ML25163A132

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Nuclear Power Station - Biennial Problem Identification and Resolution Inspection Report 05000346/2025010
ML25163A132
Person / Time
Site: Davis Besse 
Issue date: 06/16/2025
From: Sanchez-Santiago E
NRC/RGN-III/DORS/RPB2
To: Tony Brown
Vistra Operations Company
References
IR 2025010
Download: ML25163A132 (1)


Text

Terry Brown Site Vice President Vistra Operations Company, LLC Davis-Besse Nuclear Power Station 5501 N. State Rte. 2, Mail Stop A-DB-3080 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2025010

Dear Terry Brown:

On May 8, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Davis-Besse Nuclear Power Station and 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.

The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight process can continue to be implemented.

The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 June 16, 2025

T. Brown 2

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, Elba M. Sanchez Santiago, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000346 License No. NPF-3

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Sanchez Santiago, Elba on 06/16/25

ML25163A132

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available OFFICE RIII RIII NAME RNg:gmp ESanchez Santiago DATE 06/12/2025 06/16/2025

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

05000346 License Number:

NPF-3 Report Number:

05000346/2025010 Enterprise Identifier:

I-2025-010-0000 Licensee:

Vistra Operations Company, LLC Facility:

Davis-Besse Nuclear Power Station Location:

Oak Harbor, OH Inspection Dates:

April 21, 2025 to May 08, 2025 Inspectors:

R. Cassara, Senior Resident Inspector R. Ng, Senior Project Engineer J. Robb, Operations Engineer Approved By:

Elba M. Sanchez Santiago, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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 Failure to Perform an Operability Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000346/2025010-01 Open/Closed

[P.2] -

Evaluation 71152B The inspectors identified a finding of very low safety significance (green) for the licensees failure to perform an operability evaluation in accordance with procedure NORM-OP-1009, SRO Review of Condition Reports. Specifically, the licensee incorrectly determined that exceeding the core lift criteria did not have a functional impact on the SSC because they believed that the suspected cause of the flow calculation changes was due to temperature inputs to the calculations drifting. The licensee did not perform an operability determination to evaluate the impact of the temperature drift to the calculation methodology for both the core lift and the departure of nucleate boiling (DNB) safety analysis.

Additional Tracking Items None.

3 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.

OTHER ACTIVITIES - BASELINE 71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04) (1 Sample)

(1)

The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the reactor coolant pump issues. The inspectors also reviewed the corrective actions for selected NRC non-cited violations and findings.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS Assessment 71152B Assessment of the Corrective Action Program Based on the samples reviewed, the inspectors concluded the licensee's implementation of the Corrective Action Program (CAP) was generally effective and supported nuclear safety.

Effectiveness of Problem Identification:

Based on the samples reviewed, the inspectors determined that the licensee continued to

4 identify issues at a low threshold and appropriately entered these issues into the CAP. The inspectors also determined the licensee usually entered problems into the CAP, timely, completely and accurately. The inspectors observed that issues were being identified by all levels of organization and with varying degrees of safety, security, or radiological significance.

Some deficiencies were identified by external organizations, including the NRC, and they were subsequently entered into the CAP for resolution. The licensee also utilized a number of CAP support processes to identify problems, including the self-assessment and audit processes and the Operating Experience (OE) Program. For example, the inspectors noted that the licensee periodically performed departmental self-assessments and Nuclear Oversight audits to identify issues in station programs and processes. The identified deficiencies and improvement opportunities were entered into the CAP for resolution.

Similarly, the licensee screened issues from both the NRC and from industry OE programs and entered them into the CAP for evaluation when they were applicable to the station. The inspectors determined the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee had conducted effectiveness reviews and used the CAP to document instances in which previous corrective actions were ineffective or were inappropriately closed.

The Inspectors performed a review of the reactor coolant pump issues over the last 5 years. The inspectors focused on any potential recurring or age-related issues that were not identified by the licensee. As part of this review, the inspectors reviewed selected corrective action program documents, and interviewed the system engineer. The inspectors concluded that deficiencies and concerns were identified and entered into the CAP at a low threshold.

Issues with the pumps were characterized and addressed appropriately. The inspectors did not identify any programmatic deficiencies in this area.

