ML050480651
| ML050480651 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/17/2005 |
| From: | Lanksbury R Division of Reactor Safety III |
| To: | Richard Anderson FirstEnergy Nuclear Operating Co |
| References | |
| 50-440/04-301, IR-04-301 50-440/04-301 | |
| Download: ML050480651 (38) | |
See also: IR 05000440/2004301
Text
February 11, 2005
EA 03-214
Mr. Mark B. Bezilla
Vice President-Nuclear, Davis-Besse
FirstEnergy Nuclear Operating Company
Davis-Besse Nuclear Power Station
5501 North State Route 2
Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION
NRC INTEGRATED INSPECTION REPORT 05000346/2004016
Dear Mr. Bezilla:
On December 31, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report
documents the inspection findings which were discussed on January 6, 2005, with members
of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
For the entire inspection period, the Davis-Besse Nuclear Power Station was under the
Inspection Manual Chapter (IMC) 0350 Process. The Davis-Besse Oversight Panel assessed
inspection findings and other performance data to determine the required level and focus of
followup inspection activities and any other appropriate regulatory actions. Even though the
Reactor Oversight Process had been suspended at the Davis-Besse Nuclear Power Station, it
was used as guidance for inspection activities and to assess findings.
Based on the results of this inspection, the NRC has determined that a violation of NRC
requirements occurred. The report documents one NRC identified finding of very low safety
significance which involved a violation of NRC requirements. However, because the violation
was of very low safety significance and because it was entered into your corrective action
program, the NRC is treating this issue as a Non-Cited Violation consistent with Section VI.A
of the NRC Enforcement Policy.
If you contest the severity of a Non-Cited Violation, 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
M. Bezilla
-2-
copies to the Regional Administrator Region III, 2443 Warrenville Road, Suite 210, Lisle, IL
60532-4352; the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington DC 20555-001; and the NRC Resident Inspector at Davis-Besse.
The inspectors performed enhanced inspection activities in the 2nd, 3rd, and 4th quarters of
CY2004 associated with the Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstone Performance Indicators. Based on the results of these inspections and evaluation
of the data you submitted for each of these Performance Indicators, the Oversight Panel has
determined that the Performance Indicators will be returned to normal monitoring under the
baseline inspection program.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Steven A. Reynolds, Chairman
Davis-Besse Oversight Panel
Docket No. 50-346
License No. NPF-3
Enclosure:
Inspection Report 05000346/2004016
w/Attachment: Supplemental Information
cc w/encl:
The Honorable Dennis Kucinich
G. Leidich, President - FENOC
J. Hagan, Senior Vice President
Engineering and Services, FENOC
L. Myers, Chief Operating Officer, FENOC
Plant Manager
Manager - Regulatory Compliance
M. OReilly, Attorney, FirstEnergy
Ohio State Liaison Officer
R. Owen, Administrator, Ohio Department of Health
Public Utilities Commission of Ohio
President, Board of County Commissioners
of Lucas County
J. Papcun, President, Ottawa County Board of Commissioners
D. Lochbaum, Union Of Concerned Scientists
J. Riccio, Greenpeace
P. Gunter, N.I.R.S.
DOCUMENT NAME: C:\\Karen's Documents\\ML050450453.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with DB0350
attachment/enclosure "N" = No copy
OFFICE
RIII
RIII
NAME
CLipa:dtp
SReynolds
DATE
02/11/05
02/11/05
OFFICIAL RECORD COPY
M. Bezilla
-3-
ADAMS Distribution:
GYS
SPS1
RidsNrrDipmIipb
GEG
KGO
CST1
CAA1
C. Pederson, DRS (hard copy - IRs only)
DRPIII
DRSIII
PLB1
JRK1
WDL (IRs only)
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No:
50-346
License No:
Report No:
Licensee:
FirstEnergy Nuclear Operating Company (FENOC)
Facility:
Davis-Besse Nuclear Power Station
Location:
5501 North State Route 2
Oak Harbor, OH 43449-9760
Dates:
November 14 through December 31, 2004
Inspectors:
S. Thomas, Senior Resident Inspector
J. Rutkowski, Resident Inspector
M. Salter-Williams, Resident Inspector
J. Jacobson, Senior Engineer
J. House, Senior Radiation Specialist
H. Peterson, Senior Operations Engineer
R. Walton, Operations Engineer
Approved by:
Christine A. Lipa, Chief
Branch 4
Division of Reactor Projects
Enclosure
1
SUMMARY OF FINDINGS
IR 05000346/2004016; 11/14/2004-12/31/2004; Davis-Besse Nuclear Power Station; Other
Activities.
This report covers a 7 week period of resident inspection. The inspection was conducted by
regional inspectors and resident inspectors. One Green finding associated with one Non-Cited
violation was identified. The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination
Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 3, dated July 2000.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
Green. The inspectors identified a finding of very low safety significance for the
licensees failure to take timely corrective action to remove visible corrosion on several
terminal connections on the stations safety-related 2P and 2N batteries. The primary
cause of this finding was related to the cross-cutting area of problem identification and
resolution.
The inspectors determined that the finding was more than minor because it impacted
the Mitigating Systems cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. This issue was determined to be of very low safety significance
because there were no documented cases of any of the affected battery cells terminal
resistance measurements in excess of 150 micro-ohms. This was considered to be a
Non-Cited Violation of 10CFR 50, Appendix B, Criterion XVI. (Section 4OA5)
B.
Licensee Identified Findings
None
Enclosure
2
REPORT DETAILS
Summary of Plant Status
At the beginning of the inspection period, the plant was operating at approximately 100 percent
power. During this inspection period, brief planned power reductions of less than 10 percent
occurred on two occasions (November 21, 2004, and December 19, 2004) to support planned
testing. On each occasion, the testing was completed and power was restored to
approximately 100 percent. The plant operated at approximately 100 percent power for the
remainder of the inspection period.
For the entire inspection period, the Davis-Besse Nuclear Power Station was under the
IMC 0350 Process.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R05
Fire Protection (71111.05Q)
a.
Inspection Scope
The inspectors conducted fire protection inspections focused on the availability,
accessibility, and condition of fire fighting equipment; the control of transient
combustibles; and the condition and status of installed fire barriers. The inspectors
selected fire areas for inspection based on their overall contribution to internal fire risk,
as documented in the Individual Plant Examination of External Events, and their
potential to impact equipment which could initiate a plant transient. Inspectors
determined whether fire hoses and extinguishers were in their designated locations and
available for immediate use; fire detectors and sprinklers were unobstructed; transient
material loading was within the analyzed limits; and fire doors, dampers, and penetration
seals were in satisfactory condition.
The following area was inspected and constitutes one sample:
Decay Heat Cooler Room and Hatch Area
b.
Findings
No findings of significance were identified.
Enclosure
3
1R11
Licensed Operator Requalification (71111.11)
.1
Facility Operating History
a.
Inspection Scope
The inspectors reviewed the plants operating history from October 2002 through
October 2004, to assess whether the Licensed Operator Requalification Training
(LORT) program had addressed operator performance deficiencies noted at the plant.
b.
Findings
No findings of significance were identified.
.2
Licensee Requalification Examinations
a.
Inspection Scope
The inspectors performed a biennial inspection of the licensees LORT program. The
inspectors reviewed the current year requalification biennial written examinations and
annual operating test material to evaluate general quality, construction, and difficulty
level. The biennial written examination material consisted of forty questions in a
multiple-choice format. The questions addressed plant and control systems,
administrative controls, and procedural limits. The operating test material consisted of
dynamic simulator scenarios and job performance measures (JPMs). The inspectors
reviewed the methodology for developing the examinations, including the LORT
program 2-year sample plan, probabilistic risk assessment insights, previously identified
operator performance deficiencies, and plant modifications. The inspectors assessed
the level of examination material duplication during the current year annual
examinations. The inspectors also interviewed members of the licensees management
and training staff, and discussed various aspects of the examination development.
b.
