IR 05000346/2023001
| 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
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.
April 26, 2023 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 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:
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
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 Aspect Report Section Not Applicable Severity Level IV NCV 05000346/202300101 Open/Closed Not Applicable 71152A 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-Besse Nuclear Power Station, Unit 1, Strong Winds Result in Ultimate Heat Sink Low Water Level 71153 Closed LER 05000346/2022001-00 LER 2022001-00 for Davis-Besse Nuclear Power Station, Unit 1, Plant Heat up with Inoperable Decay Heat Pump due to Oil Leak Induced by Constant Level Oiler 71153 Closed
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.
REACTOR SAFETY
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) (4 Samples)
- (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,
RADIATION SAFETY
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 Aspect Report Section Not Applicable Severity Level IV NCV 05000346/202300101 Open/Closed Not Applicable 71152A 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
Procedure
Type
Designation
Description or Title
Revision or
Date
RAEP02830
Flooding
RAEP02870
Station Isolation
Procedures
RAEP02880
DBOP06233
Auxiliary Feedwater System
Procedures
DBOP06316
Diesel Generator Operating Procedure
DBBP-OPS0043
Fire Brigade Administration
ECCS Pump Room 12, Rooms 115, Fire Area A04
Auxiliary Feed Pump 2 Room, Room 238, Fire Area F
Diesel Generator 11 Room, Rooms 318 and 318UL, Fire
Area K
Lube Oil Storage Tank Room and Duct Chase Rooms 249
and 249DC, Fire Area II
Oil Drum Storage Area, Room 337, Fire Area II
Fire Plans
Lube Oil Filter Room, Room 347, Fire Area II
DBOP06505
Control Room Emergency Ventilation System Procedure
DBOP06511
Control Room Heating, Ventilation and Air Conditioning
System Procedure
Procedures
DBSP03446
Decay Heat Train 1 Pump and Valve Test (Mode 13)
2300678
Foreign Material Found in DB5353, EDG 1 Duplex Fuel Oil
Strainer
01/31/2023
2300689
Potential FME Issue with DO3671
2/01/2023
Corrective Action
Documents
2300849
SBODG Voltage Regulator Swings
2/07/2023
200821553
Diesel Generator and Auxiliary
01/29/2023
200831601
Diesel Generator and Auxiliary, EDG 1
01/29/2023
200835518
EDG 1 and Auxiliary
2/03/2023
Work Orders
2008885078
Station Blackout Diesel
2/07/2023
Corrective Action
Documents
2301677
Underground Fire Protection Leak Causes Electric Fire
Pump Auto Start
03/07/2023
DBBP-OPS0003
OnLine Risk Management Process
NGDb-00001
OnLine Risk Management
Procedures
NOP-OP1007
Risk Management
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2300219
DBNINI2, Source Range NI Pre-Amp Checks Not in
Tolerance
01/10/2023
2301284
X01 Transformer Oil Leak
2/24/2023
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
Corrective Action
Documents
2301949
High Pressure Injection Pump 1 Motor I/B Bearing High Oil
Level
03/15/2023
Miscellaneous
Westinghouse Instructions for Radiator and Cooler Valves
01/01/1964
200900222
Channel Calibration NI2 RPS Channel 1
01/10/2023
Work Orders
200908057
Transformer Oil Leak from East Side Cooler Fins
2/28/2023
2103768
SBODG Voltage Regulator 2 Did Not Control
05/08/2021
2104582
SBODG Voltage Regulator 1 Green Light Flashing
06/10/2021
Corrective Action
Documents
2104601
SBODG Voltage Regulators 1 and 2 Malfunctions
06/11/2021
Miscellaneous
SW1382
AFP 1 Suction Valve
Procedures
DBPF3291002
200826089
High Pressure Injection Pump 2 AC Lube O
2/09/2023
200831601
Diesel Generator and Auxiliary
2/17/2023
200835518
EDG 1 and Auxiliary
2/03/2023
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
Work Orders
200853375
PM Perform Diagnostic Static Test
01/17/2023
2301227
2302-21 Emergency Response Integrated Drill -
Development of Protective Action Recommendations
2/22/2023
Corrective Action
Documents
2301229
2302-21 Emergency Response Integrated Drill - Periodic
Update
2/22/2023
Miscellaneous
Davis-Besse Hostile Action Based Tabletop
2/02/2023
CR 202107154
Bauer Air Compressor Air Line Degradation
09/23/2021
CR 202109304
Bauer Compressor Storage Tank#4 Gauge Corrosion
2/08/2021
Corrective Action
Documents
CR 202208607
Bauer Air Compressor CO Monitor Failed
11/09/2022
Corrective Action
CR 202300739
NRC Identified: NOP-OP4310, Firehawk M7 Self Contained
2/02/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Breathing Apparatus Overhaul Requirements
Grade D Air Quality Analysis Data 2021 through 2022
Various
Respiratory Protection Qualification Records for Control
Room Personnel on Shift 01/30/2023 Dayshift
Various
Quantitative Respirator Mask Fit Performed 01/30/2023 at
200
01/30/2023
Miscellaneous
22 MSA Firehawk SCBA Annual Tests
08/16/2022
DBHP01308
Respiratory Protection Equipment Inspection and
Maintenance
NOP-OP4302
Issuing Respiratory Protection
NOP-OP4303
Respirator Quantitative Fit Test Portacount Pro 8030
Procedures
NOP-OP4310
Firehawk M7 Self Contained Breathing Apparatus
1011
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
Inventory
2/15/2022
Work Orders
200841710
Firehawk M7 Self Contained Breathing Apparatus
2/15/2022
CR 202202060
Positive Whole-Body Count on S/G Platform Worker
03/12/2022
CR 202204344
Davis Besse TLD Vendor Issues Revised Results for the
Second Half of 2021
05/23/2022
CR 202205349
Global Dosimetry (Mirion) as Found Broken TLD
07/06/2022
Corrective Action
Documents
CR 202205350
Global Dosimetry (Mirion) Communicative Ordering Issues
07/06/2022
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,
16396, 12614, and 27360
08/25/2022
and
08/26/2022
Miscellaneous
Dosimetry Investigation/Dose Assessment for ID 29034
08/26/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOP-OP4201
Routine External Exposure Monitoring
NOP-OP4202
Declared Pregnant Workers
NOP-OP4204
Special External Exposure Monitoring
Procedures
NOP-OP4206
Bioassay Program
Work Orders
200755739
Source Term Determination
2/06/2021
2202550
Decay Heat Pump 2 Pump O/B Constant Oiler Empty
03/23/2022
2203165
Decay Heat Pump 2 - Oil Leak at Outboard Pump Bearing
04/10/2022
Corrective Action
Documents
2204943
Decay Heat Pump 2 Concluded to be Previously Inoperable
in Mode 3 with Outboard Bearing Oil Leak Not Resolved
06/17/2022