Effectiveness of Prioritization and Evaluation of Issues:

Based on the samples reviewed, the inspectors determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety, security or radiological significance of the identified problem. The licensee utilized a multi-discipline team consisting of department directors and managers to review the condition report categorization, evaluation method selection, and other actions would adequately address the causes and extent of condition when applicable. Upon completion of the evaluation or actions, the Corrective Action Review Board reviewed those products to ensure they met the CAP requirements. During the Management Review Board and Corrective Action Review Board meetings the inspectors observed, licensee staff were generally thorough and intrusive in reviewing issues. The inspectors also observed healthy dialogues and good interactions among the members of the respective groups. Licensee staff were prepared and challenged each other on disposition of the identified conditions. Actions were prioritized based on the safety, security or radiological significance of the issues. In general, once a degraded or non-conforming issue was identified, the CAP process was effective in directing equipment operability or functionality reviews. The inspectors did identify an issue related to an operability review, which was documented in the Results Section of this report.

Effectiveness of Corrective Actions:

Based on the samples reviewed, the inspectors determined the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety, security or radiological significant were tracked to completion in a timely manner. Problems requiring the performance of a causal evaluation were resolved in

5 accordance with CAP requirements. The inspectors sampled assignments associated with violations that were identified by the NRC previously and those associated with various significances. The inspectors determined that the corrective actions sampled were generally effective and timely and addressed the adverse conditions.

Assessment 71152B The Use of Operating Experience Based on the samples reviewed, the team determined that the licensees performance in the use of operating experience (OE) was generally effective. The licensee screened industry and NRC OE information for applicability to the station. When applicable, condition reports were written, and actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The inspectors observed OE information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations. The licensee is also cognizant on generating OE lesson learned from issues encountered in the plant. The inspectors did not identify any issue of significance in this area.

Assessment 71152B Self-Assessments and Audits Based on the samples reviewed, the inspectors determined that the licensees performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and Quality Assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the inspectors identified issues that were not previously known, including issues regarding the CAP itself. Those issues were generally captured, and actions were generally taken by the licensee through the CAP for resolution. The inspectors did not identify any issue of significance in this area.

Assessment 71152B Safety Conscious Work Environment The inspectors reviewed the results of the Davis-Besse safety culture survey that was conducted in November 2024. The inspectors noted the survey documented negative staff responses regarding the Employee Concerns Program (ECP). The inspectors also noted that there was a high number of negative responses in several departments regarding confidence in the CAP to prioritize, investigate, and resolve issues. As a result, the inspectors reviewed licensee actions to address the negative survey trends. The inspectors also performed individual interviews of a representative cross-section of licensee personnel, including individual contributors, supervisors and contractors from various departments. The inspectors also interviewed the ECP manager and reviewed selected ECP case files. A total of 23 licensee personnel were interviewed during this inspection.

Based on the interviews and a review of licensee actions, the inspectors determined licensee personnel believed that they could raise nuclear safety, security or radiological issues through multiple channels including ECP without fear of retaliation. Licensee staff also believe that the CAP effectively addresses issues important to nuclear safety. However, some licensee staff have expressed frustration with the CAP process on resolving low-level issues partly because

6 they are not aware of all the considerations and constrains going into the decisions. Similarly, several licensee staff members were not fully aware of the ECP or how they could utilize the program. The inspectors determined that the ongoing licensee efforts to improve communications should address these negative responses. The inspectors found no evidence of challenges to the safety conscious work environment at Davis-Besse.

Failure to Perform an Operability Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000346/2025010-01 Open/Closed

[P.2] -

Evaluation 71152B The inspectors identified a finding of very low safety significance (green) for the licensee's failure to perform an operability evaluation in accordance with procedure NORM-OP-1009, SRO Review of Condition Reports. Specifically, the licensee incorrectly determined that exceeding the core lift criteria did not have a functional impact on the SSC because they believed that the suspected cause of the flow calculation changes was due to temperature inputs to the calculations drifting. The licensee did not perform an operability determination to evaluate the impact of the temperature drift to the calculation methodology for both the core lift and the departure of nucleate boiling (DNB) safety analysis.

==

Description:==

In May 2022, the licensee identified an increasing trend in RCS flow rate calculated per DB-SP-03358, RCS Flow Rate Test. This reactor coolant system (RCS) flow rate test is a Technical Specification (TS) surveillance that is required to be performed every 18 months.