Findings
No findings of significance were identified.
.3
Licensee Administration of Requalification Examinations
a.
Inspection Scope
The inspectors observed administration of the requalification operating test to assess
the licensees effectiveness in conducting the test and to assess the facility evaluators
ability to determine adequate performance using objective, measurable performance
standards. The inspectors evaluated, in parallel with the facility evaluators, the
performance of seven licensed operators for one operating shift crew during two
dynamic simulator scenarios. The shift crew was divided into two 5-person simulator
crews for evaluation purposes, with the two remaining individuals rotating into their
respective licensed positions during the second scenario. Each crew consisted of three
Enclosure
4
senior reactor operators and two reactor operators. In addition, the inspectors observed
licensee evaluators administer five JPMs to a select number of operators. The
inspectors observed the training staff personnel administer the operating test, including
pre-examination briefings, observations of operator performance, and individual and
crew evaluations after the dynamic simulator scenarios.
b.
Findings
No findings of significance were identified.
.4
Examination Security
a.
Inspection Scope
The inspectors observed and reviewed the licensees overall licensed operator
requalification examination security program related to examination physical security
(e.g., access restrictions and simulator considerations) and integrity (e.g., predictability
and bias). The inspectors also reviewed the facility licensees examination security
procedure, any corrective actions related to past or present examination security
problems at the facility, and the implementation of security and integrity measures
(e.g., security agreements, sampling criteria, bank use, and test item repetition)
throughout the examination process.
b.
Findings
No findings of significance were identified.
.5
Licensee Training Feedback System
a.
Inspection Scope
The inspectors assessed the methods and effectiveness of the licensees processes for
revising and maintaining its LORT program up to date, including the use of feedback
from plant events and industry experience information. The inspectors interviewed
licensee personnel (operators, instructors, and management) and reviewed applicable
procedures. In addition, the inspectors reviewed the licensees quality assurance
oversight activities, including licensee training department self-assessment reports. The
inspectors evaluated the licensees ability to assess the effectiveness of its LORT
program and their ability to implement appropriate corrective actions.
b.
Findings
No findings of significance were identified.
Enclosure
5
.6
Licensee Remedial Training Program
a.
Inspection Scope
The inspectors assessed the adequacy and effectiveness of remedial training conducted
since the previous annual requalification examinations. The inspectors reviewed the
remedial training documentation for one individual who demonstrated unsatisfactory
performance during the current biennial written examination and the subsequent
post-remedial re-examination administered the previous week. The inspectors also
reviewed the remedial training package for one individual who demonstrated
unsatisfactory performance during the current annual operating test. The inspectors
reviewed the training package to determine whether performance and knowledge
weaknesses identified during the annual examination were adequately addressed. The
inspectors also reviewed remedial training procedures and records to determine whether
the subsequent re-evaluation was properly completed prior to returning the individuals to
licensed duties.
b.
Findings
No findings of significance were identified.
.7
Conformance with Operator License Condition
a.
Inspection Scope
The inspectors evaluated facility and individual operator license conformance with the
requirements of 10 CFR Part 55. The inspectors reviewed the licensees program for
maintaining active operator licenses to assess compliance with 10 CFR 55.53(e) and (f).
The inspectors reviewed the licensees procedural compliance and the process for
tracking on-shift hours for licensed operators. The inspectors also conducted reviews to
determine whether proficiency watch-standing hours were credited to the correct control
room positions in accordance with Technical Specifications. The inspectors reviewed
six licensed operator medical records to ensure compliance with 10 CFR 55.21 and
55.25, and medical standards delineated in ANSI/ANS-3.4. In addition, the inspectors
reviewed the licensees LORT program to assess compliance with the requalification
program requirements prescribed by 10 CFR 55.59(c).
b.
Findings
No findings of significance were identified.
.8
Conformance with Simulator Requirements
a.
Inspection Scope
The inspectors assessed the adequacy of the licensees simulation facility (simulator) for
use in operator licensing examinations and for satisfying experience requirements as
prescribed in 10 CFR 55.46, Simulation Facilities. The inspectors reviewed a sample
Enclosure
6
of simulator performance test records (i.e., transient tests, malfunction tests, and reactor
core performance tests), simulator work order records, and the process for ensuring
continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The
inspectors reviewed and evaluated the discrepancy process to ensure that simulator
fidelity was maintained. This was accomplished by a review of discrepancies noted
during the inspection to determine whether they were entered into the licensees
corrective action system and by an evaluation to verify that the licensee adequately
captured simulator problems and that corrective actions were performed and completed
in a timely fashion commensurate with the safety significance of the item (prioritization
scheme). Open simulator discrepancies were reviewed for importance relative to impact
on 10 CFR 55.45 and 55.59 operator actions as well as nuclear and thermal hydraulic
operating characteristics. Closed simulator discrepancies were reviewed for the last
12 months for timeliness of resolution. The inspectors reviewed the licensees recent
simulator core modeling performance testing to assess the adequacy of the simulator to
replicate the actual reactor plant cores performance characteristics. The inspectors
also conducted interviews with the licensees simulator configuration control personnel
and completed the checklist described in Appendix C of NRC Inspection Procedure (IP) 71111.11 to evaluate whether or not the licensees plant-referenced simulator was
operating adequately as required by 10 CFR 55.46 (c) and (d).
b.
Findings
No findings of significance were identified.
.9
Biennial Written Examination and Annual Operating Test Results
a.
Inspection Scope
The inspectors reviewed the overall pass/fail results of the comprehensive biennial
written tests, the annual job performance measure operating tests, and the annual
simulator operating tests (required to be given per 10 CFR 55.59(a)(2)) administered
by the licensee during calendar year 2004. The overall results were compared with the
significance determination process in accordance with NRC Manual Chapter 0609,
Appendix IProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix I" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Operator Requalification Human Performance Significance Determination
Process (SDP). Year 2004 was the second year of the licensees 24-month training
program. This represents one sample.
b.
Findings
No findings of significance were identified.
1R12
Maintenance Effectiveness (71111.12)
a.
Inspection Scope
The inspectors evaluated the licensees handling of performance issues related to the
auxiliary feedwater system. This inspection consisted of evaluating the following
licensee activities:
Enclosure
7
work scheduling practices, including consideration of risk of transient initiation
while performing work on operating components;
use of the condition report process and WO notification system in identifying
deficiencies and issues with the equipment;
problem solving and issue resolution associated with the failures and
degradations of components associated with the system;
that maintenance activities on the components had been assigned appropriate
risk classification;
that corrective actions for the long-term reliability were appropriate;
that pump performance trends were appropriate for normal pump testing
frequency;
that alert and action levels, per the inservice testing program, were appropriately
considered in reviewing auxiliary feedwater pump performance;
that short-term corrective actions were appropriate for deficiencies with potential
to become operator workarounds or the potential to become transient initiators;
and
that maintenance rule system status determination was appropriate for the
equipments recent history and current open work items.
The inspectors also observed that the licensee was aware of the small performance
margins available in the system and was developing plans for system improvements
designed to increase the available margins.
This constitutes one sample.
b.
Findings
No findings of significance were identified.
1R15
Operability Evaluations (71111.15)
a.
Inspection Scope
Condition Report 04-07274 discussed instrument inaccuracies which were not
accounted for during bench testing of snubbers. These inaccuracies could have
potentially resulted in nine snubbers exceeding their Technical Specification
requirements for bleed rates and lockup velocities. The licensee reviewed their as-
found data and determined that eight of the snubbers were within the technical
specification operability range even when taking instrument inaccuracies into account.
