IR 05000346/2019004
| ML20035D918 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/31/2020 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR 2019001, IR 2019004 | |
| Download: ML20035D918 (37) | |
Text
ary 31, 2020
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2019004 AND 07200014/2019001
Dear Mr. Bezilla:
On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On January 16, 2020, the NRC inspectors discussed the results of this inspection with Doug Huey and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-identified violations which were determined to be Severity Level IV are documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Davis-Besse Nuclear Power Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Billy C. Dickson, Jr, Chief Branch 2 Division of Reactor Projects Docket No. 05000346; 07200014 License No. NPF-3
Enclosure:
As stated
Inspection Report
Docket Number: 05000346; 07200014 License Number: NPF-3 Report Number: 05000346/2019004; 07200014/2019001 Enterprise Identifier: I-2019-004-0063; I-2019-001-0114 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Inspection Dates: October 01, 2019 to December 31, 2019 Inspectors: J. Cassidy, Senior Health Physicist J. Dalzell, Health Physicist R. Edwards, Senior Health Physicist N. Fields, Health Physicist M. Garza, Emergency Preparedness Inspector J. Harvey, Resident Inspector M. Learn, Reactor Engineer D. Mills, Senior Resident Inspector J. Rutkowski, Project Engineer Approved By: Billy C. Dickson, Jr, Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Davis-Besse Nuclear Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Licensee-identified non-cited violations are documented in report section: 60855.1.
List of Findings and Violations Inadvertent Injection into Once Through Steam Generator 1 while Running the Emergency Feedwater Pump Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71152 NCV 05000346/2019004-02 Complacency Open/Closed A self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification Section 5.4.1.a for the licensees failure to establish a procedure to address the requirements of RG 1.33 Appendix A, Section 9. Specifically, the licensee failed to properly pre-plan and establish documented instructions that included provisions to ensure EFW recirculation. This resulted in an inadvertent injection into Steam Generator 1 affecting performance of the steam generator and causing operation outside of the acceptable region of the steam generator level to superheat curve, and affecting performance of the reactor core due to an uncontrolled reactivity insertion.
Emergency Ventilation System Inadequate Acceptance Criteria Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.11] - 71153 NCV 05000346/2019004-03 Challenge the Open/Closed Unknown A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Title 10 Code of Federal Regulations Part 50, Appendix B, criterion V, "Instructions,
Procedures, and Drawings," was identified when the licensee failed to prescribe the appropriate quantitative or qualitative acceptance criteria in a procedure used for determining that activities important to safety were satisfactorily completed. Specifically, the licensee failed to have appropriate acceptance criteria incorporated into the Emergency Ventilation System train 1 surveillance which resulted in the licensee failing to recognize the test had failed.
Additional Tracking Items Type Issue Number Title Report Section Status URI 05000346/2019004-01 Unresolved Item Regarding 60855.1 Open Peak Fuel Clad Temperature During Vacuum Drying of Canister #9
LER 05000346/2019-001-00 LER 2019-001-00 for Davis- 71153 Closed Besse Nuclear Power Station, Unit 1, Emergency Ventilation System Train Inoperable due to Non-specific Test Description of Damper Operation
PLANT STATUS
The unit operated at or near full rated thermal power for the entire inspection period.
On April 25, 2018, FirstEnergy Solutions (FES) / FirstEnergy Nuclear Operating Company (FENOC) notified the U.S. Nuclear Regulatory Commission (NRC) that they intend to shut down all four of their operating nuclear power plants (ADAMS Accession Number ML18115A007). On March 21, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and FENOC filed for bankruptcy. On July 26, 2019, FES/FENOC submitted a letter to the NRC withdrawing the April 25, 2018, certification of permanent cessation of power operations for Davis-Besse Nuclear Power Station and Perry Nuclear Power Plant (ADAMS Accession Number ML19207A097). The NRC continues to maintain focus on public health and safety and the protection of the environment. This will include a continuous evaluation by inspectors to determine whether the licensee's financial condition is impacting safe operation of the plant.
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 plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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 Seasonal Extreme Weather Sample (IP Section 03.02)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following:
- Station building heating
- Piping heat tracing function
- Intake canal frazil ice compensatory measure preparation
71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency Diesel Generator (EDG) 1 while EDG 2 was out of service for planned maintenance during the week ending October 5, 2019
- (2) Diesel Fire Pump while the Electric Fire Pump was removed from service during the week ending October 26, 2019
- (3) High Pressure Injection (HPI) 1 while HPI 2 was out of service for planned testing during the week ending November 2, 2019
- (4) Motor Driven Feedwater Pump after planned testing during the week ending November 2, 2019
- (5) Decay Heat/Low Pressure Injection (DH/LPI) Pump 2 while DH/LPI 1 was out of service for planned maintenance during the week ending November 16, 2019
- (6) Auxiliary Feed Water (AFW) 1 while AFW 2 was out of service for planned maintenance during the week ending November 23, 2019
71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)
- (1) The inspectors evaluated system configurations during a complete walkdown of the containment spray system on during the week ending November 9, 2019.
71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) High Voltage Switchgear Room B, Fire Area Q, during the week ending October 5, 2019
- (2) Makeup Pump Room, Fire Area AB, during the week ending November 2, 2019
- (3) Auxiliary Feed Pump 1 Room, Fire Area E, during the week ending November 23, 2019
- (4) Spent Fuel Pool Pump Room, Fire Area U, during the week ending December 28, 2019
71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)
The inspectors evaluated readiness and performance of:
- (1) The Chemical Injection system, which helps maintain the integrity and heat removal capability of the service water system.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests administered from October 19 through December 11, 2019.
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) The inspectors observed and evaluated licensed operator performance in the Control Room during shift turnover, operator workstation computer replacement, axial power shaping rod position adjustment, and a Decay Heat/Low Pressure Injection Pump quarterly surveillance run during the week ending December 21, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification simulator scenario during the week ending December 7, 2019.
71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Emergency Ventilation System Unavailability and Reliability
- (2) Motor Driven Feed Pump Target Rock Valve power converter installation
- (3) Motor Driven Feedwater Pump Unavailability and Reliability
71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Planned preventive maintenance activities on Emergency Diesel Generator 2 during the week ending October 5, 2019
- (2) Plant process computer outage during the week ending November 2, 2019
- (3) Planned maintenance on Startup Transformer X01 during the week ending November 16, 2019
- (4) Emergent work on the Train 1 Emergency Core Cooling System (ECCS) sump pumps during the week ending November 23, 2019
71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Clarification needed with respect to motor driven feedpump alignment in Mode 1, Condition report (CR) 2019-07507
- (2) OP3006 miscellaneous instrument shift checks performed with invalid Group 38 data, CR 2019-09248
- (3) Battery specific gravity is out of program limit, CR 2019-09966
- (6) Pressure Differential Switch Found Outside Tech Spec Allowable As-Found Range, CR 2019-10422
71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)
The inspectors evaluated the following post maintenance tests:
- (1) Emergency Diesel Generator 2 after planned maintenance during the week ending October 5, 2019
- (2) Auxiliary Feedpump 2 comprehensive test after planned maintenance during the week ending November 23, 2019
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)
- (1) Local leak rate testing of containment personnel hatch after containment entry during the week ending November 16, 2019
- (2) Safety Features Actuation System Channel 3 response time testing during the week ending December 7, 2019
71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
- DB-2018-031-00, 10 CFR 50.54(q)(2) Analysis, August 23, 2018
- DB-2018-031-00, 10 CFR 50.54(q)(3) Screen/Evaluation, August 23, 2018 This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
The inspectors evaluated:
- (1) Emergency preparedness drill on October 15,
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (IP Section 02.01)
The inspectors evaluated airborne controls and radioactive monitoring.