The purpose of the surveillance was to verify the TS minimum RCS flow limit rate limit.

Additionally, it serves to verify the core lift analysis maximum RCS flow rate limit, which is not a TS controlled parameter. The method used is to perform a secondary side heat balance to calculate the RCS flow rate. The surveillance is also used to verify that plant RCS flow instruments are within acceptable tolerance for other TS surveillances. The TS minimum flow rate limit is to ensure that the initial condition assumed in the safety analysis for DNB is maintained. Although the core lift criteria is not a TS limit, it precludes the fuel assembly liftoff during postulated Condition I and Condition II events. Conditional I events are normal operations such as startup, shutdown or refueling. Condition II events are plant transients such as loss of feedwater or control rod drop. These flow limits protect the fuel rod fission product barrier. At the time the trend was identified, both acceptance criteria were satisfied but the licensee implemented a number of actions to investigate the increasing trend.

In April 2024, during the next surveillance, the RCS flow rate calculated from one of the two channels exceeded the core lift analysis maximum RCS flow limit. The licensee initiated condition report CR-2024-2942 for this condition. Per procedure NORM-OP-1009, SRO Review of Condition Reports, states that Entry into the Operability Determination (OD) process is contingent upon the Deficient Condition satisfying the Three Required Entry Criteria (TRC). The licensee at the time determined that Criterion 1, Does the deficient condition affect a TS SSC installed in an operating unit? was met. The licensee determined that Criteria 2, Does the deficient condition have a functional impact on the SSC? This includes the ability to perform required functions under postulated, off-normal design conditions was not met because the licensee believed there was reasonable assurance that the core lift analysis was met and therefore, the RCS and fuel would continue to perform their functions. This was based on the RCS radiochemistry and no indications of fuel defects or

7 fuel failure and diverse indication of acceptable flow. As such, Criterion 3, Is the functional impact of the deficient condition substantive? did not need to be answered. Therefore, the licensee did not perform an operability determination.

In May 2025, the inspectors reviewed the condition report associated with this issue. Based on the review, the inspectors determined that exceeding the core lift criteria had a functional impact on the fuel assembly during postulated, off-normal design conditions. Specifically, given that the licensee believed at the time that the suspected cause of the flow calculation changes was due to temperature inputs to the calculations drifting, the inspectors determined that the impact to the calculation methodology was not evaluated and could impact both the core lift and the DNB safety analyses. The inspectors concluded that both Criterion 2 and 3 should have been answered yes and an operability determination be performed.

Corrective Actions: The licensee entered this issue into the CAP and plans to revise the core lift analysis to address the issue.

Corrective Action References: CR-2025-03538, Inadequate Detail in CR-2024-04075 to Capture Basis for Meeting Technical Specification Requirements Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to perform an operability evaluation in accordance with NORM-OP-1009 was a performance deficiency that was reasonably within the licensees ability to foresee and correct and should have been prevented. Specifically, the licensee incorrectly determined that exceeding the core lift criteria did not have a functional impact on the SSC because they believed that the suspected cause of the flow calculation changes was due to temperature inputs to the calculations drifting.

However, the impact from the temperature drift to the calculation methodology was not evaluated and could impact both the core lift and the DNB safety analyses.

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. Specifically, since the same calculation is used to verify both the maximum core lift analysis limit and the minimum RCS flow limit, the licensee did not thoroughly evaluate the impact to both safety analysis methodology, which is directly related to the fuel barrier performance.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the issue to Green because the inspectors answered all the Fuel Cladding Integrity questions in IMC 0609 Exhibit 3 - Barrier Integrity Screening Questions no.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate the cause of the RCS flow exceeding the core lift limit and therefore, did not consider the full impact to the calculation methodology of both safety analysis limits.

8 Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

On May 8, 2025, the inspectors presented the biennial problem identification and resolution inspection results to Terry Brown and other members of the licensee staff.