Based upon their review of the as-found data for snubber DB-SNT20, the licensee
determined that the lockup velocity for the snubber could potentially be outside of its
Technical Specification acceptance criteria and as a result required an operability
evaluation. The inspectors reviewed Operability Evaluation 2004-0027 Revision 00
which discussed potential operability issues for snubber DB-SNT20, which is a 2 1/2 inch
Grinnel snubber installed on the Emergency Diesel Generator 1-2 exhaust line. This
operability evaluation was reviewed to determine whether the operability of the
component was justified. The inspectors compared the operability and design criteria in
the appropriate sections of the Technical Specifications and USAR to the licensees
Enclosure
8
evaluations presented on the issue to verify that the component was operable. Where
compensatory measures were necessary to maintain operability, the inspectors
reviewed the documents listed at the end of the report to determine whether the
measures were in place, would work as intended, and were properly controlled.
This constitutes one sample.
b.
Findings
No findings of significance were identified.
1R16
Operator Work-Arounds (71111.16)
a.
Inspection Scope
The inspectors reviewed all of the existing operator workarounds and control room
deficiencies to determine whether the cumulative conditions had a significant impact on
plant risk or on the operators ability to respond to a transient or an accident. This
involved reviewing the entire list of operator workarounds, control room deficiencies, and
turnover sheets. In addition, the inspectors interviewed operators and staff to determine
whether that the licensee had appropriately classified the workarounds and deficiencies
for significance, that the workarounds were achievable, and that the licensee had made
or planned timely and appropriate corrective actions to resolve the deficiency
responsible for the workaround. In addition to evaluating the individual impact of each
operator workaround, the inspector evaluated the cumulative affect of all workarounds
on plant safety.
This constitutes one sample.
b.
Findings
No findings of significance were identified.
1R22
Surveillance Testing (71111.22)
a.
Inspection Scope
On November 16, 2004, the inspectors observed performance of DB-SS-03091, Motor
Driven Feed Pump Quarterly Test, Revision 06. The inspectors reviewed the test
procedure and Technical Specifications to determine whether the test met the Technical
Specification frequency requirements; operability and availability were properly treated
and recorded in the unit log; the test was conducted in accordance with the procedures,
including establishing the proper plant conditions and prerequisites; and the test
acceptance criteria were met.
This constitutes one sample.
Enclosure
9
b
Findings
No findings of significance were identified.
2.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1
Plant Walkdowns and Radiation Work Permit Reviews
a.
Inspection Scope
The inspectors identified radiologically significant work areas within a Technical
Specification locked high radiation area (LHRA) and also identified potential airborne
radioactivity areas in the containment building. The inspectors reviewed the radiation
work permit (RWP) and work package, which included radiological controls and surveys
of these areas, to determine if radiological controls including surveys, air sampling data,
postings, and barricades were adequate. These reviews and observations, along with
those contained in Section 2OS1(.1) of Inspection Report 50-346/04-015 represented
one sample.
The inspectors observed work activities in the LHRA and potential airborne radioactivity
areas and reviewed the surveys for these areas in order to determine whether the
prescribed RWP, procedures, and engineering controls were in place; licensee surveys
and postings were complete and accurate; and air samplers were properly located.
These reviews and observations, along with those contained in Section 2OS1(.1) of
Inspection Report 50-346/04-015 represented one sample.
The inspectors reviewed the RWP and associated radiological controls used to access
the containment building, and evaluated the work control instructions and control
barriers that were specified in order to determine whether the controls and requirements
were met. Site technical specification requirements for high radiation areas and LHRAs
were used as standards for the necessary barriers. Electronic dosimeter alarm set
points for both integrated dose and dose rate were evaluated for conformity with survey
indications and plant policy. The inspectors determined whether the pre-job briefing
emphasized to workers the actions required when their electronic dosimeters noticeably
malfunctioned or alarmed. These reviews and observations, along with those contained
in Section 2OS1(.1) of Inspection Report 50-346/04-015 represented one sample.
b.
Findings
No findings of significance were identified.
Enclosure
10
.2
Job-In-Progress Reviews
a.
Inspection Scope
The inspectors accompanied licensee personnel during an at power containment entry
and observed work activities in LHRAs, potential airborne radioactivity areas, and high
radiation areas that presented the greatest radiological risk to workers. Radiological
conditions involved neutron and gamma streaming that produced radiological gradients
which could result in a high collective dose to workers.
The inspectors reviewed radiological job requirements including RWP and work
procedure requirements, and attended as low as is reasonably achievable (ALARA) job
briefings. Job performance was observed with respect to these requirements to verify
that radiological conditions in the work area were adequately communicated to workers
through pre-job briefings and postings. These reviews and observations, along with
those contained in Section 2OS1(.3) of Inspection Report 50-346/04-015 represented
one sample.
The inspectors also verified the adequacy of radiological controls including required
radiation, contamination, and airborne surveys for entry into a LHRA; radiation
protection job coverage which included surveillance for both gamma and neutron
radiation and streaming paths; and contamination controls. These reviews and
observations, along with those contained in Section 2OS1(.3) of Inspection
Report 50-346/04-015 represented one sample.
Work in high radiation areas having significant dose rate gradients, both neutron and
gamma, was observed to evaluate the application of dosimetry to effectively monitor
exposure to personnel, and to verify that licensee controls were adequate. The
inspectors observed radiation protection (RP) technicians coverage of the containment
entry. This involved controlling worker and observer locations relative to radiation
survey data and real time monitoring for both gamma and neutron radiation in order to
maintain personnel radiological exposure ALARA. These reviews and observations
represented one sample.
b.
Findings
No findings of significance were identified.
.3
Radiation Worker Performance
a.
Inspection Scope
During job performance observations, the inspectors evaluated radiation worker
performance with respect to stated radiation protection work requirements. The
inspectors also evaluated whether workers were aware of the significant radiological
conditions in their workplace, the RWP controls and limits in place, and that their
performance had accounted for the level of radiological hazards present. These
Enclosure
11
reviews and observations, along with those contained in Section 2OS1(.5) of Inspection
Report 50-346/04-015 represented one sample.
Radiological problem reports, which found that the cause of an event resulted from
radiation worker errors, were reviewed to determine if there was an observable pattern
traceable to a similar cause, and to determine if this perspective matched the corrective
action approach taken by the licensee to resolve the reported problems. These reviews
and observations, along with those contained in Section 2OS1(.5) of Inspection Report
50-346/04-015 represented one sample.
b.
Findings
No findings of significance were identified.
.4
Radiation Protection Technician Proficiency
a.
Inspection Scope
The inspectors observed and evaluated RP technician performance with respect to
RP work requirements. This was done to evaluate whether the technicians were aware
of the radiological conditions in their workplace, the RWP controls and limits in place,
and if their performance was consistent with their training and qualifications with respect
to the radiological hazards and work activities. These reviews and observations, along
with those contained in Section 2OS1(.6) of Inspection Report 50-346/04-015
represented one sample.
Radiological problem reports, which found that the cause of an event was RP technician
error, were reviewed to determine if there was an observable pattern traceable to a
similar cause, and to determine if this perspective matched the corrective action
approach taken by the licensee to resolve the reported problems. These reviews
and observations, along with those contained in Section 2OS1(.6) of Inspection
Report 50-346/04-015 represented one sample.
b.
Findings
No findings of significance were identified.
2OS2 As Low As Is Reasonably Achievable (ALARA) Planning And Controls (71121.02)
.1
Job Site Inspections and ALARA Control
a.
