ML25351A112
| ML25351A112 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/22/2025 |
| From: | Sanchez-Santiago E NRC/RGN-III/DORS/RPB2 |
| To: | Craven R Vistra Operations Company |
| References | |
| EAF-RIII-2025-0160 IR 2025001, IR 2025003 | |
| Download: ML25351A112 (0) | |
Text
EAF-RIII20250160 Robert Craven 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 - INTEGRATED INSPECTION REPORT 05000346/2025003; 07200014/2025001 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Robert Craven:
On September 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On December 2, 2025, 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.
Due to the temporary cessation of government operations, which commenced on October 01, 2025, the NRC began operating under its Office of Management and Budget-approved plan for operations during a lapse in appropriations. Consistent with that plan, the NRC operated at reduced staffing levels throughout the duration of the shutdown. However, the NRC continued to perform critical health and safety functions and make progress on other high-priority activities associated with the ADVANCE Act and Executive Order 14300. On November 13, 2025, following the passage of a continuing resolution, the NRC resumed normal operations. However, due to the 43-day lapse in normal operations, the Office of Nuclear Reactor Regulation granted the regional offices an extension on the issuance of the calendar year 2025, third quarter integrated inspection reports normally issued by November 15, 2025, to December 31, 2025. The NRC will resume the routine cycle of issuing inspection reports on a quarterly basis beginning with the calendar year 2025, fourth quarter integrated inspection reports, which will be issued 45 days after the fourth quarter ends on December 31, 2025.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
December 22, 2025
R. Craven 2
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.
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; 07200014 License No. NPF-3
Enclosure:
As stated cc: Distribution via LISTSERV Signed by Sanchez Santiago, Elba on 12/22/25
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RIII RIII-EICS RIII NAME RNg:gmp DBetancourt-Roldan ESanchezSantiago DATE 12/22/2025 12/22/2025 12/22/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
05000346; 07200014 License Number:
NPF-3 Report Number:
05000346/2025003; 07200014/2025001 Enterprise Identifier:
I2025003-0052; I2025001-0111 Licensee:
Vistra Operations Company, LLC Facility:
Davis-Besse Nuclear Power Station Location:
Oak Harbor, OH Inspection Dates:
July 01, 2025 to September 30, 2025 Inspectors:
B. Towne, Senior Resident Inspector N. Audia, Reactor Inspector K. Fay, Senior Reactor Inspector A. Guieb, Resident Inspector I. Hafeez, Senior Reactor Inspector T. Hooker, Health Physicist C. Padilla, Senior Resident Inspector A. Rowe, Transport & Storage Safety Inspector J. Tapp, Senior Trans & Storage Safety Insp 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 an integrated inspection at Davis-Besse Nuclear Power Staion, 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 Incorporate Strategies from FAQ070040 to Reduce Fire Risk During Non-Power Operation High Risk Evolutions Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000346/202500301 Open/Closed None (NPP) 71111.21N.05 The inspection team identified a Green finding and associated non-cited violation (NCV) of the Davis-Besse Operating License Condition 2.C(4), Transition License Condition step 3, for failing to revise procedures to implement Non-Power Operation requirements for National Fire Protection Association (NFPA) 805. Specifically, Davis-Besse failed to incorporate strategies committed by the licensee in response to Frequently Asked Question (FAQ) 070040 to reduce fire risk during Non-Power Operation (NPO) high risk evolutions (HREs) into their procedures.
Additional Tracking Items Type Issue Number Title Report Section Status URI 05000346/20240 1002 Failure to Correctly Implement 10 CFR 50.59 Administrative Procedures 71111.21M Closed URI 05000346/20220 1101 Multiple NFPA 805 Non-Power Operation Transition Issues 71111.21N
.05 Closed EDG EAF-RIII20250160 Enforcement Action EAF-RIII20250160:
Failure to Comply with 10 CFR Part 37 71124.08 Closed LER 05000346/2021 001-02 LER 2021001-02 for Davis-Besse Nuclear Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground 71153 Closed LER 05000346/2021 001-01 LER 2021001-00 for Davis-Besse Nuclear Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground 71153 Closed LER 05000346/2021 001-01 LER 2021001-01 for Davis-Besse Nuclear Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground 71153 Closed
3 PLANT STATUS Unit 1 began the inspection period at rated thermal power. On August 12, 2025, the unit was shut down to conduct repairs to the steam generator 1 (SG1) level instrument reference leg.