9 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date ATA-2023-2857 NRC Cyber Security Inspection IP71130.10 Self-Assessment 02/13/2023 CR-2017-11317 Cyber Security Program: Control Deficiencies 11/17/2017 CR-2017-11807 Cyber Security Program: Control Deficiencies 11/30/2017 CR-2018-10472 Error in the Auxiliary Building Tornado Differential Pressure Model 11/27/2018 CR-2020-03138 Received L787 RCP 1-1 MTR LWR BRG OIL LVL High Computer Point 04/12/2020 CR-2020-04242 System Monitoring - Reactor Coolant Pump (RCP) 1-2 Seal Cavity Pressure Trends 05/14/2020 CR-2021-02678 2021 Cyber Inspection: Untimely Implementation of CA-2017-11807-001 04/08/2021 CR-2021-04888 Cyber: Implement the New Baseline Configuration Auditing Requirements of NOBP-SS-1205, Cyber Security Configuration Control 06/23/2021 CR-2021-05292 RCP 1-2 Third Stage Cavity Pressure Reading Lower than Normal 07/10/2021 CR-2021-07196 Rising Trend RCP 1-2 Drinking Bird Counts 09/25/2021 CR-2021-08974 Service Water Baseline Test Engineering Review DB-PF-03216 11/24/2021 CR-2021-09282 NRC TI inspection: DB-OP-06313 Procedure Enhancement Observation for Open Phase Condition 12/07/2021 CR-2022-00817 HPI Train 1 Pressure Rising Following MU Valve Stroke 02/03/2022 CR-2022-03833 Increasing Trend for Reactor Coolant System Flow Rate Calculated per DB-SP-03358, RCS Flow Rate Test 05/04/2022 CR-2022-09409 RCP Motor Oil Drain Tank Level High 12/11/2022 CR-2022-09426 2022 NRC Radiation Protection Baseline Inspection: NRC Identified Tritium Sampling Basis Methodology Was Not Determined 12/12/2022 CR-2022-09681 RCP 1-2 Third Stage Seal Downward Pressure Trend and Elevated Seal Leakage Rate 12/21/2022 71152B Corrective Action Documents CR-2023-02245 Performance Gap Analysis Requested for Instrument and Control Maintenance Regarding Nuclear Instrument 03/24/2023

10 Inspection Procedure Type Designation Description or Title Revision or Date Maintenance CR-2023-02453 2023 Security Training Inspection, NRC Finding 03/30/2023 CR-2023-02623 Zip Drive Disk Discovered at PAF Entrance Area 04/04/2023 CR-2023-02948 Conditions outside of Original Design Tolerance Identified While Mapping the Cooling Tower 04/12/2023 CR-2023-03338 Ground Settling Aggregate Review Enhancements 04/21/2023 CR-2023-03771 MS-C-23-08-20: Prep - Utilization of a Cancelled Documents by Access Authorization 05/04/2023 CR-2023-04596 SBODG Cylinder 20 Rocker Arm Shaft Cap Broken 06/05/2023 CR-2023-04687 SBODG Extended Unavailability Time due to Low Fuel Oil Level 06/08/2023 CR-2023-04801 Call Tree Individual Did Not Respond to Unannounced Call-In Dill 06/14/2023 CR-2023-04944 Insufficient Documentation of Evaluations for Sink Holes/Areas of Settlement Within 15 feet of Safety-Related Structures 06/21/2023 CR-2023-05000 Failure to address adverse condition (Fire Protection piping misalignment) in Corrective Action Program 06/22/2023 CR-2023-05298 Trending for Self Powered Neutron Detectors 07/03/2023 CR-2023-05430 Replacement Door 458 Incorrect Size 07/11/2023 CR-2023-05666 FME: Retaining Pin Stuck Between Fuel Pins of Fuel Assembly 07/20/2023 CR-2023-05671 SCBA-029 Failed Monthly Performance Test 07/20/2023 CR-2023-05829 RC Loop 2 Hotleg NR Temp (PPCS:T730) Appears High 07/26/2023 CR-2023-05945 Area of Concern (AOC) Issued to Davis-Besse Site Protection due to Recent Trend of Safety and Human Performance 07/31/2023 CR-2023-06048 MS-C-23-07-08: FINDING: M&TE Usage Not Tracked in ATICTS 08/03/2023 CR-2023-06564 2023 WANO AFI: NP.1 Workers are Not Consistently Adhering to Human Performance Standards during Work Activities.

08/23/2023 71152B Corrective Action Documents CR-2023-06732

  1. 1 Emergency Diesel Generator (#1 EDG) Monthly Water Jacket Iron Analysis is Trending Higher Than Typical Values.