Inspection Scope
The inspectors observed work activities in areas having the potential for significant
radiation exposure levels as well as potential airborne radiological hazards during an at
power containment entry. The licensees use of ALARA controls for these work
activities was evaluated using the following:
Enclosure
12
The licensees use of engineering controls to achieve dose reductions was
evaluated to verify that procedures and controls were consistent with the
licensees ALARA reviews. The use of containment structures to provide
radiation shielding and avoidance of areas of potential radiation (gamma and
neutron) streaming was observed;
During the evolution, personnel were observed to determine if they were utilizing
low dose waiting areas and were effective in maintaining their doses ALARA by
using lower dose areas while traversing areas within the containment building;
and
The inspectors attended the work briefing and observed ongoing work activities
to determine if workers received appropriate on-the-job supervision to ensure the
ALARA requirements were met. This included verification that the first-line job
supervisor ensured that the work activity was conducted in a dose efficient
manner by minimizing work crew size, ensuring that workers were properly
trained, and that proper tools and equipment were available when the job
started.
b.
Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS2
Radioactive Material Processing and Transportation (71122.02)
.1
Radioactive Waste System
a.
Inspection Scope
The inspectors reviewed descriptions of the liquid and solid radioactive waste systems
in the Updated Final Safety Analysis Report (UFSAR). The inspectors reviewed the
2003 effluent release report for information on the types and amounts of radioactive
waste (radwaste) generated and disposed. The inspectors reviewed the scope of the
licensees audit program for the radioactive material processing and transportation
programs to verify that the audit program met the requirements of 10 CFR 20.1101©).
These reviews represented one sample.
b.
Findings
No findings of significance were identified.
Enclosure
13
.2
Radioactive Waste System Walkdowns
a.
Inspection Scope
The inspectors performed walkdowns of the liquid and solid radwaste processing
systems to verify that the systems agreed with the descriptions in the UFSAR and the
Process Control Program, and to assess the material condition and operability of the
systems. The inspectors reviewed the status of radioactive waste process equipment
that was not operational or was abandoned in place, along with the licensees
administrative and physical controls, in order to ensure that the equipment would not
contribute to an unmonitored release path, affect operating systems, or be a source of
unnecessary personnel exposure.
No significant changes had been made to the radwaste processing system since the last
inspection. The inspectors reviewed the current processes for transferring waste resin
and sludge discharges into shipping or disposal containers to determine if appropriate
waste stream mixing and/or sampling procedures were utilized. This included the
methodologies for waste concentration averaging to determine if representative samples
of the waste product were provided for the purposes of waste classification specified in
10 CFR 61.55 for waste disposal. These reviews represented one sample.
b.
Findings
No findings of significance were identified.
.3
Waste Characterization and Classification
a.
Inspection Scope
The inspectors reviewed the licensees radio-chemical sample analysis results for each
of the waste streams, including dry active waste, ion exchange resins, filters, sludge,
and activation products. The inspectors also reviewed the licensees use of scaling
factors to quantify difficult-to-measure radionuclides such as pure alpha or
beta emitters, and isotopes that decay by electron capture. The reviews were
conducted to verify that the licensees program assured compliance with 10 CFR 61.55
and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also
reviewed the licensees waste characterization and classification program to ensure that
the waste stream composition data accounted for changing operational parameters and
thus remained valid between the annual sample analysis updates. These reviews
represented one sample.
b.
Findings
No findings of significance were identified.
Enclosure
14
.4
Shipment Preparation
a.
Inspection Scope
The inspectors were unable to perform detailed observations of shipment preparation
during this inspection. From shipping records, the inspectors were able to verify that
receiving licensees were authorized to receive the shipments and that the requirements
of the transport cask Certificate of Compliance were met.
From limited observations of shipment preparation in the radwaste building and a
review of training materials and records, the inspectors verified that the workers had
adequate skills to accomplish each task and that the shippers were knowledgeable of
the shipping regulations; and that shipping personnel demonstrated adequate skills to
accomplish the package preparation requirements for public transport with respect to
NRC Bulletin 79-19 and 49 CFR Part 172 Subpart H. The inspectors reviewed the
training records of shipping personnel, which included shipment packaging, surveying,
labeling, marking, placarding, vehicle checks, emergency instructions, disposal
manifest, shipping papers provided to the driver, and licensee verification of shipment
readiness. The review was conducted to verify that the licensees training program
provided training consistent with NRC and Department of Transportation requirements.
These reviews represented one sample.
b.
Findings
No findings of significance were identified.
.5
Shipping Records
a.
Inspection Scope
The inspectors reviewed five non-excepted package shipment manifests/documents
completed in 2003 and 2004 to verify compliance with NRC and Department of
Transportation requirements (i.e., 10 CFR Parts 20 and 71, and 49 CFR Parts 172 and
173). This included required emergency response information and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> contact
telephone number. This review represented one sample.
b.
Findings
No findings of significance were identified.
.6
Identification and Resolution of Problems For Radioactive Material Processing and
Transportation
a.
Inspection Scope
The inspectors reviewed condition reports, an audit, and field observations that covered
the period from the last inspection of this area and that addressed deficiencies in the
radioactive waste and radioactive materials shipping program. This was done in order
Enclosure
15
to verify that the licensee had effectively implemented the corrective action program and
that problems were identified, characterized, prioritized and corrected. The inspectors
also verified that the licensee's self-assessment program was capable of identifying and
addressing repetitive deficiencies or significant individual deficiencies that had been
identified in problem identification and resolution.
The inspectors also reviewed corrective action reports from the radioactive material and
shipping programs since the previous inspection, interviewed staff, and reviewed
documents to determine if the following activities were being conducted in an effective
and timely manner commensurate with their importance to safety and risk:
Initial problem identification, characterization, and tracking;
Disposition of operability/reportability issues;
Evaluation of safety significance/risk and priority for resolution;
Identification of repetitive problems;
Identification of contributing causes;
Identification and implementation of effective corrective actions;
Resolution of Non-Cited Violations (NCVs) tracked in corrective action system(s);
and
Implementation/consideration of risk significant operational experience feedback.
These reviews represented one sample.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification (71151)
Cornerstones: Mitigating Systems, Initiating Events
Reactor Safety Strategic Area
.1
Mitigating System Cornerstone Performance Indicator Review
a.
Inspection Scope
The inspectors reviewed the reported data [3rd quarter 2003 to 3rd quarter 2004] for the
following Mitigating System Cornerstone performance indicator:
Safety System Unavailability, Auxiliary Emergency AC Power.
The inspectors used the definitions and guidance contained in Nuclear Energy
Institute 99-02, Regulatory Assessment Indicator Guideline, Revision 2, during the
conduct of this review. The inspectors reviewed station logs and condition reports to
determine the accuracy of the licensees data submission.
Enclosure
16
This constitutes one sample.
b.
Findings
No findings of significance were identified.
.2
Initiating Events Cornerstone Performance Indicator Review
a.
Inspection Scope
The inspectors reviewed the reported data [1st quarter 2004 to 4th quarter 2004] for the
following Initiating Event Cornerstone performance indicators:
Unplanned Scrams per 7000 Critical Hours;
Unplanned Scrams with Loss of Normal Heat Sink; and
Unplanned Power Changes per 7000 Critical Hours
The inspectors used the definitions and guidance contained in Nuclear Energy
Institute 99-02, Regulatory Assessment Indicator Guideline, Revision 2, during the
conduct of this review. The inspectors reviewed station logs and condition reports to
verify the accuracy of the licensees data submission.
This constitutes three samples.
b.
Findings
No findings of significance were identified.
.3
Review of Returning Performance Indicator Monitoring to the Baseline Inspection
Program
The inspectors performed enhanced inspection activities in the 2nd, 3rd, and 4th quarters
of CY2004 associated with the Initiating Events, Mitigating Systems, and Barrier
Integrity Cornerstone Performance Indicators. Based on the results of these inspections
and evaluation of the licensees submitted data, the Oversight Panel has determined
that the PIs will be returned to normal monitoring under the baseline inspection program.
4OA2 Identification and Resolution of Problems (71152)
.1
Daily Review
a.
Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems,
and in order to help identify repetitive equipment deficiencies or specific human
performance issues for follow-up, the inspectors performed a daily screening of items
entered into the licensees corrective action program. This screening was accomplished
by reviewing documents entered into the licensee corrective action program and review
Enclosure
17
of document packages prepared for the licensees daily Management Alignment and
Ownership Meetings.
b.