- (1) The inspectors reviewed the following:
Installed Ventilation Systems
- Radwaste Area Ventilation System Temporary Ventilation System Setups
- None were available during this inspection Portable or Installed Monitoring Systems
- AMS-4 on refuel floor
- AMS-4 in waste handling area Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)
The inspectors evaluated self-contained breathing apparatus program implementation.
- (1) The inspectors reviewed the following:
Status and Surveillance Records for Self-Contained Breathing Apparatus
- SCBA Unit 31
- SCBA Unit 45
- SCBA Unit 66 Self-Contained Breathing Apparatus Fit for On-Shift Operators
- Three operators on shift "5" Self-Contained Breathing Apparatus Maintenance Check
- SCBA Unit 31
- SCBA Unit 45
- SCBA Unit 66
71124.04 - Occupational Dose Assessment Source Term Categorization (IP Section 02.01)
- (1) The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity.
External Dosimetry (IP Section 02.02) (1 Sample)
- (1) The inspectors evaluated the external dosimetry program implementation.
Internal Dosimetry (IP Section 02.03) (1 Sample)
The inspectors evaluated the internal dosimetry program implementation.
- (1) The inspectors reviewed the following:
Whole Body Counts
- Whole Body Count(s) associated with Personal Contamination Event #Outage 18-005
- Investigation Bioassay for High Pressure 80 valve work: Plant ID 19260 In-Vitro Internal Monitoring
- None were available during this inspection.
Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring
- None were available during this inspection.
Special Dosimetric Situations (IP Section 02.04) (1 Sample)
The inspectors evaluated the following special dosimetric situation:
(1)
- Declaration of Pregnancy, 12/10/2018
- Declaration of Pregnancy, 08/20/2019
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage.
- (1) The inspectors toured the following areas:
- Low Level Radioactive Waste Storage Facility
- Building 7 The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:
- 6 containers in the Low Level Radioactive Waste Storage Facility
- 4 Containers in Building 7 Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated the following radioactive waste processing systems during plant walkdowns:
- (1) Liquid or Solid Radioactive Waste Processing Systems
- Advanced Liquid Processing System Radioactive Waste Resin and/or Sludge Discharges Processes
- Primary Resins Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
(1)
- Dry Active Waste
- Primary Resin
- Primary Filters
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated the following radioactive material shipment preparation processes:
- (1) The inspectors evaluated training and qualification records for selected individuals due to limited observation of the radioactive material shipment preparation process.
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
(1)
- 2018-1008; Cask with filters in Poly Container
- 2018-1029; Metal Cask of Filters
- 2019-1001; Cask with resin in Poly Container
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS10: Cooling Water Support Systems (IP Section 02.09) ===
- (1) July 1, 2018 - September 30, 2019
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1, 2018 - September 30, 2019
71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in FLEX equipment battery issues that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR 2019-07705 - Water was flowed from the EFWST [Emergency Feedwater Storage Tank] to OTSG 1 [Once Through Steam Generator 1] while running the EFW
[Emergency Feedwater] pump to recirculate engine coolant
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000346/2019-001-00, "Emergency Ventilation System Inoperable due to Non-Specific Test Description of Damper Operation," ML19282A383. The inspectors determined the issue was within the licensee's ability to foresee and correct and that a violation of NRC requirements occurred. The circumstances surrounding this LER are documented in the inspection results section.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60854.1 - Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants
- (1) The inspectors reviewed documents, interviewed plant personnel, and performed in-field observations to assess the licensees preoperational testing of an ISFSI. The licensees preoperational testing activities took place partially at the vendors facility and partially at the licensees facility.
The inspectors performed an independent assessment that the licensee had adequately demonstrated its readiness to safely perform ISFSI loading and unloading operations. Specifically, the inspectors evaluated the following:
- (1) The licensee performed preoperational dry run activities. The inspectors evaluated following activities:
- The inspectors observed dry run activities on October 7 - 10, 2019. Specifically, the inspectors observed insertion and removal of a DSC into an HSM, transport of a transfer cask (TC) between the ISFSI and t Auxiliary Building, upending of a TC from the transporter to the cask wash pit (dry), and movement of the TC between the cask wash pit and the spent fuel pool.
- The inspectors completed an in-office review of the welding and processing dry run documentation on September 23 - October 4, 2019.
- (2) Fuel Selection
- The inspectors reviewed cask fuel selection packages to verify that the licensee was loading fuel in accordance with TS 2.1, Fuel to be Stored in the Standardized NUHOMS System.
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) Operation of an Independent Spent Fuel Storage Installation at Operating Plants (60855.1)
The inspectors evaluated the licensees independent spent fuel storage installation cask loadings on October 14 - 19 and November 4 - 8, 2019. Specifically, the inspectors observed the following activities:
- Fuel selection and fuel loading for the first canister planned for the campaign, DSC-9, and DSC-11
- Heavy load movement of the Outer Top Cover Plate and lifting the Transfer Cask from the processing area and placing it on the transport vehicle
- Drying and backfill evolutions
- Closure welding and non-destructive weld evaluations
- Transfer and transport evolutions
- Radiological field surveys The inspectors performed walkdowns of the ISFSI pad, including independent radiation surveys, and walkdowns of the ISFSI haul path and vertical cask transporter (VCT).
The inspectors evaluated the following:
- Selected corrective action program action requests
- Selected 72.48 screenings and evaluations
60856 - Review of 10 CFR 72.212(b) Evaluations Review of 10 CFR 72.212(b) Evaluations
- (1) The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212 and 10 CFR 72.48. Prior to use of a dry cask storage system, the licensee is required to perform written evaluations in accordance with 10 CFR 72.212(b)(5)(i) to establish that the terms, conditions, and specifications of a CoC or an amended CoC have been met. Specifically, the inspectors performed an in-office review of the following from May 2019 through October 2019:
- 10 CFR 72.212 Evaluation Report for the NUHOMS EOS System Certificate of Compliance 1042, Revision 0 and associated calculations
- ECP 15-0086, Dry Cask Storage Independent Spent Fuel Storage Installation (ISFSI Parent) and supporting engineering changes and referenced calculations
- Licensees Quality Assurance Program Manual
60856.1 - Review of 10 CFR 72.212(b) Evaluations at Operating Plants Review of 10 CFR 72.212(b) Evaluations at Operating Plants
- (1) The inspectors evaluated the licensees revised engineering documentation and calculations associated with the NUHOMS EOS CoC 072-01042, Revision 0.
Specifically, from May through October 2019, the inspectors performed an in-office review the following:
- Transfer Cask Lifting Yoke Assembly
- Doerfer Transporter Skid Modifications
- Auxiliary Building and Crane Structural Analysis
- ISFSI Pad Structural Capacity Qualification
INSPECTION RESULTS
Unresolved Item Unresolved Item Regarding Peak Fuel Clad Temperature 60855.1 (Open) During Vacuum Drying of Canister #9 URI 05000346/2019004-01
Description:
During the processing of Dry Shielded Canister (DSC) 9, the canister loaded with spent fuel took longer than expected to achieve the required dryness criterion. Various attempts to achieve dryness were made, including backfilling the canister with helium and attempting additional drying. Through their investigation, the licensee identified a vacuum leak in a fitting that connected the vacuum drying equipment to the DSC. The fitting was safely repaired, and the DSC was successfully dried. Given the extended time in vacuum drying and the changing thermal environment in the DSC during troubleshooting, the inspectors questioned whether the canister conditions encountered during troubleshooting were consistent with the design basis thermal analysis described in Chapter 4 of the NUHOMS EOS System Updated Final Safety Analysis Report, Revision 1. To determine whether DSC-9 remained in an analyzed condition, the licensee consulted with Orano to perform an evaluation into the maximum peak cladding temperature and also to determine whether the thermal cycling conditions specified in the UFSAR were met during processing.