08/29/2023

11 Inspection Procedure Type Designation Description or Title Revision or Date CR-2023-07574 RCP 1-1 Drinking Bird Counter Stopped Moving 10/07/2023 CR-2023-07667 RC Loop 2 Hot Leg NR Temp Appears High (PPCS:T730) 10/11/2023 CR-2023-07692 Degrading Seal Parameters for RCP 1-2 10/11/2023 CR-2023-07894 AFPT 2 Governor is Hunting Excessively at the HSS.

10/20/2023 CR-2023-09194 RPS Channel 1 RCS Flow Mode Configured to Incorrect Vendor Specification 12/14/2023 CR-2024-00078 Startup Transformer Bushings are Beyond the Normal Life Expectancy of 30 Years 01/04/2024 CR-2024-00153 Transfer of CWMT #1 to CWMT #2 during RE1770 A/B Testing (ACE) 01/08/2024 CR-2024-00232 Individual Accessed Radiological Control Area (RCA) without a Thermoluminescent Dosimeter (TLD) 01/10/2024 CR-2024-00407 Adverse Trend in Human Performance Events and errors Since November 2023 at Davis-Besse 01/16/2024 CR-2024-00824 Security Did Not Meet 1 of 2 Objectives from the Area of Concern 02/01/2024 CR-2024-01034 MS-C-24-02-22: No Condition Report for a 10CFR21 Notification from Velan 02/08/2024 CR-2024-01052 MS-C-24-02-22: Corrective Action Response Does Not Include Sufficient Objective Evidence for Closure as Required by CAP 02/09/2024 CR-2024-01054 MS-C-24-02-22: Effectiveness Review ER-2023-01268-1 Is Not Correct 02/09/2024 CR-2024-01119 Increase in Human Performance Errors Within Security 02/13/2024 CR-2024-01181 MS-C-24-02-09: PMT Leak Check Hold Time Information Not Properly Documented and Missing Painter Initial 02/15/2024 CR-2024-01182 MS-C-24-02-09: Issues with Order 200867885 Documentation 02/15/2024 CR-2024-01340 Aggregate Review of Ground Settling/Buried Piping Leaks at Davis-Besse 02/21/2024 CR-2024-01446 Radioactive Material Identified during Baseline Survey.

02/23/2024 CR-2024-01529 CFAM Elevation Notice - Davis-Besse Site Protection Inconsistent Application of Security Fundamentals 02/27/2024 71152B Corrective Action Documents CR-2024-02076 Unexpected Dose Rates Found during Incore Tank Survey 03/12/2024

12 Inspection Procedure Type Designation Description or Title Revision or Date CR-2024-02170 NRC Identified - Improvement Opportunity with Alpha Monitoring 03/14/2024 CR-2024-02249 Water Accumulation in Fire Pump Diesel Day Tank 03/16/2024 CR-2024-02254 RCP 1-2 Whip Restraint SE Nuts Loose 03/16/2024 CR-2024-02338 Positive Whole Body Count on Steam Generator Worker 03/19/2024 CR-2024-02488 Integrated SFAS Test Train 1 Required Evaluation of IST Program Document for Valve Stroke Times - 1R23 03/22/2024 CR-2024-02599 MS Line 2 to AFPT 1 Isolation Valve MS106A Tripping Closed with SG Pressure >20PSIG 03/26/2024 CR-2024-02942 Calculated RCS Flowrate per DB-SP-03358 Exceeds Core Tilt Limit 04/04/2024 CR-2024-03162 Fire Piping Rupture Outside the Turbine Building Near the Tool Crib Entrance 04/11/2024 CR-2024-03180 Station Blackout Diesel Fuel Oil Day Tank Elevated Micro-Organism 04/12/2024 CR-2024-03400 Trending: Spent Fuel Pool Leakage/SF99-Q, ZONE 2 FUEL TRANSFER PIT FLOOR LEAK MONITOR DRAIN, Blockage Impacts 04/18/2024 CR-2024-03413 EPZ Siren 002 Located in Jerusalem Township in Lucas County Failed the April 17, 2024, Siren Test.

04/18/2024 CR-2024-03734 Irregular Thermoluminescent Dosimeter (TLD) Results From 2nd Half 2023 04/26/2024 CR-2024-04083 Individual Alarms Passive Monitor Upon Issuance of Dose of Legal Record Dosimeter 05/06/2024 CR-2024-04337 Trending Small Changes in CTRM Indications Following CTRM Ventilation Swap.