Findings
No findings of significance were identified.
.2
Semi-Annual Trend Review
a.
Inspection Scope
As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"
the inspectors performed a review of the licensees corrective action program (CAP) and
associated documents to identify trends that could indicate the existence of a more
significant safety issue. The inspectors review was focused on repetitive equipment
issues, but also considered the results of daily inspector CAP item screening discussed
in section 4OA2.1 above, licensee trending efforts, and licensee human performance
results. The inspectors review considered the 6 month period of July 2004 through
December 2004. Inspectors also reviewed collective significance condition reports and
Quality Trend Summary Reports. The review also included issues documented in the
licensees system health reports and maintenance rule assessments. The inspectors
compared and contrasted their results with the results contained in the licensees latest
quarterly trend reports.
The inspectors also evaluated the reports against the requirements of NOP-LP-2001,
Condition Report Process, Revision 8 and NG-NA-00711, Quality Trending,
Revision 06, and 10 CFR Part 50, Appendix B.
b.
Assessment and Observations
During the 3rd and 4th quarters of 2004, the Davis-Besse Nuclear Power Station
remained under the IMC 0350 Process. As part of approval process which granted
restart approval to the facility, the licensee was issued a Confirmatory Order which
required, in part, that the licensee, on an annual basis, contract for independent
assessments in the areas of operations performance, organizational safety culture, the
corrective action program implementation, and the engineering program effectiveness.
Assessments in each of these areas was completed during the 3rd and 4th quarters of
2004 and each assessment, either directly or indirectly, assessed the licensees ability
to identify and resolve issues. Senior inspectors have been assigned to review each of
the completed assessments.
Although the Agencys evaluation of these Independent Assessment Reports continue,
to date no new significant adverse performance trends have been identified as a result
of these assessments. Additionally, based on the inspectors evaluation of condition
reports, trending reports, quality assessment reports, system health reports, and daily
observations of licensee performance. There were no examples identified where the
licensee failed to identify an adverse performance trend.
Enclosure
18
.3
Biennial Licensed Operator Training Program Sample Review
a.
Inspection Scope
The inspectors reviewed licensee self-assessments and eleven corrective action
documents written to document deficiencies identified in the licensed operator training
program. The licensees self-assessments included a review of the licensed operator
training program completed approximately a month prior to this inspection activity.
The self-assessments and corrective action documents were reviewed to ensure that
the full extent of the issues were identified, an appropriate evaluation was performed,
the condition report was appropriately prioritized, and that actions were planned or
in-progress to resolve the issues.
b.
Findings
No findings of significance were identified.
4OA3 Event Followup (71153)
.1
On December 23, 2004, at 0614 , the plant declared a station isolation and implemented
their emergency plan off-normal procedure RA-EP-02870, Station Isolation, due to a
winter storm quickly depositing large amounts of snow in Ottawa and surrounding
counties. The weather conditions caused Ottawa County, the plants county of
residence, to declare a category 3 snow emergency. At 1345, the licensee made an
8-hour notification to the NRC (Event 41286) under 10 CFR 50.72(b)(3)(xiii) for a loss of
emergency response capability due to the potential inability of local population to
perform an evacuation. At 1805 hours0.0209 days <br />0.501 hours <br />0.00298 weeks <br />6.868025e-4 months <br /> on December 23, 2004, after weather conditions
improved, Ottawa County downgraded the weather emergency and the plant exited the
off-normal procedure. The inspectors observed the licensees implementation of
RA-EP-02780 and sampled the licensees manning relative to commitments for
emergency planning and for normal station operations. No items of significance were
identified.
.2
(Closed) LER 05000346/1998-002-01: Plant Trip Due to High Pressurizer Level as a
Result of Loss of Letdown Capability
Licensee Event Report 05000346/1998-002-00, Plant Trip Due to High Pressurizer
Level As a Result of Loss of Letdown Capability was previously evaluated and closed
by inspectors in Inspection Report 05000346/99009(DRP). The details of the event, the
licensees actions, and corrective actions were documented in Inspection Report
05000346/98005(DRP). No violations of regulatory requirements or findings of
significance were observed.
On November 7, 2003, the licensee submitted Revision 01 to this LER. The purpose of
this revision was to update their commitments which addressed this issue. These
commitments included: determining the failure mechanism for Makeup and Purification
Demineralizer #3; flushing of the letdown flow path, as necessary; evaluating and testing
Enclosure
19
Valve MU4; and evaluating the Integrated Control System for a trip at low power to
determine if operating practices could be enhanced.
The inspectors reviewed the licensee's corrective actions and determined them to be
acceptable. This item is closed.
4OA5 Other Activities (93812)
Following restart authorization, Inspection Procedure 93812 remained in effect to
facilitate the evaluation and documentation of issues not specifically covered by existing
procedures, but important to the evaluation of the licensees performance post-restart.
This inspection procedure remains in effect as part of the integrated resident inspection
report until a time to be determined by the Davis-Besse Oversight Panel.
.1
Evaluation of the Independent Engineering Assessment Report
a.
Inspection Scope
As part of the inspection activities performed to verify the licensees compliance with the
requirements for independent assessments, as described in the March 8, 2004,
Confirmatory Order Modifying License No. NPF-3, the inspectors reviewed the
Confirmatory Order Independent Assessment Report of the Engineering Program
Effectiveness at the Davis-Besse Nuclear Power Station, dated December 6, 2004. The
inspectors reviewed the report to determine whether the report provided an overall
assessment of Engineering performance, the Teams assessment activities supported
the reports conclusions, and the licensee documented specific action plans to address
deficiencies that were documented in the report.
b.
Observations and Findings
The first annual Davis-Besse Independent Engineering Assessment required by the
Order was performed during the time period of October 11, 2004 to October 22, 2004.
The inspectors reviewed and documented their evaluation of the Independent
Assessment Plan and implementation in Inspection Report 05000346/2004015. During
the time period that the assessment team was on site, the inspectors observed many of
the assessment activities while they were in progress. On December 6, 2004, the
licensee submitted the Engineering Independent Assessment Final Report to the NRC.
This report documented the findings of that assessment.
The final report was broken down into six areas of assessment:
Modifications Process;
Calculations;
System Engineering;
Use of the Corrective Action Program by Engineering;
Management Topics; and
Self Assessment
Enclosure
20
The independent assessment team reviewed engineering products in a number of areas
and did not identify any discrepancies that were considered significant in terms of the
validity of the work product, or indicative of a systematic deficiency in engineering work
performance or management. The team identified a number of areas where changes
could be made to enhance Engineering performance. These Noteworthy Items were
captured by the licensee in the corrective action program. As a direct result of the
assessment activities, the team developed conclusions in each of the assessment areas
and identified the following three Areas for Improvement:
Slow closure of some modifications - The team identified that approximately
550 Engineering Change Requests have not yet been dispositioned and
approximately 57 modifications, some installed as early as 1998, were not
closed out;
Declining focus on and rate of progress of the Calculation Improvement Program
- Relatively few items have been addressed since restart and most items initially
due in the March - June 2004 time frame were extended through the end of the
year. Many of these items were reported as 0 percent complete; and
Slippage of the Self Assessment schedule and mixed quality of assessment
findings and corrective actions - The team found that of the 34 engineering self
assessments scheduled for 2004, 7 were completed, 10 were pending
completion, and 17 were canceled. Of the 16 self assessments that the team
reviewed, half were found to be thorough and to identify appropriate corrective
actions while the remaining half were found to be average or below average,
particularly with respect to corrective actions.
In response to these issues, the licensee developed and committed to several Action
Plans in the December 6, 2004 submittal. These commitments are scheduled for
completion during 2005 with the exception of the classification of the 550 proposed
engineering changes, which is scheduled for completion by the end of Cycle 14
(February 2006 time frame).