At the time of the inspection, this evaluation was ongoing and unavailable to the inspectors.
Planned Closure Actions: Upon receipt of the calculations, the agency will perform its review to determine if there are any technical issues or a violation occurred.
Corrective Action References: CR-2019-09156 Licensee-Identified Non-Cited Violation 60855.1 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 72.158, Control of special processes, requires the licensee, applicant for a license, certificate holder, and applicant for a CoC shall establish measures to ensure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
Contrary to the above, between October 15, 2019, and October 21, 2019, the licensee did not ensure that the nondestructive examinations completed on seven welds were accomplished using qualified procedures. Specifically, the developer that was used during the examination of the welds was not as specified in the procedures.
Significance/Severity: Severity Level IV. The inspectors assessed the significance of the violation using the NRC Enforcement Policy and Enforcement Manual. Because ISFSIs are not part of the Reactor Oversight Process, this violation was assessed using Traditional Enforcement in accordance with Section 2.2 of the Enforcement Policy. Consistent with the guidance in Section 1.2.6.D of the Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level: (1)commensurate with its safety significance; and
- (2) informed by similar violations addressed in the Violation Examples. The inspectors found no similar violations in the violation examples.
This violation has been determined to be of very low safety significance because the licensee was able to have the nondestructive examination procedure requalified to allow for the use of the developer that had been used to complete the examination with no issues.
Corrective Action References: CR-2019-08736 Licensee-Identified Non-Cited Violation 60855.1 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 72.146, Design Control requires, in part, that the licensee, shall establish measures to ensure that applicable regulatory requirements and the design basis, as specified in the license or CoC application for those structures, systems, and components to which this section applies, are correctly translated into specifications, drawings, procedures, and instructions. These measures must include provisions to ensure that appropriate quality standards are specified and included in design documents and that deviations from standards are controlled. Measures must be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the functions of the structures, systems, and components which are important to safety.
Contrary to the above, on October 11, 2019, the licensee found several errors in the approved fuel selection calculations resulting in several of the fuels assemblies not meeting the requirements of TS 2.1, Fuel to be Stored in the EOS-37PTH DSC. Specifically, the calculations that had initially been approved contained several errors, including the heavy metal mass, burn-up, and the number of days that some fuel assemblies were in the operating reactor.
Significance/Severity: Severity Level IV. The inspectors assessed the significance of the violation using the NRC Enforcement Policy and Enforcement Manual. Because ISFSIs are not part of the Reactor Oversight Process, this violation was assessed using Traditional Enforcement in accordance with Section 2.2 of the Enforcement Policy. Consistent with the guidance in Section 1.2.6.D of the Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level: (1)commensurate with its safety significance; and
- (2) informed by similar violations addressed in the Violation Examples. The inspectors found no similar violations in the violation examples.
This violation is of very low safety significance because the errors were found and corrected before any fuel had been loaded into the dry cask canisters.
Corrective Action References: CR-2019-08369, CR-2019-08339, CR-2019-08408, CR-2019-08449, CR-2019-08457, CR-2019-08503, CR-2019-08709, CR-2019-08901 Inadvertent Injection into Once Through Steam Generator 1 while Running the Emergency Feedwater Pump Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71152 NCV 05000346/2019004-02 Complacency Open/Closed A self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification Section 5.4.1.a for the licensees failure to establish a procedure to address the requirements of RG 1.33 Appendix A, Section 9. Specifically, the licensee failed to properly pre-plan and establish documented instructions that included provisions to ensure EFW recirculation. This resulted in an inadvertent injection into Steam Generator 1 affecting performance of the steam generator and causing operation outside of the acceptable region of the steam generator level to superheat curve, and affecting performance of the reactor core due to an uncontrolled reactivity insertion.
Description:
On September 19, 2019, operators locally started the diesel driven emergency feedwater pump (EFWP) per work order 200724732 as part of a maintenance activity. The operators ran EFWP for one minute to clear cooling system voids following replacement of the diesel engine coolant. The licensees intention was to run the pump with valves lined up to recirculate the water to the EFWP storage tank for roughly one minute. However, the work order mistakenly directed operators to operate the EFWP with valves aligned for steam generator injection. This resulted in unintended EFWP injection into Steam Generator 1 (SG1) for one minute and seventeen seconds. Relatively cold water injection into the steam generator resulted in a reduction in steam superheat which moved SG1 into the unacceptable range of the water level to steam superheat curve for six minutes. The licensee correctly entered Technical Specification limiting condition for operation 3.7.18, Steam Generator Level, condition A, which requires restoration of steam generator level to within limits within 15 minutes. This limiting condition for operation ensures that the mass and energy release to the containment and/or the amount of reactor coolant system cooling (and corresponding positive reactivity insertion) resulting from a main steam line break would be bounded by the accident analysis. The licensee restored steam generator level within six minutes. The reduction in SG1 superheat and fact that the EFW injects into the steam generators through the Auxiliary Feedwater path at a higher location than main feedwater caused slight overcooling of RCS flow into the core that resulted in an inadvertent positive reactivity insertion and reactor power change. This reactivity change was of a small magnitude and resulted in a very small power change.
The licensee performed an immediate investigation, communicated the event to staff, and issued a night order to reinforce expectations that operations staff review marked-up drawings and flow-paths during pre-job briefs. The licensee performed a causal evaluation to determine the cause of the inadvertent EFWP injection into SG1. The causal evaluation identified that the procedure section referenced by the work order (Section 3.4 of DB-OP-06234) had a generic title Starting EFW Pump that was not descriptive enough and included no cautions about the potential for water injection into the steam generators. The licensee concluded that these deficiencies were contrary to the Davis-Besse procedure writing guide (NG-QS-00121). It was not identified that the improper procedure was specified in the work order during the planning process, nor during independent reviews by the reactor operations staff, the shift crews, or the operators performing the evolution. Additionally, the pre-job brief did not verify the flow-path and the control room crew did not evaluate for the possibility of feeding the steam generators.
Corrective Actions: The licensee performed a causal evaluation to determine the cause of the inadvertent EFWP injection into SG1 and identify corrective actions. The causal evaluation identified that in addition to the procedure being inadequately written, human performance errors occurred during work planning, shift review, pre-job brief, and performance of the maintenance run. The licensee revised procedure DB-OP-06234 to move the Section 3.4 content into the Emergency Operations section and added a new Section 3.4 written to direct operation of the EFWP in recirculation mode. The licensee also performed an engineering analysis to confirm that the steam generator was not damaged by the inadvertent EFW injection. Additionally, the associated operators were removed from shift and remediated.
Corrective Action References: Condition Report 2019-07705
Performance Assessment:
Performance Deficiency: The licensees failure to utilize an appropriate procedure to operate the EFWP without inadvertently injecting into steam generator 1 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee failed to utilize an appropriate procedure to operate the EFW pump, resulting in the unplanned EFW injection into steam generator 1 that caused an uncontrolled positive reactivity insertion and entry into technical specification LCO 3.7.18 for six minutes due to operation outside the acceptable range of steam generator level for the amount of steam superheat.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors determined that the finding had very low safety significance (Green) because it:
- (1) was not a design deficiency;
- (2) did not represent a loss of system and/or function;
- (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and (4)did not result in the loss of a high safety-significant, non-technical specification train.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee failed to use their human performance tools to ensure the correct procedure was identified and performed for the circumstance. Licensee work planner review of the work order during the planning process did not identify that an improper procedure was specified, nor did separate reviews by the reactor operations staff, the shift crews, and the SROs performing the evolution. Additionally, the pre-job brief did not verify the flow path and the control room crew did not evaluate for the possibility of feeding the steam generators.
