IR 05000346/2021002
| ML21224A237 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/12/2021 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2021001 | |
| Download: ML21224A237 (19) | |
Text
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2021002 AND 07200014/2021001
Dear Mr. Brown:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On July 27, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Davis-Besse Nuclear Power Station.
August 12, 2021 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Billy C. Dickson, Jr., Chief 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:
Report Number:
05000346/2021002 AND 07200014/2021001
Enterprise Identifier:
I-2021-002-0078
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Davis-Besse Nuclear Power Station
Location:
Oak Harbor, OH
Inspection Dates:
April 01, 2021 to June 30, 2021
Inspectors:
R. Cassara, Resident Inspector
J. Cassidy, Senior Health Physicist
J. Dalzell, Project Engineer
R. Edwards, Senior Health Physicist
D. Mills, Senior Resident Inspector
R. Ruiz, Project Engineer
Approved By:
Billy C. Dickson, Jr., Chief
Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Davis-Besse Nuclear Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Spent Fuel Storage Cask Design Changes Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000346/2021002-01 Open/Closed Not Applicable 60855 The inspectors identified a Severity Level IV Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 72.48(d)(1), Changes, Tests, and Experiments, for failing to maintain a record of a change to the spent fuel storage cask design that includes a written evaluation providing the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to 10 CFR 72.48(c)(2). Specifically, the licensee failed to recognize in 10 CFR 72.48 screening No. 721042-146 that changes to thermal conditions in the annulus potentially impact the analyzed fuel cladding temperatures, which consistent with NRC endorsed industry guidance, would require an evaluation providing the bases for determining the change does not require a license amendment pursuant to 72.48(c)(2). However, an evaluation was not performed. Additionally, in the changes described in 10 CFR 72.48 evaluation No. 721042-155, the licensee failed to demonstrate the supporting adiabatic heat up calculation, which differed from the ANSYS Fluent models in the NUHOMS EOS Updated Final Safety Analysis Report (UFSAR), was a methodology approved by the NRC for the intended application consistent with 10 CFR 72.48(a)(2)(ii) and would not require a license amendment.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000346/2019004-01 Unresolved Item Regarding Peak Fuel Clad Temperature During Vacuum Drying of Canister 9 60855 Closed
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On May 21, 2021, the unit was down powered to 40 percent to perform scheduled testing of the turbine stop valves. The unit was returned to rated thermal power on May 22, 2021 and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from high lake levels and localized flooding in the area surrounding the plant due to heavy rain and high winds during the week ending June 1, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency diesel generator train 1 during the week ending May 22, 2021
- (2) Station blackout diesel generator during the week ending June 26, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Control room and adjacent support rooms, fire area FF during the week ending May 22, 2021
- (2) Service water pipe tunnel, fire area BG during the week ending June 12, 2021
- (3) Auxiliary feed pump 2 room, fire area F during the week ending June 26, 2021
- (4) Service water pump area and diesel fire pump area, rooms 51 and 52, fire area BF during the week ending June 26, 2021
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) PT-RCA1 reactor coolant system pressure transmitter replacement during the week ending May 29, 2021
- (2) Station blackout diesel generator license renewal maintenance during the week ending June 12, 2021
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Emergency diesel generator 1 voltage regulator reference adjuster replacement during the week ending June 26, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Elevated risk due to downpower to 40 percent for turbine stop valve testing during the week ending May 22, 2021
- (2) Elevated risk during emergent work in containment to replace PT-RC2A1 reactor coolant system pressure transmitter during the week ending May 29, 2021
- (3) Elevated risk while emergency diesel generator 1 inoperable due to failed field flash switch during the week ending May 29, 2021
- (4) Elevated risk during period of high winds and rain causing local flooding during the week ending May 29, 2021
- (5) Elevated risk due to the failure of emergency diesel generator 1 voltage regulator reference adjuster during the week ending June 26, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Component cooling water train 2 ventilation damper malfunction, CR 2021-04374
- (2) Cycle 22 1/8 core location H14 max-segment peaking deviation approaching BMAC limit, CR 2021-04524
- (3) EDG 1 failed to reach required voltage and frequency during the 184-day test, CR 2021-04282
- (4) EDG 1 overvoltage during monthly run, CR 2021-04913
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Installation of constant level oilers on decay heat pump 1 during the week ending May 29, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Emergency diesel generator train 1 following replacement of field flash selector switch during the week ending May 29, 2021
- (2) Emergency diesel generator train 1 following replacement of voltage regulator reference adjuster during the week ending July 3, 2021
- (3) Personnel hatch local leak rate testing following containment entry during the week ending May 29, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Emergency diesel generator 2 testing during the week ending June 5, 2021
- (2) Channel functional test of reactor coolant pump monitor to steam feed rupture control system channel 1 and reactor protection system channel 1 during the week ending June 19,
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensees radiological work planning for the following work activities.