05/14/2024 CR-2024-04787 Main Steam Line Room 1 (Room 601) Temperature Exceeded 120 Degrees Fahrenheit 05/30/2024 CR-2024-04911 RCS Leakage Trends Not in MAOM at Time of Publishing 06/04/2024 CR-2024-05061 Level 4 Clearance Discrepancy 06/11/2024 CR-2024-05271 Surveillance Testing to Fulfill SR 3.3.1.3 Not Performed on a Staggered Test Basis 06/20/2024 CR-2024-05297 MS-C-24-05-31: Staged Combustibles Not Addressed in Fire Loading Calculations 06/20/2024

13 Inspection Procedure Type Designation Description or Title Revision or Date CR-2024-05444 Turbine Building North Slab Trending 06/26/2024 CR-2024-05571 Level 4 Clearance Condition 07/02/2024 CR-2024-05576 Level 4 Clearance Issue for C49 Work 07/02/2024 CR-2024-06093 RCP 1-2 Nuclear Safety Concern 07/25/2024 CR-2024-06186 Discrepancy Between Plant Drawing and Field Wiring 07/30/2024 CR-2024-06323 Level 4 Clearance Issue 08/05/2024 CR-2024-06451 NRC Identified (NRC Inspection 71130.05): CR-2021-05955-ATA-01 Closed without Supporting Justification.

08/08/2024 CR-2024-06580 EP Drill: 8/13/24: Drill Participant Did Not Respond 08/14/2024 CR-2024-06768 Concern Identified Regarding Concurrent Yellow Risk Surveillance Testing 08/22/2024 CR-2024-06827 Demin Water Transfer Pump 1 Trip Due to Mispositioning of Switch 08/26/2024 CR-2024-06857 NRC Identified Fire Barrier Question 08/27/2024 CR-2024-06873 NRC Identified Fire Barrier Penetration Question 08/27/2024 CR-2024-06932 Level 4 Clearance Event - Potential Drawing Discrepancy on E-666 Sh1 08/29/2024 CR-2024-07102 Preliminary Indications Identified Potential Rotation Issues with Siren 504 Following Testing.

09/06/2024 CR-2024-07221 NRC Identified Concern (Protected Equipment Postings) 09/11/2024 CR-2024-07227 EPZ Siren 005 Did Not Receive the Test Signal during the Silent Siren Test on 09/11/2024 09/11/2024 CR-2024-07386 INPO Temporary Modifications (>1 Cycle) Indicator Yellow for August 2024 09/18/2024 CR-2024-07412 Fleet Assessment Notice of Concern - Negative Trend in Plant Status Control, Bumping of Components 09/19/2024 CR-2024-07435 License Event Report (LER) 2021-001 Revision 01 09/19/2024 CR-2024-07563 Security Did Not Meet 1 Objective from the Area of Concern 09/25/2024 CR-2024-07800 DB Siren 002 Failure 10/04/2024 CR-2024-07935 EDG Speed Switch Evaluation Concludes an Unanalyzed Condition Existed.

10/10/2024 CR-2024-08176 Siren 205 in Ottawa County Had a Communications Failure during 10/18/2024 Testing.

10/18/2024

14 Inspection Procedure Type Designation Description or Title Revision or Date CR-2024-08416 Plant Status Control Event - SW37, CCW HEAT EXCHANGER 3 OUTLET ISOLATION, Inadvertently Left Closed During Performance of DB1OP-06262, Attachment 30 (ACE) 10/26/2024 CR-2024-08554 Several Telephone Lines Were Found Dead During Walkdown/Communication Test at the Joint Information Center Emergency Response Facility 10/31/2024 CR-2024-09019 NRC NCV: Inadequate Assessment of Fire Brigade Performance (ACE) 11/18/2024 CR-2024-09020 NRC NCV: Reactor Protection System Flow Modules Found Not Conforming to Design 11/18/2024 CR-2024-09356 Meteorological Tower Primary 75M Wind Speed Failed 12/04/2024 CR-2024-09424 Davis-Besse Backup 4-Way Blast Dial Server is Out of Service 12/09/2024 CR-2024-09449 Error in Historical CCW HX 1 Performance Test 12/10/2024 CR-2024-09582 NRC NCV: Failure to Ensure Adequate Auxiliary Feedwater Pump Minimum Flow 12/16/2024 CR-2024-09751 Primary 75-Meter Wind Direction Indicating Erratically.