Enforcement:
Violation: Technical Specification Section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 9 addresses Procedures for Performing Maintenance and Section a, states in part Maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, on September 18, 2019, the licensee failed to establish a procedure to address the requirements of RG 1.33 Appendix A, Section 9. Specifically, the licensee failed to properly pre-plan and establish documented instructions that included provisions to ensure EFW recirculation. This resulted in an inadvertent injection into Steam Generator 1 affecting performance of the steam generator and causing operation outside of the acceptable region of the steam generator level to superheat curve, and affecting performance of the reactor core due to an uncontrolled reactivity insertion.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Trend in FLEX Batteries 71152 During a semi-annual trend review, the inspectors noted multiple condition reports initiated since January 2019 related to FLEX battery issues. Specifically, these condition reports identified issues with spent fuel pool level instrumentation batteries, various FLEX generators, the FLEX debris removal trucks and the alternate low-pressure FLEX emergency feedwater pump. The inspectors discussed the battery observations with the licensee and the licensee stated the issue was being concurrently tracked, as discussed in CR 2019-14009. The inspectors performed a search of the corrective action program and validated that the licensee considered proper inputs. The inspectors also reviewed the licensees evaluation to address the adequacy of FLEX battery maintenance activities. The inspectors did not identify any additional concerns.
Emergency Ventilation System Inadequate Acceptance Criteria Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.11] - 71153 NCV 05000346/2019004-03 Challenge the Open/Closed Unknown A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Title 10 Code of Federal Regulations Part 50, Appendix B, criterion V, "Instructions, Procedures, and Drawings," was identified when the licensee failed to prescribe the appropriate quantitative or qualitative acceptance criteria in a procedure used for determining that activities important to safety were satisfactorily completed. Specifically, the licensee failed to have appropriate acceptance criteria incorporated into the Emergency Ventilation System train 1 surveillance which resulted in the licensee failing to recognize the test had failed.
Description:
On July 19, 2019, the licensee was performing a scheduled monthly surveillance test of the emergency ventilation system (EVS) train 1. During this test, the operators noted the fan failed to produce the desired negative pressure within the shield building negative pressure area because the recirculation and exhaust dampers were not modulating as required.
Specifically, the differential pressure controller was set to maintain -0.75 inches water gauge by recirculation and exhaust damper modulation. The licensee declared the train inoperable and entered Technical Specification limiting condition of operation (LCO) 3.7.12, Station Emergency Ventilation System, Condition A, which states, in part, to restore the station EVS train to operable status within 7 days. The licensee determined that infantile failure of a controller caused the issue. They replaced the controller and the system tested satisfactorily within the LCO completion time.
While performing a past operability review due to the July failure, the licensee noted the surveillance performed on June 21, 2019, also failed to produce the desired negative pressure. The licensee determined this was a reportable condition because the 30-day inoperability time between the June surveillance and identification in July was in excess of the seven-day LCO plus the specified shutdown time. Specifically, TS 3.7.12 condition C requires the licensee to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if the required action and associated completion time was not met for Condition A. The licensee submitted licensee event report 05000346/2019-001 in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(i)(B) as a condition which was prohibited by the plants Technical Specifications.
The licensee performed a causal analysis and determined the failure to identify the failed surveillance test in June was due to a combination of inadequate procedural guidance and a gap in crew knowledge. Specifically, the acceptance criterion in DB-SS-03250, Emergency Ventilation system Train 1 Monthly Test, Revision 9, stated, in part, emergency ventilation system train 1 started from the control room and operated properly for at least fifteen minutes.
Proper operation was not specifically described in the acceptance criterion step. However, Note 4.7 stated, in part, recirculating damper CV5000B and exhaust damper CV5000A modulate to maintain a negative pressure of approximately 0.75 inch water gauge in the annulus area. Step 4.7 stated, in part, immediately after starting EVS fan 1, perform the following local checks: CV5000B, EVS fan 1 exhaust recirculation damper is controlling to maintain a negative 0.75 inches water gauge as indicated on PDI5000 or PDC5000. During the June test, the operator noted the dampers were maintaining at -0.45 inches water gauge; however, at the time this wasnt determined to be a failed test.
Through review of the causal analysis, the inspectors noted the licensee had an additional opportunity to identify the failed surveillance before the July test. Specifically, the system engineer questioned the June test results on July 10 while reviewing the completed surveillance. The individual discussed the observation with supervision and the on-shift operations crew, which was the same crew that had performed the June test. However, the licensee failed to identify the June surveillance test as an issue and therefore did not write a condition report. Instead, the licensee generated informal actions to have additional observation during the next surveillance scheduled for July 19, 2019. The inspectors also recognized the non-conservatism associated with the informal action to wait nine days until the next surveillance test, as it was not in alignment with the LCO completion time of seven days. The licensee subsequently identified the adverse condition of EVS during the July surveillance.
Corrective Actions: Immediate corrective actions included replacing the controller.
Additionally, both EVS train surveillance test procedures were modified to include specific acceptance criteria associated with the negative pressure. Additionally, a failure of the same model controller occurred in 2017. The licensee sent both the 2017 and 2019 failed controllers to the vendor for additional analysis.
Performance Assessment:
Performance Deficiency: The licensee failed to prescribe appropriate quantitative or qualitative acceptance criteria for determining that important activities were satisfactorily completed. Specifically, the licensee failed to include detailed acceptance criteria in the emergency ventilation system train 1 surveillance procedure, which resulted in a missed failed surveillance test.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, "Barrier Integrity Screening Questions," the inspectors determined the finding screened as having very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, auxiliary building or spent fuel pool.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, during the June 2019 surveillance test, when faced with unexpected pressure measurements the licensee failed to stop and evaluate the meaning of the test results.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, criterion V, Instructions, Procedures and, Drawings, states, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. The licensee established DB-SS-03250, the Emergency Ventilation System Train 1 Monthly Test, Revision 9 and prior, as the implementing procedure to ensure that EVS train 2 was able to perform its intended safety function, an activity affecting quality.
Technical Specification LCO 3.7.12, Station Emergency Ventilation System (EVS) requires, in part, two station EVS trains shall be operable in Modes 1, 2, 3, and 4. With one station EVS train inoperable, LCO 3.7.12 requires restoration to operable status within seven days. If the required action and associated completion time is not met, be in Mode 3 in six hours and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Contrary to the above, prior to September 10, 2019, the licensee failed to have a procedure that included the appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, the licensee failed to include acceptance criteria in the Emergency Ventilation System test procedures that ensured the surveillance had be completed satisfactorily.
Additionally, because the licensee was not aware of the EVS inoperability from June 21, 2019, to July 19, 2019, the licensee failed to take the actions required by TS LCO 3.7.12.
Enforcement Action: This violation is being treated as an 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 January 16, 2020, the inspectors presented the integrated inspection results to Mr. D. Huey, General Plant Manager and other members of the licensee staff.
- On October 25, 2019, the inspectors presented the Emergency Preparedness Inspection Exit Meeting inspection results to Mr. J. Vetter, Emergency Preparedness Manager and other members of the licensee staff.
- On December 13, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. D. Huey, General Plant Manager and other members of the licensee staff.
- On December 19, 2019, the inspectors presented the Licensed Operator Requalification program annual examination results review inspection results to Mr. D. Witt, Licensed Operator Requalification Training Supervisor and other members of the licensee staff.
- On January 16, 2020, the inspectors presented the Independent Spent Fuel Storage Installation Loading inspection results to Mr. D. Huey, General Plant Manager and other members of the licensee staff.