- (1) Repair/Replace Gasket on the Cavity Nuclear Instrumentation (NI) Covers under Radiation Work Permit (RWP) 120-5115
- (2) Insulation Work Activities in Containment under Radiation Work Permit (RWP)120-5016
- (3) Contractor Services Activities in Containment under Radiation Work Permit (RWP)120-5032
- (4) Under Vessel Inspections Following NI Covers under Radiation Work Permit (RWP)120-5103 Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (4 Samples)
The inspectors evaluated dose estimates and exposure tracking for the following work activities.
- (2) Insulation Work Activities in Containment under Radiation Work Permit (RWP)120-5016
- (3) Contractor Services Activities in Containment under Radiation Work Permit (RWP)120-5032
- (4) Under Vessel Inspections Following NI Covers under Radiation Work Permit (RWP)120-5103
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Unit 1 Control 1 Control Room Emergency Ventilation System
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Frisker - Ludlum Model 12 2.7.625 ready for use
- (2) Extendable Survey Meter - Mirion Telepole 2.7.342 ready for use
- (3) Extendable Survey Meter - Mirion Telepole 2.7.343 ready for use
- (4) Portable Ion Chamber - Victoreen 451B 2.7.525 ready for use
- (5) Portable Ion Chamber - Victoreen 451B 2.7.535 ready for use
- (6) Portable Ion Chamber - Victoreen 451B 2.7.616 ready for use
- (7) Personnel Contamination Monitor - Mirion ARGOS-5AB 2.12.111 in auxiliary building
- (8) Personnel Contamination Monitor - Mirion ARGOS-5AB 2.12.96 at auxiliary building exit
- (9) Portal Monitor - Mirion GEM-5 2.12.116 at auxiliary building exit
- (10) Portable Air Monitor - Thermo Fisher AMS-4 2.8.171 in auxiliary building
INSPECTION RESULTS
Spent Fuel Storage Cask Design Changes Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000346/2021002-01 Open/Closed Not Applicable 60855 The inspectors identified a Severity Level IV Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 72.48(d)(1), Changes, Tests, and Experiments, for failing to maintain a record of a change to the spent fuel storage cask design that includes a written evaluation providing the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to 10 CFR 72.48(c)(2).
Specifically, the licensee failed to recognize in 10 CFR 72.48 screening No. 721042-146 that changes to thermal conditions in the annulus potentially impact the analyzed fuel cladding temperatures, which consistent with NRC endorsed industry guidance, would require an evaluation providing the bases for determining the change does not require a license amendment pursuant to 72.48(c)(2). However, an evaluation was not performed.
Additionally, in the changes described in 10 CFR 72.48 evaluation No. 721042-155, the licensee failed to demonstrate the supporting adiabatic heat up calculation, which differed from the ANSYS Fluent models in the NUHOMS EOS Updated Final Safety Analysis Report (UFSAR), was a methodology approved by the NRC for the intended application consistent with 10 CFR 72.48(a)(2)(ii) and would not require a license amendment.