The assessment team also identified the following strengths during the assessment
activities:
Rapid Response Team effectiveness in supporting resolution of emergent
issues;
Internalization of Engineering Principles and Expectations; and
Engineering Assessment Board influence on the quality of engineering work
products.
c.
Conclusions
The inspectors concluded that the independent assessment teams activities were of
sufficient depth and scope. The results of these activities were adequately documented
Enclosure
21
and the Action Plans developed by the licensee to address the Areas For Improvement
were appropriate. This independent assessment of Engineering performance was found
to be in accordance with the requirements of the March 8, 2004, Confirmatory Order.
.2
Review of Operations Independent Assessment Report Revision Submittal
The inspectors documented their initial review of the Operations Independent
Assessment Report in inspection report 05000346/2004015.
In a meeting on December 7, 2004, the NRC requested the licensee to provide an
overall assessment of Operations Department performance beyond that already
submitted to the NRC on October 8, 2004. In addition to the overall performance
assessment, the NRC also requested that several of the reports documented Areas For
Improvement be clarified and placed in proper context. Based on the discussion, the
licensee committed to request the Operations Independent Assessment Team to revise
their report to provide a comprehensive assessment of their findings and to clarify the
Areas For Improvement associated with non-licensed operator/licensed operator training
programs (Commitment #A21355) and Shift Manager Responsibilities
(Commitment #A21341).
On December 22, 2004, the licensee submitted Revision 1 of the Independent
Assessment Report of Operations Performance for the Davis-Besse Nuclear Power
Station. The inspectors determined that the revision adequately documented the
requested information.
The inspectors concluded that the teams assessment activities were of sufficient depth
and scope; that the results of these activities were sufficiently documented; and that the
Action Plans developed by the licensee to address the Areas For Improvement were
adequate.
.3
Station Battery 2P/2N Terminal Corrosion
Introduction: The inspectors identified a Non-Cited Violation of 10CFR 50, Appendix B,
Criterion XVI, having very low safety significance, for the licensees failure to take timely
corrective action to remove visible corrosion on several terminal connections on the
stations safety-related 2P and 2N batteries. The primary cause of this finding was
related to the cross-cutting area of problem identification and resolution.
Description: On December 6, during a tour of the 2P and 2N station battery room the
inspectors noticed surface corrosion present on several terminal connections for each
battery, and a buildup of corrosion products on the terminal connection for at least two
cells.
Further inspection revealed that some corrosion had existed on several terminals of the
2P and 2N battery terminals since late 2003, and was documented in the licensees
corrective action program as Condition Report 03-10564. An apparent cause evaluation
associated with this condition report, which was approved on January 19, 2004,
documented, in part, the following:
Enclosure
22
The consequences of battery post seal leakage is slow degradation of battery
connections due to corrosion. This condition can be remedied by cleaning off
the corrosion and re-coating the affected area with no-oxide grease.
Preventative action is to replace the seals, or replace the battery. The condition
is monitored during quarterly battery surveillance. The resistance of corroded
connections is measured to determine if corrosion has progressed to the point of
affecting the electrical contact area between the battery post and inter-cell
connector. Operating history indicates that the battery can tolerate this condition
without degradation of electrical contact for several months. Two orders have
been initiated to remediate the condition.
Based on this evaluation, two corrective actions were initiated in January 2004. These
corrective actions were for the plant engineer to verify that work order for cleaning
connections of Battery 2P [2N] is scheduled and completed. These corrective actions
were subsequently deferred in July 2004. The reason for these deferrals was
documented as follows:
Battery surveillance to date indicates that the battery connection resistance
readings are not affected by the visible corrosion. Cleaning corrosion from the
battery connections involves some degree of risk associated with cleaning
energized components. The risk of battery connector cleaning must be weighed
against the risk of doing nothing until batteries 2N and 2P are replaced during
the mid-cycle outage. Based on visual inspection performed on 7/12/04 the risk
associated with cleaning battery connections outweighs the risk of extending the
maintenance.
Again in November 2004, subsequent to the performance of the DB-ME-03001, Station
Battery Quarterly Surveillance, Revision 8, for the 2P and 2N station batteries, condition
reports were written which documented corrosion present on terminal connections of
approximately 62 cells. Again, no action was taken to remove the corrosion and re-coat
the terminal connections with no-oxide grease material.
On December 7, 2004, the inspectors had several discussions regarding the issue of
battery terminal connection corrosion with senior operations department individuals.
During these discussions, the inspectors learned that the Davis-Besse electrical
maintenance procedures used to periodically inspect and test the station batteries did
not contain instructions that allowed the electricians to address minor corrosion issues
as part of those maintenance activities. Additionally, the inspectors were informed that
since none of the affected battery cells had exhibited terminal connection resistance
values in excess of 150 micro ohms, the licensee was willing to accept the terminal
corrosion until the 2P/2N batteries were replaced in January 2005.
On December 8, 2004, the inspectors discussed this issue with the Plant Manager.
Shortly after that discussion, actions were taken to clean the terminal connections on
the 2P and 2N station battery, and DB-ME-03001 was revised to include instructions to
clean corrosion on battery terminal connections when identified.
Enclosure
23
Analysis: The inspectors determined that not taking prompt action to correct a known
deficiency on the safety-related station batteries was a performance deficiency because
the issue was reasonably within the licensees ability to foresee and correct and could
have been prevented. The inspectors determined that the finding was more than minor
because it impacted the Mitigating Systems cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. This violation was determined not to constitute an
immediate safety issue and was determined to be of very low safety significance
because there were no documented cases of any of the affected battery cells terminal
resistance measurements in excess of 150 micro-ohms.
Enforcement: 10CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall
be established to assure that conditions adverse to quality such as deficiencies,
deviations, and defective material and equipment are properly identified and corrected.
Contrary to this, varying degrees of corrosion existed for an extended period of time on
the terminal connections for several of the cells that comprise the 2P and 2N
safety-related station batteries. Because this finding was determined to have very low
safety significance, and because this issue was entered into the licensees corrective
action program, this violation is being treated as a Non-Cited Violation consistent with
Section VI.A of the NRC Enforcement Policy (NCV 05000346/2004016-01). The
licensee entered this issue into their corrective action program as CR 04-07545.
.4
Frazil Ice Issues
During the early morning hours of December 21, 2004, the licensee observed
decreasing service water intake forebay levels which were not consistent with level
changes in Lake Erie. The intake forebay is a reservoir that is connected to Lake Erie
by a 96 inch pipe, through which makeup water flows when there is a difference
between intake and Lake levels. Diverging levels in clear winter weather is indicative of
frazil ice blockage of the intake crib at the Lake Erie side of the makeup pipe. The
licensee entered Section 4.2, Actions During Frazil Ice Conditions, of procedure
DB-OP-06913, Seasonal Plant Preparation Checklist, and took actions to minimize
water losses from the intake forebay. Upon completion of these actions, the forebay
water level, which was at approximately the 567 feet level, was observed to be
decreasing at approximately 4 inches per hour.
At an elevation of 562 feet, the licensee has sufficient water in the forebay to meet their
design requirements for an ultimate heat sink. If the actual water level decreases to
below 562 feet, the licensees technical specifications require shutdown to hot standby
within 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. At 564 feet, the licensees procedures require them to place in service
a temporary pump that is sized to pump approximately 9000 gpm from Lake Erie, over
the dike for the intake canal, and into the forebay via the intake canal. The lowest level
reached in the intake forebay was approximately 564.8 feet before warming weather
conditions restored normal makeup flow from the lake. Although the level did not
decrease below 564 feet, the licensee conservatively decided to demonstrate the
capability to install and operate the temporary pump.