- On January 16, 2020, the inspectors presented the Independent Spent Fuel Storage Preoperational Testing inspection results to Mr. D. Huey, General Plant Manager and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60854.1 Corrective Action CR-2019-08812 Clarify Reporting Requirements for Dry Fuel Storage at 10/23/2019
Documents Davis-Besse
Resulting from
Inspection
Miscellaneous 2019 ISFSI Dry Run Training Exercise 05/16/2019
Dry Run Training Exercise Observations 05/24/2019
Response to NRC DFS Questions 10/16/2019
DSC Welding and NDE Dry Run Records 05/23/2019
NUHOMS EOS Weld Demonstration 04/25/2019
Procedures DB-MM-12314 Dry Shielded Canister Drying, Backfill and Sealing 0
Operations
60855.1 ALARA Plans 119-1081 ISFSI Loading Campaign ALARA Plan 0
Calculations 503948-0403 Thermal Evaluation of Loading Operation for the EOS- 2
37PTH DSC at Davis-Besse Nuclear Power Station
for 33 Water Drain out in the TC/DSC Annulus
C-NF-062.02-068 Fuel Selection for the 2019 Davis-Besse Dry Cask 10/18/2019
Storage Campaign, Revision 1, Addendum 3
C-NF-062.02-068 Fuel Selection for the 2019 Davis-Besse Dry Cask 10/13/2019
Storage Campaign, Revision 1, Addendum 1
C-NF-062.02-068 Fuel Selection for the 2019 Davis-Besse Dry Cask 1, 2
Storage Campaign
C-NF-062.02-068 Fuel Selection for the 2019 Davis-Besse Dry Cask 10/15/2019
Storage Campaign, Revision 1, Addendum 1
Corrective Action Selected Corrective Action Documents Created Since
Documents 2017
CR-2019-07062 Error in Fuel Selected for 2019 Dry Cask Campaign 08/22/2019
CR-2019-08339 Assembly Weight Error in Fuel Selection Calculation for 10/12/2019
the 2019 Day Cask Loading at Davis Besse
CR-2019-08369 Decay Heat Error in the Fuel Selection Calculation for the 10/13/2019
2019 Dry Cask Loading at Davis Besse
CR-2019-08408 Errors in Dry Fuel Storage Characterization Calc and 10/14/2019
Selection Calc Related to 2019 Canister 1
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-2019-08449 Errors in Dry Fuel Storage Characterization Calc and 10/15/2019
Selection Calc Related to 2019 Canister 2
CR-2019-08457 Need to Replace Four Assemblies Identified in planned 10/15/2019
Dry Cask Loading Identified
CR-2019-08503 Errors in Dry Fuel Storage Characterization Calc and 10/16/2019
Selection Calc Related to 2019 Canister 3
CR-2019-08709 Errors in Dry Fuel Storage Characterization Calc Related 10/21/2019
to 2019 Contingency Assemblies
CR-2019-08736 Dry Cask Storage - NDE Procedure Discrepancy 10/22/2019
CR-2019-08816 Dry Cask Storage Procedure Enhancement 10/23/2019
CR-2019-08892 Dry Cask Storage - Operational Issues with the Doerfer 10/25/2019
Wheelift Transporter
CR-2019-08901 Need to Replace Assemblies in Davis-Besse EOS4-8 10/25/2019
Canisters Identified
CR-2019-08946 Dry Cask Storage - Transfer Cask Trunnion Indication 10/26/2019
CR-2019-09019 Dust-Like Debris Identified on Assembly ID during Video 10/28/2019
Verification of Dry Cask
CR-2019-09135 Dry Cask Storage-Dose Rate Alarm 10/30/2019
CR-2019-09156 Thermal Cycle Counting for DSC #009 10/31/2019
CR-2019-09337 Dry Cask Storage - Wrong Beveling for DSC #11 Inner 11/04/2019
Top Cover Weld Surface
CR-2019-09611 Increased Dose due to More Work on Dry Shielded 11/13/2019
Canister #12
CR-2019-09779 Dry Cask Storage - Challenges with Dry Shielded 11/19/2019
Canister #15 Vacuum Drying
CR-2019-09792 Dry Cask Storage - DSC#15 Drain Port Cover Root Pass 11/20/2019
Weld Unable to be Completed
CR-2019-09828 Dry Cask Storage - Potential Issue with Fuel Drop 11/21/2019
Analysis
CR-2019-09830 Dry Cask Storage - Several suspect welds on Doerfer 11/21/2019
Wheelift transporter
CR-2019-10082 Individual Alarmed Passive Monitoring 12/02/2019
CR-2019-10088 Dry Cask Storage - Individual Received Dose Rate Alarm 12/03/2019
CR-2019-10187 Vendor Supplied Thermolumincescent Dosimetry Results 12/06/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
Corrective Action CR-2019-09200 Failure to Perform 10 CFR 72.48 Review for Dry Fuel 11/01/2019
Documents Storage Procedure Administrative Changes
Resulting from CR-2020-00135 Document Reference Excluded from the Davis-Besse 01/08/2020
Inspection EOS 10 CFR 72.212 Report
Miscellaneous Action Plan to Resume Vacuum Drying at Davis Besse 6
Selected 10 CFR 72.48 Screenings and Evaluations
NUHOMS EOS System Updated Final Safety Analysis 1
Report
2019 DCS Loading Campaign Oversight Review Plan 08/15/2019
21042- 146 TN Americas 10 CFR Part 72. 48 Applicability Review 10/18/2019
Regarding Water Boiling in the TC/DSC Annulus
21042-148 TN Americas 10 CFR Part 72. 48 Applicability Review 10/20/2019
Regarding Water Level in the TC/DSC Annulus
NDE Reports 6007-19-006-0807- NDE Report for Canister #10 10/30/2019
103019-03
607-19-006-0807- Liquid Penetrant Examination Report for DSC #11
110419
607-19-006-0807- Liquid Penetrant Examination Report for DSC #12 11/11/2019
111119
Procedures DB-MM-12312 Dry Shielded Canister Preparations for Loading 0
NUHOMS-EOS-37PTH
DB-MM-12313 Transfer Cask Handling for Fuel Loading NUHOMS-EOS- 0, 2
37PTH
DB-MM-12314 Dry Shielded Canister Drying, Backfill and Sealing 0-5
Operations NUHOMS-EOS- 37PTH
DB-MM-12315 Movement of Transfer Cask to the ISFSI Pad and Dry 0, 1
Shielded Canister Insertion into EOS-HSM
DB-MM-12316 Dry Shielded Canister Extraction from EOS-HSM 1
DB-MM-12318 Guidance for ISFSI Equipment Malfunctions NUHOMS- 0
EOS-37PTH
DB-MM-12319 Dry Shielded Canister Removal of Field Welds NUHOMS- 0
EOS-37PTH
NOP-OP-4503 Personnel Contamination Monitoring 11
Radiation DB-M-20180613-2 2018 ISFSI Pad Survey Report 06/13/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
Surveys DB-M-20190411-4 2019 ISFSI Radiation Survey Report 04/11/2019
DB-M-20191024-6 Survey of HSM, ISFSI Pad and Perimeter for DSC #9 10/24/2019
DB-M-20191031-4 Survey of HSM, ISFSI Pad and Perimeter for DSC #10 10/31/2019
DB-M-20191220-2 Post DCS Campaign HSM Pad Survey/ 12/20/2019