Description:
In October 2019, the licensee loaded the first Certificate of Compliance (CoC)1042, Amendment 0, NUHOMS EOS System. While processing their first EOS-37 dry shielded canister (DSC), DSC No. 9, the licensee experienced unexpected issues complicating the drying process. Specifically, the licensee was unable to demonstrate the dryness criterion was met during vacuum drying as specified in the NUHOMS EOS Technical Specification (TS) limiting condition of operation (LCO) 3.1.1. LCO 3.1.1 states, in part, that The DSC vacuum drying pressure shall be sustained at or below 3 Torr (3 mm Hg)absolute for a period of at least 30 minutes following evacuation. While troubleshooting the issue, the licensee backfilled the canister with helium so that the fittings could be checked for leakage. When the licensee backfilled the canister with helium, the water in the annulus began to rapidly boil. The boiling in the annulus created a safety hazard to personnel, so the licensee backed out of the procedure by drawing a vacuum. The licensee worked with the CoC holder and eventually identified and fixed a leaking fitting that was preventing them from meeting the dryness criteria. The licensee then completed processing the canister and was able to meet TS requirements.
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 UFSAR, Revision 1. Once the licensee completed processing the canister, the licensee consulted with the CoC holder to address the issues experienced during the vacuum drying process. The licensee made several changes to the UFSAR using the 10 CFR 72.48 process. To complete a review of the thermal analysis and the changes made to the UFSAR, the inspectors opened Unresolved Item (URI)05000346/2019004-01 (ML20035D918).
The NRC staff reviewed the licensees corrective actions associated with the conditions encountered during troubleshooting. This included a review of calculations concluding that temperatures did not exceed the maximum peak cladding temperature limits specified in the UFSAR. Also reviewed were changes to the UFSAR made following the issues encountered during vacuum drying of DSC No. 9. The NRC staff identified the following issues associated with the licensees UFSAR changes:
1) Section 4.5.11 of the EOS UFSAR states the water in the annulus is monitored and replenished with fresh water to prevent boiling, and to maintain the water level if excessive evaporation occurs Presence of water within the annulus maintains the maximum DSC shell temperature below the boiling temperature of water in open atmosphere (223°F). Title 10 CFR 72.48 screening No. 721042-146, dated October 18, 2019, revised these statements in the UFSAR. Specifically, the licensee changed the language in the UFSAR from no boiling of water in the annulus to an expectation of boiling at high heat loads. The change also provided additional instructions that the annulus must remain open to the atmosphere and how to add water to the annulus to ensure water level is maintained.
In the screening, the licensee stated that the changes being made were editorial in nature and provided additional clarification. However, UFSAR Section 4.5.11 was consistent with the NRCs Safety Evaluation Report for this system which stated that the water in the annulus would be maintained below the boiling temperature of water to ensure the canister shell would be maintained below 223°F at a given pressure. These assumptions can only be met with a constant pressure in the DSC and subcooled water in the annulus so that the evaluation performed remained valid. Hence, boiling in the annulus would have an adverse effect on the design function conditions that maintain the DSC shell below 223°F during vacuum drying operations and subsequently the design function to keep peak cladding (a fission product barrier) temperatures within limits. Therefore, the licensee incorrectly concluded in their screening that there were no changes involving a system, structure, or component that adversely affected a design function described in the UFSAR. Furthermore, the licensee failed to recognize that changes to thermal conditions in the annulus and DSC shell temperatures potentially impact the analyzed fuel cladding temperatures. Potential changes to fuel cladding impacts, adverse or not, should be evaluated per 72.48 as noted in industry guidance endorsed by the NRC in Regulatory Guide 3.72, Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments, Revision 0. These evaluations are required to provide the bases for determining the change does not require a license amendment pursuant to 72.48(c)(2).