The unit was returned to rated thermal power on August 19, 2025, 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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
Emergency diesel generator (EDG) train 2 after EDG train 2 monthly surveillance on August 28, 2025 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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)
Cable spreading room, room 422A, fire area CC, on July 14, 2025 (2)
Main steam line area and control room heating ventilation and cooling equipment room, room 601, 602, and 603, fire area DH on July 28, 2025 (3)
Component cooling water heat exchanger and pump room, room 328, fire area T on August 27, 2025 (4)
Service building 6, laydown area, station blackout diesel on September 4, 2025 (5)
High voltage switchgear room A, room 325, fire area S on September 30, 2025
4 Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during a simulated fire in the high voltage switchgear room A, breaker AC202 on August 8, 2025 71111.07A - Heat Exchanger/Sink Performance Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
Service water cold water forebay flow verification during the week ending September 6, 2025 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
(1)
The inspectors observed and evaluated licensed operator performance in the control room during plant shutdown and transition to mode 4 due to steam generator level instrument reference leg leak on August 12, 2025 (2)
The inspectors observed and evaluated licensed operator performance in the control room during transition to mode 2 and reactor startup following a maintenance outage on August 17, 2025 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated operator performance in the simulator during rapid shutdown scenario validation on August 14, 2025 71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (3 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)
Service water pump 1 strainer drain valve asfound diagnostic inservice testing on July 8, 2025 (2)
Makeup and purification system demineralizer 3 inlet isolation valve troubleshooting following failure to establish flow during the week ending September 6, 2025 (3)
Negative battery charger 2 (DBC2N) load testing on September 26, 2025
5 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)
Assessment of elevated risk and mitigating actions due to PJM electrical grid hot weather and max generation alerts during the week ending July 26, 2025 (2)
Assessment of elevated risk and mitigating actions due to station air compressor (SAC) 2 maintenance outage during the week ending August 2, 2025 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples 1 Partial)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)
Operability determination of temperature instruments TIRC3A5 and TIRC3B5 due to discovery of missed surveillance for SR 3.3.17.3 on July 31, 2025 (2)
Operability determination of high pressure injection (HPI) pump 2 due to recirculation flow outside of acceptance criteria band on August 5, 2025 (3)
(Partial)
Operability determination of steam feed rupture control system due to diverging steam generator 2 level instrumentation on August 11, 2025 (4)
Operability determination of source range nuclear instrument 2 due to start up rate (SUR) and counts per second (CPS) reading erratically on August 17, 2025 71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated Unit 1 maintenance outage activities from August 12 to August 18, 2025 71111.24 - Testing and Maintenance of Equipment Important to Risk The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)
(1)
Post-maintenance test of station air compressor (SAC) 2 following troubleshooting after second trip of SAC 2 on August 5, 2025 (2)
Post-maintenance test following HPI train 1 scheduled maintenance on September 10, 2025 (3)
Post-maintenance test following motor-driven feed pump maintenance outage on September 17, 2025
6 Surveillance Testing (IP Section 03.01) (4 Samples)
(1)
Auxiliary feedwater pump (AFP) 1 quarterly test on July 9, 2025 (2)
Decay heat train 1 pump and valve test on July 19, 2025 (3)
EDG 1 monthly test on July 20, 2025 (4)
Emergency feedwater pump monthly test on September 20, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)
Asfound testing of MV1379 service water pump strainer 1 drain valve in accordance with DBSV09302 testing motor operated valves on July 8, 2025 71114.06 - Drill Evaluation Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
(1)
The inspectors evaluated an emergency plan training exercise simulating a fuel leak and radiological release followed by containment failure resulting in a general emergency declaration on September 18, 2025 RADIATION SAFETY 71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,
& Transportation Radioactive Material Storage (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
(1) 10 CFR Part 37 material storage location Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
(1)
Spent resin processing systems Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
(1)
Primary and secondary resin waste streams (2)
Dry active waste stream
7 Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
(1)
Shipment 20231001; Filter; UN3321 Radioactive Material, low specific activity (LSA-II)
(2)
Shipment 20231002; Secondary Resin Liners; UN2910, Radioactive Material, excepted package - limited quantity of material (3)
Shipment 20251001; Primary Resin Liner; UN3321, Radioactive Material, low specific activity (LSA-II)
OTHER ACTIVITIESBASELINE 71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program to identify potential trends in jockey fire pump volumetric flow that might be indicative of a more significant safety issue.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (3 Samples)
The inspectors evaluated the following licensee event reports (LERs):
(1)
LER 2021001-00 for Davis-Besse Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground, (ML21105A489). The inspection conclusions associated with this LER are documented in, 05000346/2021092 (ML21356A058), 05000346/2022040 (ML22314A225), 05000346/2022090 (ML22109A157) and 05000346/2025002 (ML25216A272). This LER is Closed.
(2)
LER 2021-00101 for Davis-Besse Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground, (ML24263A236). This LER updated LER 2021001-00 with the cause and corrective actions taken since the initial report submittal. The updated information was reviewed and there were no changes to our inspection conclusions as indicated in our review of LER 2021001-00 above. This LER is Closed.
(3)
LER 2021001-02 for Davis-Besse Power Station, Unit 1, Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground, (ML24344A257). This LER revision added additional reporting requirement. There were no changes in our inspection conclusions as indicated in our review of LER 2021001-00 above. This LER is Closed.
8 OTHER ACTIVITIESTEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation of an Independent Spent Fuel Storage Installation Operation of an Independent Spent Fuel Storage Installation (1 Sample)
(1)
The inspectors evaluated the licensees activities related to long-term operation and monitoring of their independent spent fuel storage installation (ISFSI). The inspectors were onsite from August 18 through August 21, 2025. During the onsite walkdown, the inspectors toured the ISFSI and evaluated the material and radiological conditions of the ISFSI pad and storage system. The inspectors verified that the ISFSI pads radiological conditions were as expected during the walkdown.