Work Orders 200731159 2019 SFP Cask Crane Functional Test 09/20/2019
200765066 2019 SFP Cask Crane Annual Inspection 08/29/2019
60856.1 Calculations 155170-C-C-00003 ISFSI Pad Structural Capacity Qualification 2
155170-C-C-00004 Auxiliary Building Structural Qualification 6
EOS01-0205 EOS Horizontal Storage Module (EOS-HSM) Weight & 1
CG Calculation
EOSTE-0206 EOS-TC125 Lifting Yoke Assembly Evaluation 1, 2
Corrective Action CR-2019-08808 Transfer Cask Lifting Yoke Design Calculation 10/23/2019
Documents
Corrective Action CR-2019-04479 Concerns Identified With Cask Crane Corbel Design 05/17/2019
Documents Calculation
Resulting from CR-2019-04963 Concerns Identified with Cask Crane Concrete Corbel 07/05/2019
Inspection (Bracket) Design Calculation
CR-2019-08808 Transfer Cask Lifting Yoke Design Calculation 10/23/2019
CR-2019-08912 NRC Dry Cask Inspection Identified Inadequate Technical 10/25/2019
Basis in Calculation 155170-C-C-00003
Drawings EOS01-3112 NUHOMS EOS System Construction and Assembly of 2
EOS-HSMS-FPS Segmented Base
EOSTE-4008 NUHOMS EOS System Transfer Equipment EOS-TC125 2
Lifting Yoke Assembly
EOSTE-4008 Orano TN Drawing, EOS-TC125 Lifting Yoke Assembly 0, 2
I4105-0000 Transfer Skid Assembly 1
NUH-03-7103 Standardized NUHOMS Horizontal Storage Module, 5
HSM-H Base
Engineering ECP No. 18-0014 Cask Crane Seismic Restraint Modification 04/15/2019
Changes
Miscellaneous Response to NRC Questions on Pad Model 03/05/2019
Cask Crane Repair Basis
EOSTE-0101 AREVA TN Document, Design Criteria Document (DCD) 1
Inspection Type Designation Description or Title Revision or
Procedure Date
for the Lifting Yokes
Study 1002263 Charpy Testing Temperature and Acceptance Criteria for 04/10/2019
ANSI N14.6-1993 Lift Yokes
Procedures DB-MM-06004 Spent Fuel Cask Crane Operation Revision 11
71111.01 Corrective Action CR 2019-07524 Discrepencies Associated with BA Heat Trace Circuit 148 09/11/2019
Documents CR 2019-08535 CFPP18Q Freeze Protection Cabinet Found Deenergized 10/17/2019
CR 2019-09186 Freeze Protection CKT 15 Indicates "****.*" 11/01/2019
CR 2019-09575 Heat Trace Circuits Not Operating Correctly PM-5289 11/12/2019
CR 2019-10068 TIC20350S Indicates "Open In P" 12/02/2019
CR 2019-10069 TIC20487S Indicates "Open In P" 12/02/2019
Procedures DB-OP-06913 Seasonal Plant Preparation Checklist 35
71111.04Q Corrective Action ATA-2019-14112 Several Fire Protection Procedures Need to be Enhanced 10/29/2019
Documents to Reflect the Same Information for FP Locked Valves
Resulting from
Inspection
Drawings 12501 Auxiliary Feedwater System 60
M-033C Decay Heat Train 2 30
OS 041A Sheet 1 Emergency Diesel Generator Systems 35
Procedures DB-OP-06011 High Pressure Injection System 34
DB-OP-06012 DH Loop 2 Normal Lineup Valve Checklist 73
DB-OP-06233 AFW Train 1 Switch and Breaker Checklist 45
DB-OP-06316 Diesel Operating Procedure 63
DB-OP-06610 Station Fire Suppression Water System 40
DB-SS-03091 MDFP Flow Path Valve Checklist 20
71111.04S Corrective Action CR 2018-10646 Containment Spray Pump #1 Motor Leads with Broken 12/04/2018
Documents Strands
CR 2018-11082 CS Pump 2 Pump Inboard Bearing Oiler Needs Adjusted 12/18/2018
Drawings M-034 Emergency Core Cooling System Containment Spray and 72
Core Flooding Systems
OS-005 Containment Spray System 14
Procedures DB-OP-06013 Containment Spray System 27
Work Orders WO 200707980 CS Pump 1 Comprehensive Quarterly Test 02/28/2019
WO 200713413 CS Pump 2 Quarterly Test 04/07/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.05Q Corrective Action CR 2019-08098 Pre-Fire Plan PFP-AB-323 Drawing Error Identified 10/03/2019
Documents
Resulting from
Inspection
Fire Plans PFP-AB-237 Auxiliary Feed Pump 1 Room Fire Area E 4
PFP-AB-312 Spent Fuel Pool Pump Room 6
PFP-AB-323 Risk Significant Area, High Voltage Switchgear Room B, 5
Room 323, Fire Area Q
Miscellaneous Davis-Besse Unit 1 Fire Hazard Analysis Report 28
Procedures PFP-AB-225 Makeup Pump Room Vestibule Rooms 225 and 226A 04
71111.07A Corrective Action CR 2018-01158 POD 2017-03523, Revision 1, Elbow Wall Thinning 03/09/2018
Documents CR 2019-07376 Impact to Plant Due to Extended Actibrom Chem Feed 09/05/2019
Shutdown
Drawings OS-020 Service Water System 103
OS-048A Chlorination System 16
Procedures DB-CH-06043 Intake Chlorination System 2
DB-CH-06900 Operational Chemical Control Limits 65
71111.11A Miscellaneous Davis-Besse Licensed Operator Requalification Program 12/19/2019
Annual Examination Summary Results for 2019
71111.11Q Miscellaneous ORQ-EPE-S111-R- Davis-Besse Licensed Operator Requalification Scenario 12/04/2019
Procedures DB-SP-03447 Decay Heat Train 2 Pump and Valve Test 6
NOBP-LP-2601 Human Performance Program 13
NOP-OP-1002 Conduct of Operations 14
71111.12 Corrective Action CR 2010-78416 AF 6451 Issue during AFW Train #2 Flowpath Verification 06/17/2010
Documents DB-SP-03164
CR 2010-78435 Potential Rework for ZC6451 06/17/2010
CR 2010-79809 AF6451 Found Failed Open and De-energized 07/17/2010
CR 2010-81273 Past Operability Review of AFW Positioner ZC6451 08/16/2010
CR 2017-12439 MDFP Oil Leak on LO Cooler Discharge Pipe Union 12/27/2017
CR 2018-02517 DC Bus Ground Received during Restoration of FW6459, 10/09/2018
MDFP Discharge to OTSG 1
CR 2018-06706 CV 5000A and CV 5000B Failed to Operated During EVS 07/27/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
Train 1 Monthly Test
CR 2018-08883 DC Bus Ground Received during Restoration of FW6459, 10/09/2018
MDFP Discharge to OTSG 1
CR 2019-06418 Critical Order ECP15-0138-004 Target Rock Work 07/30/2019
Dropped at T+1
CR 2019-06625 MDFP Minimum Recirc Flow 210 GPM 08/07/2019
CR 2019-06899 EVS Train #1 Exceeded Maintenance Rule Unavailability 08/16/2019
Limit
CR 2019-07507 Clarification Needed with Respect to Motor Driven 09/11/2019
Feedpump Alignment in Mode 1
Drawings 12501 Containment and Penetration Rooms 29
OS-0330 Emergency Ventilation System 16