2) In 10 CFR 72.48 evaluation No. 721042-155, dated October 29, 2019, the licensee evaluated a change to the UFSAR establishing additional limits for a canister in vacuum drying. Specifically, the change modified steps 17 and 24 in Section 9.1.3 of the UFSAR limiting the canister to a pressure below 3 Torr for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> before pressure must then be raised. This change was supported by calculation No. 503948-0404, Revision 0, that evaluated the thermal impact of the proposed UFSAR changes establishing additional vacuum drying operation limitations.
Section 4.4, Thermal Evaluation for Storage, of the EOS UFSAR states ANSYS Fluent CFD [Computational Fluid Dynamics] models are used to demonstrate that the maximum temperatures of key components such as fuel cladding, concrete, heat shields, etc. are below maximum temperature limits. Section 4.5.2.2 of the EOS UFSAR states similar to the modeling approach used for evaluation of storage conditions, the unstructured meshes for the EOS-37PTH DSC basket assembly and the EOS-TC125 are imported and combined into ANSYS Fluent to create an integrated model. Finally, Section 4.5.11 states the EOS-37 DSC models described in Section 4.5.2 are used to determine the maximum fuel cladding temperatures for vacuum drying operations. In 72.48 evaluation No. 721042-155, the licensee concluded that calculation No. 503948-0404, Revision 0, follows the same methodology as described in Section 4.5 of the UFSAR. Therefore, this change does not depart from a method of evaluation described in the UFSAR. As noted above, the UFSAR establishes that ANSYS Fluent models are used to demonstrate key components are below maximum temperature limits. However, calculation No. 503948-0404, Revision 0, used the maximum fuel cladding temperature calculated in the UFSAR and assumed an adiabatic heat up for the time duration being evaluated. The heat up rate chosen was taken from UFSAR Section 4.4.8. This section provides a method for comparing EOS 37 DSC heat up rates to the EOS 89 DSC, but it does not provide a method to demonstrate that the maximum temperatures of key components such as fuel cladding are below maximum temperature limits as stated in Section 4.4 of the EOS UFSAR. In the 72.48 evaluation, the licensee failed to demonstrate that the adiabatic heat up calculation, which differed from the ANSYS Fluent models in the EOS UFSAR, was a methodology approved by the NRC for the intended application consistent with 10 CFR 72.48(a)(2)(ii).
Corrective Actions: The concern was placed in the corrective action program. Following initial loading of DSC No. 9, calculations were performed by the licensee, and independently reviewed by the NRC, which concluded that temperatures did not exceed the maximum peak cladding temperature limits specified in the UFSAR. Therefore, there was no immediate safety concern. Additional corrective actions are still in progress and include evaluating the need for additional changes to restore compliance as well as performing a causal evaluation regarding the circumstances of the non-compliance.
Corrective Action References: CR-2021-05199; Potential NCV of 10 CFR 72.48 for 2019 DB Fuel Loading Campaign; July 8, 2021
Performance Assessment:
None Screening: The inspectors determined that the violation was of more than minor significance using NRC Enforcement Manual, Appendix E, "Example of Minor Issues." Specifically, the example for Minor changes to requirements was found to be similar and resulted in a more than minor determination since there was reasonable likelihood that the change would require prior NRC approval.
Significance: In accordance with Section 2.2 of the Enforcement Policy, ISFSIs are not subject to the Significance Determination Process (SDP) and traditional enforcement will be used for these facilities. Traditional enforcement violations are not assessed for cross-cutting aspects.
Enforcement:
Severity: The inspectors determined that the violation could be evaluated using Section 6.1.d.2 of the NRC Enforcement Policy as a Severity Level IV violation because, although more than minor, the resultant condition was of very low safety significance because the changes did not result in temperatures in the canister exceeding regulatory limits.
Violation: Title 10 CFR 72.48(d)(1) requires, in part, the licensee to maintain records of changes in the facility or spent fuel storage cask design, of changes in procedures, and of tests and experiments made pursuant 10 CFR 72.48(c). These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section.