Enclosure
24
The inspectors monitored the licensees decision making process, compliance with
existing procedures, and the installation and testing of the temporary pump. The
inspectors noted that the licensee had also experienced apparent frazil ice blockage on
the mornings of December 24 and December 25 but that the levels did not decrease
below 565 feet level in the intake forebay.
No items of significance were identified.
.5
Containment Entry for Lubricating Oil Addition
On December 27, 2004, the licensee made a containment entry to add approximately 3
gallons of oil to the reservoir for RCP 1-2 motor lower bearing. The reactor power was
maintained at approximately 100 percent. Oil addition was through a remote addition
line that was located in an accessible area. Licensee personnel initially added
approximately 2 quarts of oil to verify integrity of the oil addition line. The initial fill was
sufficient to clear the low level alarm and also verified that oil was traveling to the oil
reservoir. The inspectors observed the ALARA brief and observed the licensees
activities while in containment.
No items of significance were identified.
.6
Licensee Preparations for a Potential Work Stoppage (92709)
The majority of licensees plant physical workers, including reactor operators, are
represented by Local 245 of the International Brotherhood of Electrical Workers (IBEW).
The inspectors continued to monitor the on-going contract negotiations between the
licensee and the Local 245. Although both union and licensee management
representatives have indicated a willingness to continue negotiations beyond the
expiration date, the licensee has made preparations to ensure compliance with
regulatory requirements in the event of a work stoppage. The inspectors, using
guidance in Inspection Procedure 92709, Licensee Strike Contingency Plans, have
reviewed the licensees plans for ensuring a sufficient number of qualified personnel are
available to maintain the plant in a safe condition, should a work slowdown or stoppage
occur.
No items of significance were identified.
4OA6 Meetings
.1
Exit Meeting
The inspectors presented the inspection results to Mr. B. Allen, and other members of
licensee management on January 6, 2005. The licensee acknowledged the findings
presented. No proprietary information was identified.
.2
Interim Exit Meetings
An interim exit meeting was conducted for:
Enclosure
25
Biennial Licensed Operator Requalification Program Inspection with Mr. Allen on
November 19, 2004;
Overall assessments of the annual operating test and the biennial written
examination results via telephone with Mr. Stallard on December 13, 2004; and
Access control to radiologically significant areas, ALARA planning and controls
program and radiological waste and transportation with Mr. R. Schrauder on
December 10, 2004.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
B. Allen, Director, Plant Operation
M. Bezilla, Site Vice President
B. Boles, Manager, Plant Engineering
D. Bondy, Staff Instructor
P. Faris, Senior Nuclear Assessor, Davis-Besse Oversight
J. Grabnar, Manager, Design Engineering
L. Harder, Manager, Radiation Protection
R. Hovland, Manager, Technical Services
R. Hruby, Manager, Nuclear Oversight
D. Kline, Manager, Security
D. Lange, Staff Instructor
S. Loehlein, Director, Station Engineering
L. Myers, Chief Operating Officer, FENOC
D. Noble, Radiation Protection Supervisor
K. Ostrowski, Manager, Plant Operations
C. Price, Manager, Regulatory Compliance
M. Roder, Transaction Manager, Training
J. Reuter, Radwaste Shipper
R. Schrauder, Director, Performance Improvement
A. Stallard, Supervisor, Operations Training
C. Steenbergen, Shift Manager
M. Stevens, Manager, Maintenance
M. Trump, Training Manager
D. Wahlers, Supervisor, Nuclear Oversight
D. Wuokko, Compliance Supervisor, Performance Improvement
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Untimely Corrective Actions to Correct Safety-Related
Battery Terminal Connection Corrosion
Closed
05000346/1998-002-01
LER
Plant Trip due to High Pressurizer Level as a result of Loss
of Let Down Capability
Attachment
2
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather that
selected portions of the documents were evaluated as part of the overall inspection effort.
Inclusion of a document on this list does not imply NRC acceptance of the document or any part
of it, unless stated in the body of the inspection report.
1R05
Fire Protection
Davis-Besse Nuclear Power Station Fire Hazard Analysis Report
Drawing A-0221F; Fire Protection General Floor Plans El 545' & 555'; Revision 07
Drawing A-2132, Sheet 6; Barrier ID- Room 113; Revision 00
1R11
Licensed Operator Requalification Program
NG-NT-00601; Control of the Plant-Referenced Simulator; Revision 3; dated
November 12, 2004
NT-OT-07001; Licensed Operator Requalification Program; Revision 7
NOP-TR-1001; FENOC Conduct of Training; Revision 0
NOBP-TR-1104; FENOC Design and Development of Training Materials; Page 3;
Revision 0
DBBP-TRAN-0021; Simulator Configuration Control; Revision 0; dated
November 12, 2004
DBBP-TRAN-0502; Development and Conduct of Continuing Training Simulator
Evaluations; Revision 0
Comprehensive Biennial Written Examination; SRO #1, 2004; RO, 2004; RO #3, 2004
Simulator Scenario: ORQ-EPE-S113; Revision 7
Simulator Scenario; ORQ-EPE-S105; Revision 9
Job Performance Measure; OPS-JPM-015; Revision 0
Job Performance Measure; OPS-JPM-052; Revision 0
Job Performance Measure; OPS-JPM-053; Revision 1
Job Performance Measure; OPS-JPM-076; Revision 1
Job Performance Measure; OPS-JPM-100; Revision 1
Job Performance Measure; OPS-JPM-101; Revision 1
Shift Manager/Unit/Field Supervisor/Shift Engineer Turnover Checklist; dated
November 16, 2004
Davis-Besse Nuclear Power Station Licensed Operator Requalification Training
Program Training Plan; Revision 8; dated January 30, 2004
Pre-job Briefing Package; Cycle 04-04 Management Introduction; dated
November 15, 2004
Post-Training Assessment Report; Training Appraisal Questionnaire for Just-in-Time
Training for Startup/Criticality and Generator Synchronization; dated October 19, 2004
Sample of Crew and Individual Simulator Performance Evaluation Forms for Year 2003
Sample of Week 1 (November 1, 2004) NRC Requalification Examination Simulator
Results
Attachment
3
Sample of Remediation Packages; NOP-TR-1001-01; Remedial/Make-Up
Recommendations; Dated various
Requalification Training Attendance; Trainee Tracking - EDGs-OPS-IER-1042
Requalification Training Attendance; Trainee Tracking - RPS-OPS-SYS-1504
Requalification Training Attendance; Trainee Tracking - T.S. 2.0/3.0/4.0
Requalification Training Attendance; Trainee Tracking - OPS-GOP-1420
Requalification Training Attendance; Trainee Tracking - OPS-GOP-1430
Licensed Operator Long Term Continuing Training Schedule; Revision 3; dated
November 15, 2004
TNS-04-00322; Intra-Company Memorandum; Third Quarter 2004 Proficiency Status;
Revision 0; dated October 7, 2004
Listing of Closed Simulator Work Orders (SWO) Between January 01, 2002 through
November 16, 2004
SWO 02-0029; Open; Update NAS on Daisy for Cycle 12 Data; Issue Date
March 27, 2002
SWO 02-0116; Open; Containment RAD Reached 3600 R/hr as Read on RI 4596A/B;
Issue Date April 28, 2003