Engineering ECP 15-0138-004 Target Rock Auxiliary Feedwater Power Supply Isolation 8
Changes (FV6460)
Miscellaneous Operator Logs
DB-SUB34-01 Station Emergency Ventilation System 07/19/2019
MRPM 37 Maintenance Rule Program Manual
NORM-ER-3102 FENOC Motor 8
NORM-ER-3103 Low and Medium Voltage Switchgear and Motor Control 7
Centers
Procedures DB-SS-03090 Motor Driven Feed Pump Monthly Valve Verification 11
DB-SS-03091 Motor Driven Fuel Pump Quarterly Test 21
NG-DB-00001 On-Line Risk Management 15
NOBP-ER-3900 Equipment Reliability Common Definitions and Structure 11
NOP-ER-1001 Continuous Equipment Performance Improvement 6
NOP-ER-3004 FENOC Mainenance Rule Program 5
NORM-ER-3311 I&C Loop Components 10
Work Orders 200638294 Install Target Rock Power Converter per ECP 0138-004 08/28/2019
200772426 Terminate Control Cables within the Newly Installed 06/24/2019
Target Rock AC/DC-DC Power Converter
200798332 Identification of Cable to Support WO 200638294 08/28/2019
71111.13 Corrective Action CR 2019-01589 DFP Room Sump Pump Check Valves Degraded 02/21/2019
Documents CR 2019-01929 In Field Inspections for ECCS Sump Pump Suction 03/04/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
Strainer and Base Plate Bolt
CR 2019-01937 DR42 Leaks When Only the 'A' Pump Runs in the DH 03/05/2019
Cooler Pit Sump
CR 2019-02244 BACC: Pinhole Leak Discovered in #1 ECCS Sump Pump 03/13/2019
Discharge Line
CR 2019-02845 ECCS Room 1 Sump Pump Mechanical Alternator not 03/27/2019
Operating
CR 2019-04724 Trending of ECCS Sump Pump Discharge Piping 05/28/2019
Leakage
CR 2019-05791 Inadequate Coatings in Order 200428692 07/08/2019
CR 2019-08598 BACC: Leak on 46-HSC-155-1 Shop Weld 'C' on ECCS 10/18/2019
- 1 Sump Pump Discharge
CR 2019-08601 BACC: Leak on Field Weld '16' on Drawing M-0246B 10/18/2019
CR 2019-08602 BACC: Leak on Field Weld '17' on Drawing M-0246B 10/18/2019
CR 2019-08604 BACC: Leak on 46-HSC-155-6 Shop Weld 'A' (DH Cooler 10/18/2019
Pit Sump Pump Discharge)
CR 2019-08605 BACC: Leak on 46-HSC-155-6 Shop Weld 'E' (ECCS #1 10/18/2019
and DH Cooler Pit Sump Pump Discharge Connection)
CR 2019-08606 BACC: Leak on 46-HSC-155-6 Shop Weld 'F' (ECCS #1 10/18/2019
and DH Cooler Pit Sump Pump Discharge Connection)
CR 2019-09729 ECCS Room 1 Sump Pump 1A Degraded Operation 11/18/2019
CR 2019-09782 ECCS #1 Sump Clean-Out Findings 11/19/2019
CR 2019-10345 Accumulation of Sludge in DH Cooler Pit Sump 12/12/2019
Miscellaneous System Description for Plant Process Computer System 09/26/2019
NOP-OP-1007-01 Risk Management Plan 7
Procedures DBBP-OPS-0003 On-Line Management Process 15
NOP-OP-1007 Risk Management 30
Work Orders WO 200704931 Remove and Replace the Existing Plant Computer 10/15/2019
71111.15 Corrective Action CR 2019-01425 Station Battery 2N Found with Low Specific Gravity 02/15/2019
Documents CR 2019-01589 DFP Room Sump Pump Check Valves Degraded 02/21/2019
CR 2019-01929 In Field Inspections for ECCS Sump Pump Suction 03/04/2019
Strainer and Base Plate Bolt
Inspection Type Designation Description or Title Revision or
Procedure Date
CR 2019-01937 DR42 Leaks When Only the 'A' Pump Runs in the DH 03/05/2019
Cooler Pit Sump
CR 2019-02244 BACC: Pinhole Leak Discovered in #1 ECCS Sump Pump 03/13/2019
Discharge Line
CR 2019-02845 ECCS Room 1 Sump Pump Mechanical Alternator not 03/27/2019
Operating
CR 2019-04724 Trending of ECCS Sump Pump Discharge Piping 05/28/2019
Leakage
CR 2019-05791 Inadequate Coatings in Order 200428692 07/08/2019
CR 2019-07507 Clarification Needed with Respect to Motor Driven 09/11/2019
Feedpump Alignment in Mode 1
CR 2019-07971 EDG #2 Cylinder 7 Injector Linkage has Slight Drag 09/30/2019
CR 2019-08044 #2 EDG Piston Cylinder #14 has Small Indication on 10/02/2019
Piston Ring
CR 2019-08057 Missing Roller Pins Identified on Air Box Covers 14, 18, 10/02/2019
and 19
CR 2019-08315 #2 Emergency Diesel Generator Outage Critique Roll-Up 10/11/2019
CR 2019-08598 BACC: Leak on 46-HSC-155-1 Shop Weld 'C' on ECCS 10/18/2019
- 1 Sump Pump Discharge
CR 2019-08601 BACC: Leak on Field Weld '16' on Drawing M-0246B 10/18/2019
CR 2019-08602 BACC: Leak on Field Weld '17' on Drawing M-0246B 10/18/2019
CR 2019-08604 BACC: Leak on 46-HSC-155-6 Shop Weld 'A' (DH Cooler 10/18/2019
Pit Sump Pump Discharge)
CR 2019-08605 BACC: Leak on 46-HSC-155-6 Shop Weld 'E' (ECCS #1 10/18/2019
and DH Cooler Pit Sump Pump Discharge Connection)
CR 2019-08606 BACC: Leak on 46-HSC-155-6 Shop Weld 'F' (ECCS #1 10/18/2019
and DH Cooler Pit Sump Pump Discharge Connection)
CR 2019-08607 BACC: Leak on 46-HSC-145-31 Shop Weld 'M' (ECCS 10/18/2019
CR 2019-08814 Degraded Spare Fuel Injector Identified during the 10/23/2019
Performance of PM 11219
CR 2019-09010 10CFR21-0127 From Engine Systems Incorporated (ESI): 10/28/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
EMD Fuel Injector - Seized Plunger and Bushing
CR 2019-09248 OP 3006 Miscellaneous Instrument Shift Checks 11/02/2019
Performed with Invalid Group 38 Data
CR 2019-09251 Group 38 Rod Index not Updating, Indicated 293.36 while 11/02/2019
Actual RI on the PIP was a Different Value
CR 2019-09729 ECCS Room 1 Sump Pump 1A Degraded Operation 11/18/2019
CR 2019-09782 ECCS #1 Sump Clean-Out Findings 11/19/2019
CR 2019-09966 Battery Specific Gravity is out of Program Limit 11/26/2019
CR 2019-10345 Accumulation of Sludge in DH Cooler Pit Sump 12/12/2019
CR 2019-10422 Pressure Differential Switch Found Outside Tech Spec 12/16/2019
Allowable As-Found Range
Drawings E-18, sh 2 SFRCS Logic Diagram Logic Channels 2 & 4 and 6
Actuation Channel 2
M-0060 Auxiliary Feedwater System 60
M-006C Main Feedwater System 31
M-0078 Piping and Instrument Diagram Steam Generator 62
Secondary System
Miscellaneous Davis-Besse Nuclear Power Station Train 2 Class 1E 12/13/2018
Safety Related 125 Volt Batteries, Battery 2P and Battery
2N Expected Life and Condition Assessment; Standby
Power System Consultants, Inc.