Title 10 CFR 72.48(c)(2)(viii) requires, in part, that a specific licensee obtain a license amendment pursuant to 10 CFR 72.56 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the safety analyses performed.
Title 10 CFR 72.48(a)(2)(ii) states, in part, that definitions for the purposes of this section include departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases means changing from a method described in the FSAR to another method unless that method has been approved by NRC for the intended application.
UFSAR Section 4.4, Thermal Evaluation for Storage, of the EOS UFSAR states, in part, ANSYS Fluent CFD [Computational Fluid Dynamics] models are used to demonstrate that the maximum temperatures of key components such as fuel cladding, concrete, heat shields, etc. are below maximum temperature limits.
UFSAR Section 4.5.11 states the EOS-37 DSC models described in Section 4.5.2 are used to determine the maximum fuel cladding temperatures for vacuum drying operations.
Section 4.5.11 also states the water in the annulus is monitored and replenished with fresh water to prevent boiling. The presence of water within the annulus maintains the maximum DSC shell temperature below the boiling temperature of water in open atmosphere (223°F).
Contrary to the above, on October 18 and October 29, 2019, the licensee failed to maintain a record of two changes to the spent fuel storage cask design that includes a written evaluation providing the bases for the determination that the change did not require a license amendment pursuant to 10 CFR 72.48(c)(2). Specifically, the licensee failed to recognize in 10 CFR 72.48 screening No. 721042-146 that changes to thermal conditions in the annulus and DSC shell temperatures potentially impact the analyzed fuel cladding temperatures, which would require an evaluation providing the bases for determining the change does not require a license amendment pursuant to 72.48(c)(2). However, an evaluation was not performed. In the changes described in 10 CFR 72.48 evaluation No. 721042-155, the licensee failed to demonstrate the adiabatic heat up calculation, which differed from the ANSYS Fluent models in the EOS UFSAR described above, was a methodology approved by the NRC for the intended application consistent with 10 CFR 72.48(a)(2)(ii) and would not require a license amendment.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
The disposition of this violation closes URI: 05000346/2019004-01.
URI Unresolved Item Regarding Peak Fuel Clad Temperature During Vacuum Drying of Canister #9 URI 05000346/2019004-01 60855
Description:
This URI is being closed to a Severity Level IV NCV in this report.
Corrective Action Reference(s): CR-2019-09156
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 27, 2021, the inspectors presented the integrated inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.
On May 14, 2021, the inspectors presented the radiation protection inspection results to Mr. D. Huey, General Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
Calc No. 503948-
0405
Thermal Evaluation of EOS-37PTH in EOS-TC125 During
the Vacuum Drying Process for the 2019 Davis Besse Dry
Cask Loading Storage Campaign
CFR Screening
No. 721042-146
TN Americas 10 CFR Part 72. 48 Applicability Review
Regarding Water Boiling in the TC/DSC Annulus
60855
Miscellaneous
CFR Screening
No. 721042-155
TN Americas 10 CFR Part 72. 48 Applicability Review
Regarding Time Limit in Low Vacuum Pressure
Corrective Action
Documents
CR-2021-04332