SWO 03-0071; Open; Alarms 5-1-C and 5-1-D SFAS Trip Alarms Come in When
Blocked; Issue Date October 17, 2003
SWO 04-0076; Open; Start Program on SPDS is Still Using Cycle 13 Data Need to
Update to Cycle 14; Issue Date June 22, 2004
SWO 04-0103; Open; Turbine MS Point Out of Tolerance on PPC; Issue Date
June 30, 2004
SWO 02-0012; Open; Setpoint Change or Variable P/T Trip-RPS; Issue Date
February 18, 2002
SWO 02-0084; Open; Replacement of Victoreen RAD Monitors; Issue Date
October 1, 2002
SWO 03-0002; Open; Maximum Allowed Boron on Simulator is 2500 ppm
[meter indication]; Issue Date June 3, 2003
Simulator Certification Test; TAB01; Manual Reactor Trip; dated October 6, 2004
Simulator Certification Test; TAB02; Simultaneous Trip of All Main Feedwater Pumps;
dated October 6, 2004
Simulator Certification Test; TAB05; Simultaneous Trip of All Reactor Coolant Pumps;
dated October 13, 2004
Simulator Certification Test; TAB07; Maximum Rate Power Ramp 100 percent,
75 percent, 100 percent; dated October 19, 2004
Simulator Certification Test; TAB09; Main Steam Line Failure in the Reactor Building;
dated October 19, 2004
Simulator Certification Test; N03; Zero Power Physics Testing (Core Physics Testing);
dated March 08, 2002
Simulator Certification Test; T10; Total Loss of Feedwater; dated June 21, 2000
Simulator Certification Test; T16; Generator/Turbine Trip; dated February 16, 2003
Simulator Certification Test; T03B; Loss of All AC Power and Loss of Both Diesels;
dated December 22, 2001
Condition Report (CR) 04-05449; Simulator Configuration Control Improvement
Opportunities; dated September 2, 2004
CR 04-00181; Missed Technical Specification Action Statement; dated January 6, 2004
Attachment
4
CR 04-01230; Missed Technical Specification Entry; dated February 12, 2004
CR 04-04406; Missed Surveillance Requirement 4.3.1.1.1 for RCS Flow Channel
Check; dated July 6, 2004
CR 02-09434; NRC Inspection 71111.11 Licensed Operator Requal Inspection
Comments; dated November 15, 2002
Operations Events Involving Technical Specifications Identified in Condition
Report 04-04425; dated August 23, 2004
Self-Assessment Report 2004-0105; Simulator Configuration Control; dated
September 2, 2004
Self-Assessment Report CR/CA 04-02029-06; Licensed Operator Requalification
Program; dated November 4, 2004
1R12
Maintenance Effectiveness
DB-PF-0003; Maintenance Rule; Revision 06
NUREG-1482; Guidelines for Inservice Testing At Nuclear Power Plants; Revision 01
Pump and Valve Basis Document; Volume II - Pump Basis; Revision 00
MRPM 15; Maintenance Rule Program Manual; Revision 15
Davis-Besse Plant Health Report; 3rd Quarter 2004
CR 04-04656; INPO 2004 Evaluation - AFI CM.1-1 (Operating and Design Margins)
1R15
Operability Evaluations
DB-MM-05001; Bench Testing Snubbers; Revision 04
DB-PF-00107; Hydraulic Snubber Program; Revision 0
CR 04-07274; Snubber Test Inaccuracies not Accounted for in Recorded Results
1R16
Operator Workarounds
DB-OP-06013; Containment Spray System; Revision 12
Shift Manager/Unit/Field Supervisor/Shift Engineer Turnover Checklist
1R22
Surveillance Testing
DB-SS-03091; Motor Driven Feed Pump Quarterly Test; Revision 06
CR 04-07062; Instrumentation Snubber Problem
Dwg OS-012A, Sheet 1; Main Feedwater System; Revision 22
2OS2 ALARA Planning And Controls
CR04-02353; ALARA Brief Not Performed per DB-HP-01154; dated March 30, 2004
RWP 2004-2001; Containment Entry; Revision 3
ALARA Plan; RWP 2004-2001 Containment Entry
2PS2
Radioactive Material Processing and Transportation
CR04-04156; Safety Concern - Resin Transfer And Changing Rad Conditions; dated
June 23, 2004
Attachment
5
CR04-05833; Contamination Found On Vendor RAM Shipment to DB; dated
September 23, 2004
CR04-06946; Provide Instructions for Transportation of Radioactive Samples Less Than
0.002 Micro-curies Per Gram; dated November 11, 2004
CR04-06943; Establish Maximum Dose Rate for Radioactive Material Area Boundary;
dated November 11, 2004
CR04-07458; Missed HIC Dewatering Verification; dated December 6, 2004
CR04-08560; Issues with 10 CFR Part 61 Sampling and Analysis Program; dated
October 7, 2003
NQA Field Observation; Process Control Program; dated October 27, 2003
NQA Field Observation; 10 CFR Part 61 Radwaste Classification; dated October 15,
2003
NQA Field Observation; Transfer of Spent Purification Filters; dated July 9, 2004
DB-HP-01502; Dewatering of Filter Media; Revision 5
DB-HP-03002; Dewatering Verification; Revision 2
NOP-OP-2; Shipment of Radioactive Material/Waste; Revision 4
DB-PCP; Process Control Program; Revision 6
DB-HP-06120; Miscellaneous Liquid Waste Demineralizer Operations; Revision 5
DB-HP-01712; 10 CFR Part 61 Sampling For Waste Classification; Revision 00
Qualification Matrix; Receiving Shipping Rad Material; dated December 7, 2004
BWXT Analysis Report; 10 CFR Part 61 Isotopic Data; dated April 30, 2004
Lesson Plan; Packaging, Transport And Disposal Of Radioactive Waste; Revision 1
Qualification Matrix DOT Training; dated December 8, 2004
Shipping Papers; 04-1001 Dewatered Resin, Type B Shipment; dated May 18, 2004
Shipping Papers; TR04-0002 Primary Resin Type B Shipment; dated April 2, 2004
Shipping Papers; Radwaste LSA TR03-0018; dated August 5, 2003
Shipping Papers; Radwaste LSA Filters TR03-022; dated September 23, 2003
Shipping Papers; Radwaste LSA TR03-0019; dated August 7, 2003
4OA1 Performance Indicator Verification
Unit Logs; October 1, 2003 through September 30, 2004
4OA2 Problem Identification and Resolution
CR 04-07142; Simulator Data Improvement Opportunity Noted During NRC Inspection;
dated November 18, 2004
CR 04-07143; Criteria Used to Evaluate Crew Performance Could Be More Objective;
dated November 18, 2004
CR-04-07144; NRC Licensed Operator Requalification Training Program Inspection
[Areas Needing Improvements/Enhancements]; dated November 16, 2004
CR 04-07545; NRC Resident Questions For Batteries 2P and 2N
4OA3 Event Followup
RA-EP-02870; Station Isolation; Revision 02
Attachment
6
4OA5 Other Activities
IP 92709; Licensee Strike Contingency Plans; August 12, 1992
DB-OP-06913; Seasonal Plant Preparation Checklist; Revision 10
4OA5 Other Activities (93812)
CR 04-07545; NRC Resident Questions For Batteries 2P and 2N
CR 03-10564; Corrosion on Battery 2P and 2N Battery Terminals
CR 04-03711; Station Battery 2P Corrosion
CR 04-03692; Station Battery 2N Corrosion
CR 04-07277; Corrosion Found on Cell Connections for 2N Station Batteries
CR 04-07270; Corrosion Found on Cell Connections for 2P Station Batteries
DB-ME-03001; Station Batteries Quarterly Surveillance; Revisions 8 and 9
Attachment
7
LIST OF ACRONYMS USED
Agency-wide Document Access and Management System
As Low As Is Reasonably Achievable
Component Cooling Water
CFR
Code of Federal Regulations
CR
Condition Report
FirstEnergy Nuclear Operating Company
Integrated Control System
IMC
Inspection Manual Chapter
IR
Inspection Report
Job Familiarization Guidelines
LER
Licensee Event Report
Licensed Operator Requalification Training
Non-Cited Violation
NRC
United States Nuclear Regulatory Commission
Publicly Available Records
Performance Indicator
Reactor Coolant Pump
Radiation Protection
Radiation Work Permit
Significance Determination Process
Simulator Work Order
TS
Technical Specifications
Updated Safety Analysis Report
Work Order