Start

Procedures DBBP-OPS0003 OnLine Risk Management Process 17

NGDb-00001 OnLine Risk Management 18

NOP-OP1007 Risk Management 37

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Corrective Action 202300219 DBNINI2, Source Range NI Pre-Amp Checks Not in 01/10/2023

Documents Tolerance

2301284 X01 Transformer Oil Leak 02/24/2023

2301496 Oil Leak from Startup 02 Transformer 03/02/2023

2301638 EDG 1 Governor Oil Sight Glass Level High 03/06/2023

2301638 EDG 1 Governor Oil Sight Glass Level High 03/06/2023

2301949 High Pressure Injection Pump 1 Motor I/B Bearing High Oil 03/15/2023

Level

Miscellaneous Westinghouse Instructions for Radiator and Cooler Valves 01/01/1964

Work Orders 200900222 Channel Calibration NI2 RPS Channel 1 01/10/2023

200908057 Transformer Oil Leak from East Side Cooler Fins 02/28/2023

71111.24 Corrective Action 202103768 SBODG Voltage Regulator 2 Did Not Control 05/08/2021

Documents 202104582 SBODG Voltage Regulator 1 Green Light Flashing 06/10/2021

2104601 SBODG Voltage Regulators 1 and 2 Malfunctions 06/11/2021

Miscellaneous SW1382 AFP 1 Suction Valve 0

Procedures DBPF3291002 14

Work Orders 200826089 High Pressure Injection Pump 2 AC Lube O 02/09/2023

200831601 Diesel Generator and Auxiliary 02/17/2023

200835518 EDG 1 and Auxiliary 02/03/2023

200842901 ACH 2 Diff Press FA Norm 01/11/2023

200843270 Monthly Test DBODG 01/11/2023

200847277 AFP 1 Quarterly Test 03/22/2023

200847729 Vibration Readings Required 1st and 3rd Quarters 03/27/2023

200853375 PM Perform Diagnostic Static Test 01/17/2023

71114.06 Corrective Action 202301227 202302-21 Emergency Response Integrated Drill - 02/22/2023

Documents Development of Protective Action Recommendations

2301229 202302-21 Emergency Response Integrated Drill - Periodic 02/22/2023

Update

Miscellaneous Davis-Besse Hostile Action Based Tabletop 02/02/2023

71124.03 Corrective Action CR 202107154 Bauer Air Compressor Air Line Degradation 09/23/2021

Documents CR 202109304 Bauer Compressor Storage Tank#4 Gauge Corrosion 12/08/2021

CR 202208607 Bauer Air Compressor CO Monitor Failed 11/09/2022

Corrective Action CR 202300739 NRC Identified: NOP-OP4310, Firehawk M7 Self Contained 02/02/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Breathing Apparatus Overhaul Requirements

Resulting from

Inspection

Miscellaneous Grade D Air Quality Analysis Data 2021 through 2022 Various

Respiratory Protection Qualification Records for Control Various

Room Personnel on Shift 01/30/2023 Dayshift

Quantitative Respirator Mask Fit Performed 01/30/2023 at 01/30/2023

200

22 MSA Firehawk SCBA Annual Tests 08/16/2022

Procedures DBHP01308 Respiratory Protection Equipment Inspection and 22

Maintenance

NOP-OP4302 Issuing Respiratory Protection 5

NOP-OP4303 Respirator Quantitative Fit Test Portacount Pro 8030 7

NOP-OP4310 Firehawk M7 Self Contained Breathing Apparatus 1011

Work Orders 200762271 Control Room Emergency Ventilation System Train 1 Tests 08/16/2021

200831145 Respiratory Protection Equipment Monthly Inventory 08/15/2022

200831556 Firehawk M7 Self Contained Breathing Apparatus 08/21/2022

200841634 Monthly Respiratory Protection Equipment Monthly 12/15/2022

Inventory

200841710 Firehawk M7 Self Contained Breathing Apparatus 12/15/2022

71124.04 Corrective Action CR 202202060 Positive Whole-Body Count on S/G Platform Worker 03/12/2022

Documents CR 202204344 Davis Besse TLD Vendor Issues Revised Results for the 05/23/2022

Second Half of 2021

CR 202205349 Global Dosimetry (Mirion) as Found Broken TLD 07/06/2022

CR 202205350 Global Dosimetry (Mirion) Communicative Ordering Issues 07/06/2022

Miscellaneous Internal Dose Evaluation 03/11/2022

Area TLD Dosimetry Data 2019 through 2021 Various

Declared Pregnant Worker Record 03/21/2022

Declared Pregnant Worker Record 08/18/2021

TLD/SRD Deviation Investigation Reports for IDs 24243, 08/25/2022

16396, 12614, and 27360 and

08/26/2022

Dosimetry Investigation/Dose Assessment for ID 29034 08/26/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures NOP-OP4201 Routine External Exposure Monitoring 5

NOP-OP4202 Declared Pregnant Workers 2

NOP-OP4204 Special External Exposure Monitoring 12

NOP-OP4206 Bioassay Program 4

Work Orders 200755739 Source Term Determination 12/06/2021

71152A Corrective Action 202202550 Decay Heat Pump 2 Pump O/B Constant Oiler Empty 03/23/2022

Documents 202203165 Decay Heat Pump 2 - Oil Leak at Outboard Pump Bearing 04/10/2022

2204943 Decay Heat Pump 2 Concluded to be Previously Inoperable 06/17/2022

in Mode 3 with Outboard Bearing Oil Leak Not Resolved

13