Environmental Conditions Necessitate Entering RA-EP-
2830 Flooding Off-Normal Procedure
05/30/2021
Procedures
RA-EP-02830
Emergency Plan Off-Normal Occurrence Procedure
CR-2018-06716
EDG 1 SYNC Selector Switch does not Positively Lock
onto the DG BKR TO C1 Position
07/27/2018
Corrective Action
Documents
CR-2021-04913
EDG 1 Overvoltage during Monthly Run (EDG 1
Unavailable)
DB-OP-06316
Diesel Generator Operating Procedure
Procedures
DB-OP-06334
Station Blackout Diesel - Diesel Generator Operating
Procedure
Calculations
F-FP-013.10-014
Fire Compartment BG-01, Service Water Pipe Tunnel and
Valve Rooms
CR-2019-08665
Aux Feed Pump Sliding Door 363 Safety Concern
11/19/2019
CR-2021-04075
Fire Protection Identified Issue of Combustible Floor
Covering Under Door 510
05/19/2021
Corrective Action
Documents
CR-2021-04868
Door 215 Interlock Mechanism Degraded
06/22/2021
Protected Area Pre-Fire Plan, Auxiliary Feed Pump 2
Room - Room 238 Fire Area F
Control Room and Adjacent Support Rooms Fire Area FF
Service Water Pump Room 52
Fire Plans
Protected Area Pre-Fire Plan Service Water Pipe Tunnel
Room 250
Miscellaneous
FHAR
Hazard Analysis Report
Corrective Action
Documents
2019-03616
Perform Performance GAP Analysis to Determine if there
is a GAP in Skills and Knowledge Regarding EDG PM
04/18/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Scope
20-01501
Unexpected SBODG Trip during Electronic Governor
Adjustment
2/27/2020
20-01540
SBODG Fuse 2 (DC Fuel Pump) Blew during Testing
2/28/2020
21-04913
EDG 1 Overvoltage during Monthly Run
06/24/2021
21-0582
SBODG Voltage Regulator 1 Green Light Flashing
06/10/2021
221-04601
SBODG Voltage Regulators 1 and 2 Malfunctions
06/11/2021
CR-2021-04582
SBODG Voltage Regulator 1 Green Light Flashing
06/10/2021
Drawings
200-0078-02
EDG Excitation System Interconnection Diagram
200-0078-04
EDG Excitation System RA-70 Configurable Settings
Evaluation of Reliability of Replacement EDG Excitation
System for Davis-Besse Nuclear Power Plant [Proprietary]
Miscellaneous
Trend
Single Point Trend
06/24/2021
Procedures
DB-MM-09320
Emergency and Station Blackout Diesel Engine
Maintenance
200789507
SBODG Monthly Test
200789645
SBODG Overspeed Trip Test
200810209
SBODG License Renewal Inspection
200817105
PM 7257 Replace Adjuster RA-70 EDG 1
06/25/2021
200857743
Troubleshoot Voltage Regulator Due to Failure
06/24/2021
Work Orders
601323347
Replace Voltage Regulator EDG 1
06/24/2021
CR-2021-04310
Containment Entry Dose Rates were Higher than
Expected
05/28/2021
Corrective Action
Documents
CR-2021-04332
Environmental Conditions Necessitate Entering RA-EP-
2830 Flooding Off-Normal Procedure
05/30/2021
DB-OP-03013
Surveillance Test Procedure, Containment Daily
Inspection and Containment Closeout Inspection
NOP-OP-1007
Risk Management
Procedures
RA-EP-02830
Emergency Plan Off-Normal Occurrence Procedure
2002-02203
Emergency Diesel Generator 1 Emergency Shutdown
03/13/2020
20-02222
Diode for Relay K2 Shorted
03/14/2020
Corrective Action
Documents
20-05188
Missed Opportunity during MRB Review of CR 2020-
203
06/22/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-04282
EDG 1 Failed to Reach Required Voltage and Frequency
during the 184 Day Test
05/27/2021
CR-2021-04909
EDG 1 RICE Rule Violation
06/24/2021
200-0078-02
EDG Excitation System Interconnection Diagram
B15702501
Schematic Diagram Engine Control for Emergency Diesel
Generator 1 - 1
T21
Drawings
E559-SH 4
Emergency Diesel Generator 1 - 1 Engine Control Panel
NOP-CC-2003-05
ECR 03-0080-00, Replace EDG 1 - 1 Field Flash