Procedures DB-ME-03004 Station Battery Monthly Surveillance 7
DB-MI-03204 Channel Functional Test and Calibration of SFRCS 16
[Steam and Feedwater Rupture Control System]
Actuation Channel 2, Steam Generator Differential
Pressure Inputs PDS-2685A, PDS-2685B, PDS-2686C
and PDS-2686D
DB-OP 03006 Miscellaneous Instrument Shift Checks 63
Work Orders 200808350 Replace ECCS Sump 1-1 Pump/Motor with Motor/Pump 11/19/2019
from DB-P89-3A
200808351 Troubleshoot ECCS Sump 1-1 Pump B 11/18/2019
71111.19 Drawings OS-041C Emergency Diesel Generator Diesel Oil System 19
Procedures DB-OP-06316 Diesel Generator Operating Procedure 63
Work Orders WO 200728256 AFP 2 Quarterly Test 11/20/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
WO 200733023 PM 0728, PM 0728 KS2 - Cln Ins EDG2
71111.22 Drawings 7749-E-30-34 Schematic Diagram Davis-Besse Safety Feature
Activation System
J-102 SH. 17A RC LOOP 1 HLG WR Press SFAS Ch3 (PD-RC2B3) 1
Miscellaneous Final Report of AMS Tests Response Time Testing of 12/2019
Pressure Transmitters at Davis Besse Unit 1
Procedures DB-MI-03119 Safety Features Actuation System On-Line Response 8, 9
Time Data Collection
DB-PF-03291 Containment Personnel and Emergency Airlocks Seal 14
Leakage Test
71114.04 Corrective Action CR-2018-09935 MS-C-18-11-24 Incorrect Procedure Revision Identified in 11/08/2018
Documents TSC
CR-2019-00093 Emergency Plan Rev 33 Submittal to the NRC did not 01/04/2019
Meet a Requirement in NG-NS-00500, Nuclear
Emergency Response
CR-2019-05255 10CFR 50.54(q) Review was not Performed on Procedure 06/17/2019
Revisions
Corrective Action CR-2019-08756 Need to Perform 50.54(q) Reviews on Three Procedures 10/22/2019
Documents that were Revised and Made Effective Without these
Resulting from Reviews
Inspection
Miscellaneous DB-2018-031-00 10 CFR 50.54(q)(3) Screen/Evaluation 08/23/2018
71114.06 Corrective Action CR 2019-08495 EP Drill - Failure to Notify On-Call ERO Personnel within 10/16/2019
Documents Ten Minutes of Classification of an Event that Requires
Initial Activation
CR 2019-08504 EP Drill - Controller Provided Incorrect Coaching to Dose 10/15/2019
Assessment
CR 2019-09204 RMT Communication Issues Identified in the October 15, 11/01/2019
2019 EP Integrated Drill
71124.03 Miscellaneous Kit Number C005140 Breathing Air Quality Report - Bauer System 04/08/2019
Sample Kit Number Breathing Air Quality Report - Bauer System 12/19/2018
105974S
Sample Kit Number Breathing Air Quality Report - Bauer System 07/26/2019
1711
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedures DB-HP-060000 Operation of Air Compressors 9
NOP-OP-4303 Respirator Quantitative Fit Test Portacount Pro 8030 5
NOP-OP-4310 Firehawk M7 Self Contained Breathing Apparatus 9
71124.04 Corrective Action CR-2019-10082 Individual Alarmed Passive Monitoring 12/09/2019
Documents CR-2019-10187 Vendor Supplied Thermoluminescent Dosimetry Results 12/06/2019
Corrective Action ATA-2019-15867 NOP-OP-4205 TLD/DRD Comparison Enhancement 12/13/2019
Documents CR-2019-10379 Diving Dosimetry Enhancements 12/13/2019
Resulting from
Inspection
Miscellaneous TLD 2301380218 TLD/DRD Deviation Investigation Report 05/03/2018
TLD 2304500218 TLD/DRD Deviation Investigation Report 05/03/2018
TLD 2305640218 TLD/DRD Deviation Investigation Report 05/03/2018
TLD 2307040218 TLD/DRD Deviation Investigation Report 05/03/2018
71124.08 Corrective Action CR-2018-03364 Performance Issues with the Liquid Waste Processing 4/18/2018
Documents System
CR-2019-05986 GEM-5 Portal Monitor at LLRWSF High Background 7/31/2019
Counts During TPE Calibration
CR-2019-06639 Continued Rainwater Roof Leakage into the LLRWSF Cell 8/14/2019
Area
CR-2019-08786 Potential Trend - Reverse Osmosis/Duratek Equipment 10/23/2019
Reliability
Miscellaneous GEN-USDOT_FEN US DOT Regulations Awareness Training 1
RP- Radioactive Material Packaging, Transport and Disposal 2
RADSHIPPING_FEN Training USDOT and NOP-OP-5021 Training
Procedures Davis-Besse PCP Process Control Program 9
DB-HP-01344 Source Term Determination 3
DB-HP-01511 Low-Level Radioactive Storage Facility (LLRSWF) 8
DB-HP-01712 10 CFR 61 Sampling for Waste Classification 1
Shipping Records 2018-1008 Cask with Filters in Poly Container 06/22/2018
2018-1029 Metal Cask of Filters 12/15/2018
2019-1001 Cask with Resin in Poly Container 06/29/2019
71151 Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7
Procedures DB-SP-03357 RCS Water Inventory Balance 20
Inspection Type Designation Description or Title Revision or
Procedure Date
NG-EN-00327 RCS [Reactor Coolant System] Integrated Leakage 3
Program
71152 Corrective Action 2019-07705 Water was Flowed from the EFWST to OTSG 1 while 09/18/2019
Documents Running the EFW Pump to Recirc Engine Coolant
CR 2018-10631 Low Radiator Fluid in EFW Pump 12/03/2018
CR 2019-03728 FLEX Portable Generator FX-PG1 will not Start 04/21/2019
CR 2019-03969 Flex Truck DRT2 will not Start 04/30/2019
CR 2019-04317 FLEX Generator for Fan Alley and FLEX Building Failed 05/11/2019
to Start
CR 2019-04572 FLEX Portable Diesel Generator Battery Failure Trend CR 05/21/2019
CR 2019-05699 Cabinet CS787A, Primary SFPLI, and CS787B, Backup 07/03/2019
SFPLI, Batteries
CR 2019-05754 SFPLI Batteries not Charged for Greater than 72 Hours 07/06/2019
CR 2019-08692 Fuel Cube 1 Battery Requires Recharge 10/21/2019
CR 2019-08693 Fuel Cube 2 Battery Requires Recharge 10/21/2019
CR 2019-08781 FLEX Debris Removal Truck #1 - Dead Battery 10/22/2019
CR 2019-09022 L5701 BKR 34 Found Tripped (SFP Level Indicator 10/28/2019
C5787B)
CR 2019-09042 Alt. LP FLEX EFW Pump Failure to Start 10/29/2019
CR 2019-09330 FLEX - Battery Issues - Trending 11/04/2019
Miscellaneous Davis-Besse Unit Log
Technical Davis-Besse Tech Spec Bases
Specifications
Procedures DB-OP-06234 Emergency Feedwater System Multiple
Revisions
Work Orders 200724732 PM 12055 EFW Diesel, Gear and Pump 0
71153 Corrective Action CR 2017-10586 Damper CV5000A Failed to Open during DB-SS-03250 10/19/2017
Documents (EVS Train 1 Monthly)
CR 2018-06706 CV 5000A and CV 5000B Failed to Operate during EVS 07/27/2018
Train 1 Monthly Test
CR 2019-06097 CVS5000A, EVS Fan 1 Discharge Damper, not Operating 07/19/2019
Properly
CR 2019-06613 EVS Train 1 Past Operability Review Identifies Condition 08/06/2019
Prohibited by Technical Specifications
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous LER 2019-001 Emergency Ventilation System Train Inoperable due to 0
Non-Specific Test Description of Damper Operation
Work Orders WO 200720913 EVS Train 1 Monthly Test 06/21/2019
34