12/25/2024 CR-2025-00041 Siren 103 Current Fail After 1/3/25 Audible Test 01/03/2025 CR-2025-00151 Outside Phones Lines are Out of Service 01/09/2025 CR-2025-00155 75M Wind Direction Drift from Acceptable Direction 01/09/2025 CR-2025-00727 During testing, Lucas County Emergency Operations Center Could Not be Contacted From the Emergency Operations Facility 4-Way Phone 02/04/2025 CR-2025-00888 Annunciator 6-1-B Failed to Flash during Annunciator Panel Testing 02/10/2025 CR-2025-00917 Unsatisfactory Simulator DEP Classification 02/11/2025 CR-2025-00934 Davis-Besse 2024 Safety Conscious Work Environment Survey Chemistry Red Pillars 02/12/2025 CR-2025-00936 Davis-Besse 2024 Safety Conscious Work Environment Survey Security Red Pillar 02/12/2025 CR-2025-00939 IIS: As-Found Condition of T86-4 and DA1144 Penetration 02/12/2025 CR-2025-00992 EDG Air Start Tank T86-4 Relief Concern 02/13/2025 71152B Corrective Action Documents CR-2025-01139 Draft Tornado dP Calculation Results 02/20/2025

15 Inspection Procedure Type Designation Description or Title Revision or Date CR-2025-01226 Davis-Besse 2024 Safety Conscious Work Environment Survey Other Site Matrixed Organization Red Pillar 02/25/2025 CR-2025-01263 EDG Air Receiver Tank Returned to Service with Identified Condition from Internal Tank Inspection Not Fully Understood 02/26/2025 CR-2025-01586 P465 and Q479 Received during Valve Stroke of HP2A 03/08/2025 CR-2025-02078 Site Protection Did Not Meet the Effectiveness Review Criteria Listed in ER-2024-01119-1 03/24/2025 CR-2025-02356 Improvement Opportunity - CREVS Testing 04/01/2025 CR-2025-02751 Received Computer Points Q479 HP INJ VLV LEAKING and P465 HP INJ VLV IN PRES 04/13/2025 CR-2025-03150 2025 NRC PI&R Inspection: Backup Call Manager is Out of Service 04/24/2025 CR-2025-03358 2025 NRC PI&R Inspection - Trend - Radiation Protection Decrease in Condition Report Initiation 05/01/2025 Corrective Action Documents Resulting from Inspection CR-2025-03602 2025 NRC PI&R Inspection: Observation on CR Documentation 05/12/2025 24-1158-001 TM - AFW Pump Recirculation Rupture Disk 0

Engineering Changes CR-2014-08079 Leakage Indicated on HP57/HP59 and HP56/HP58 Back to Back Check Valve Test, DB-PF-03969 05/01/2014 Surveillance Test Intervals (STI) List 12 ATL-2025-0147 2024 SCWE Survey: Davis-Besse - Negative Red Questions and Department/Section Discussions 02/11/2025 OE-2021-0105-6 NRC Information Notice 2020-04: Operating Experience Related to Failure of Buried Fire Protection Main Yard Piping 04/20/2023 OE-2023-0138-1 OE547830R20230412 Turbine Trip due to Primary Phase Differential Generator Lockout 05/10/2023 OE-2023-0341-1 IER L1-17-5, Rev.1 Line of Sight to the Reactor Core 08/22/2023 OE-2023-0397-1 OE559877R20230914 Main Generator Transformer Lockout Caused By Failed Lightning Arrestor 01/04/2024 OE-2023-0482-1 OE563910R20231103 Degraded Service Water Piping 01/03/2024 Miscellaneous OE-2023-0514-1 IN 2023-06, Emergency Telecommunication Services Changes, ML23289A249 12/11/2023 71152B Miscellaneous OE-2024-0002-2 NRC Information Notice 2023-04: Operating Experience Related to Fire Events at Decommissioning Nuclear Power 01/02/2024