Contactor (FFC)
06/18/2003
Engineering
Changes
NOP-CC-2003-16
On DCNs M-180-47-0010 and M-180-48-000 Change the
Destination of the 'N' Conductor from FCC to FFC
07/08/2003
Engineering
Evaluations
EER-14-94013-02
SBM Selector Switches
Core Operating Limits Report
GE Manual
SBM Switch Overview
GET-6169G
Selection and Application Guide for SB Control and
Transfer Switches
Instruction Manual
SB Control and Transfer Switches - GE Power
Management
Letter to NRC from
AZZ Nuclear
Report No: P21-01072015 Report of Potential Failure of
GE Hitachi (GEH) SBM Type Switches per 10CFR Part 21
01/08/2015
Miscellaneous
Letter to NRC from
United Controls
International
10CFR21 Interim Letter, UCI Not Capable to Determine if
Defect Exist General Electric SB1 Switches and HEA
Relays
04/08/2014
Work Orders
200772884
Install Constant Level Oilers on DHP-1
DB-PF-03291
Surveillance Test Procedure, Containment Personal and
Emergency Airlock Seal Leakage Test
DB-SC-03070
Emergency Diesel Generator 1 Monthly Test
Procedures
DB-SC-03070
Emergency Diesel Generator 1 Monthly Test
Work Orders
200856554
PF3291 Personnel Air Lock
Procedures
DB-MI-03205
Surveillance Test Procedure, Channel Functional
Test/Calibration and Response Time of RCP Monitor
(RC3601) to SFRCS LCH 1 and RPS Channel 1
ALARA Plans
20-5016
Insulation Work Activities in Containment
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20-5032
Contractor Services Activities in Containment
Various
20-5103
Under Vessel Inspections Following NI Covers
Various
20-5115
Repair/Replace Gasket on the Cavity NI Covers
Various
Miscellaneous
Davis-Besse 1R21 Outage ALARA Report
20-5016
Insulation Work Activities in Containment
Various
20-5032
Contractor Services Activities in Containment
Various
20-5103
Under Vessel Inspections Following NI Covers
Various
Radiation Work
Permits (RWPs)
20-5115
Repair/Replace Gasket on the Cavity NI Covers
Various
NOP-OP-4107-15
RWP#120-5103
ALARA DAC Evaluation - Under Vessel Inspection
03/14/2020
Calculations
NOP-OP-4107-15
RWP#120-6016
ALARA DAC Evaluation - Insulation Work Activities in
Containment
2/09/2020
Corrective Action
Documents
CR-2019-06640
Calculated DAC Dose Fractions Were Exceeded by more
than +/- 10% during DB-HP-04344
08/09/2019
Corrective Action
Documents
Resulting from
Inspection
CR-2021-03462
Rust Identified on Self-Contained Breathing Apparatus
04/27/2021
Ventilation Filter Testing Program
GEN-M7SCBA_FEN
FireHawk M7 SCBA Training
GEN-
PAPRHOODTL_FEN
Industrial Safety - Respiratory Protection Training
GEN-
RESPPRAC_REN-
Full-Face Respirator Practical Exercise
MMR 2nd Stage
Regulator
AMAA277770
MSA Regulator Service Report - Annual Flow Test
01/11/2020
MMR 2nd Stage
Regulator
AMAA277770
MSA Regulator Service Report - Annual Flow Test
08/26/2019
Miscellaneous
MMR 2nd Stage
Regulator
AOAA257126
MSA Regulator Service Report - Annual Flow Test
08/26/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MMR 2nd Stage
Regulator
AOAA257126
MSA Regulator Service Report - Annual Flow Test
08/11/2020
MMR 2nd Stage
Regulator
AOAA330144
MSA Regulator Service Report - Annual Flow Test
08/27/2019
MMR 2nd Stage
Regulator
AOAA330144
MSA Regulator Service Report - Annual Flow Test
08/11/2020
NOP-ER-3202
Control Room Envelope Habitability (CREHAB) Program
Procedures
Respiratory Protection Program
DB-SS3146-001
CREVS Train 2 Filter Test
01/30/2019
Work Orders
DB-SS3302-001
CREVS Tracer Gas Test Train 2
05/17/2018
Procedures
DB-HP-00010
Radiation Measuring and Test Equipment Calibration and
Control Program
2