16 Inspection Procedure Type Designation Description or Title Revision or Date Plants In The United States OE-2024-0012-2 Information Notice 2021-01, Supplement 1: Lessons Learned From U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability Of Power-Operated Valves at Nuclear Power Plants 01/12/2024 OE-2024-0016-1 OE577016R20240114 Loss of Offsite Power Path due to Cable Pothead Fault to Ground 03/19/2024 OE-2024-0062-1 NRC Information Notice 2024-01: Minimization And Control of Contamination Involving Discrete Radioactive Particles at Decommissioning Facilities 02/15/2024 OE-2024-0121-1 NRC Information Notice 2024-02: Impact on Licensee Emergency Plans From Changes Made by Offsite Response Organizations to Alert And Notification Systems 04/04/2024 OE-2024-0141-2 OE558315R20240415 Fuel Assembly Misplaced 10/14/2024 OE-2024-0305-1 OE587467R20240830 Main Transformer Fire Resulted in Loss of One Train of Offsite Power and Reactor Trip 10/22/2024 OE-2024-0341-1 OE581674R20240930 Automatic Plant Runback due to Integrated Control System 10/14/2024 DB-CH-06900 Operational Chemical Control Limits 74 DB-OP-06513 Auxiliary Building Non-Radioactive Areas Ventilation 31 DBRM-EMER-5003 Equipment Important To Emergency Response 23 FLT-PI-BP1350 Corrective Action Review Board 0

NOBP-LP-2003 Employee Concern Program 7

NOBP-OP-0012 Operator Workarounds, Burdens, Control Room Deficiencies and Operations Aggregate Assessment 9

NOP-LP-2001 Corrective Action Program 50 NOP-LP-2023 Conduct of Quality Assurance Compliance Auditing 22 NOP-OP-1009 Operability Determinations and Functionality Assessments 09 Procedures NORM-OP-1009 SRO Review of Condition Reports 11 ATA-2023-10840 Review and Assess Area Radiation Monitor OE 06/29/2023 ATA-2023-11519 Operations Assessment of Procedural Workarounds in OPS Procedures 07/11/2023 Self-Assessments ATA-2023-20106 Emergency Diesel Generator 2 October 2023 Maintenance 11/27/2023

17 Inspection Procedure Type Designation Description or Title Revision or Date Outage Critique ATA-2023-21847 Davis-Besse Radiation Protection Program Review for 2024 in accordance with NOP-OP-4001 (Radiation Protection Program) 12/28/2023 ATA-2023-2758 Conduct Rollup Assessment of Department Response to IPA Gap and Focus Areas Following Training Cycle 23-02 02/09/2023 ATA-2023-2857 NRC Cyber Security Inspection IP71130.10 Self-Assessment 02/13/2023 ATA-2023-2857 NRC Cyber Security Inspection IP71130.10 Self-Assessment 02/13/2023 ATA-2023-4223 PM Feedback Self-Assessment 03/08/2023 ATA-2023-4498 Davis-Besse Emergency Feedwater System Assessment 03/10/2023 ATA-2023-9469 NI Divergences: Trend and Summarize Nuclear Instrumentation Power Range Divergences 06/07/2023 ATA-2024-1977-ATA-37 Area 8 Fitness-for-Duty Reviews/Assessments 01/26/2024 ATL-2022-0550-ATA-16 2nd Quarter 2023 Unannounced Call-in Drill 08/25/2023 ATL-2022-0902-ATA-05 Assess Actions Taken to Date Regarding Chemistry Section's Three Red Pillars in the 2022 SCWE Survey 12/12/2022 ATL-2023-0258-ATA-09 Review Project Schedules Generated to Ensure They Have Sufficient Granularity 06/26/2024 ATL-2023-0673-ATA-18 Monitor Quality of Completed CAP Products 01/13/2025 ATL-2024-0448-ATA-06 Quarterly Unannounced Augmentation Drill - 3rd Quarter 2024 10/10/2024 ATL-2025-0221-ATA-05 2025 NRC PI&R Inspection Document Request -

Performance Improvement 04/04/2025 QFO-2023-0008 Fitness-For-Duty Audit 10/30/2023 QFO-2024-0004 Corrective Action Program (CAP) Limited Scope Audit 02/20/2024 QFO-2024-0013 MS-C-24-08-03 Radiation Protection (QA Audit) 08/05/2024 WO 200877259 RCS Flow Rate Test 04/04/2024 Work Orders WO 200925503 Troubleshoot / Repair / Replace RPS2RC2406 11/30/2023