Since the last inspection, the inspectors evaluated corrective action documents. The inspectors also reviewed procedures and interviewed staff regarding daily temperature monitoring of the casks. The site did not perform any screenings or evaluations under 10 CFR 72.48, Changes, Tests, and Experiments, since the last inspection.
60859 - ISFSI License Renewal Inspection ISFSI License Renewal Inspection (1 Sample)
(1)
The inspectors conducted a License Renewal Inspection for the Transnuclear Standardized NUHOMS at the site. The inspectors were onsite from August 18 through August 21, 2025 to verify that:
The ISFSI license renewal program and supporting activities are consistent with regulation.
The site has adequate programs planned or in place to implement aging management for the SSCs that require an aging management review.
The license conditions added as part of the renewed Certificate of Compliance, regulatory commitments, aging management programs (AMPs),
time limited aging analyses (TLAAs), and license renewal activities are implemented and/or completed.
Age-related degradation is identified and adequately managed or corrected, as applicable.
The inspectors conducted the inspection through a combination of document reviews and onsite walkdowns. Specifically, the inspectors reviewed:
Administrative Controls for Aging Management.
The sites use of Aging Management Operating Experience and Tollgates.
All applicable TLAAs including Dry Shielded Canister (DSC) Fatigue, Transfer Cask Fatigue, and Thermal Performance of Horizontal Storage Modules (HSMs) for the Period of Extended Operation.
All applicable AMPs including DSC External Surfaces, DSC Chloride-Induced Stress Corrosion Cracking, and HSM External and Internal Surfaces.
Additionally, the inspectors observed the site perform visual examinations of a DSC external surface as well as the internal and external surfaces of an HSM.
9 INSPECTION RESULTS Unresolved Item (Closed)
Failure to Correctly Implement 10 CFR 50.59 Administrative Procedures URI 05000346/202401002 71111.21M
==
Description:==
In September 2024, as part of the Comprehensive Engineering Team Inspection, the inspectors reviewed the licensee's 10 CFR 50.59 implementation process and eleven 50.59 screenings. The inspectors determined 50.59 screenings 1500776, Switchyard 345kV Breaker Replacement, Revision 15 and 2300791, "Limiting Differential Pressure for Auxiliary Feedwater Pump Discharge Valves," Revision 0 did not contain sufficient information to justify the conclusions reached, which was contrary to procedure NOBP-LP4003A, "10 CFR 50.59 User Guidelines," Revision 12. NOBP-LP4003A, Attachment 2, "10 CFR 50.59 Screen,"
requires, in part, that the technical basis for response to each of the questions be addressed and documented, and for the justification to be complete enough to permit an independent reviewer with similar expertise to understand the judgment and develop concurrence with the technical basis without recourse to the preparer.
The licensee entered the issues into the corrective action program and generated CR202407558, "2024 CETI: Insufficient Detail Contained in 10 CFR 50.59 Screen 1500776," CR202407619, "2024 CETI: AF599 and AF608 Not Evaluated for Worst Case Differential Pressure," and CR202407625, "2024 CETI: AFW Discharge MOV Calculations Credit Operator Actions," to capture the inspectors' concerns. For screening 2300791, the licensee prepared two new screenings: 2401449, "Calculation CME050.03122, 111 &
112," and 2401590, "Calculation CME050.03117, 120, 121, 130," and updated the associated calculations. For screening 1500776, the licensee updated the screening to include more thorough justifications, including the vendor determination that existing relay settings are acceptable and would not adversely impact the main transformer's differential protection to detect abnormal condition originating in the main generation system and respond accordingly. The inspectors reviewed the updated 50.59 screenings and calculations and determined 50.59 evaluations and prior NRC approval was not required.
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it was necessary to address this violation, which impeded the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The inspectors determined the licensees failure to correctly implement 10 CFR 50.59 administrative procedures to prepare adequate written evaluations that provided the bases for the determination that the changes did not require a license amendment was contrary to 10 CFR 50.59(d)(1). Specifically, the inspectors determined screenings 1500776 and 2300791 did not provide the bases that changes made to offsite power circuit breakers and auxiliary feedwater (AFW) valves, respectively, were not adverse and did not require a license amendment. The inspectors assessed the violation in accordance with the NRC Enforcement Policy dated August 12, 2025, and the NRC Enforcement Manual, Revision 11, to determine the significance of the violation. They noted Section 2.1.3.D.5.a of the manual indicated failures to implement 10 CFR 50.59 administrative procedures that resulted in non-isolated (i.e., repetitive) failures to prepare adequate written evaluations would be categorized as Severity Level (SL) IV violations.
Following consultation with Enforcement & Investigations Coordination Staff, the inspectors have determined that two out of eleven insufficient 50.59 screenings does not meet the criteria of non-isolated failures and, as such, does not rise to the level for a Severity Level IV
10 violation and will be treated as a minor violation, consistent with Section 2.3.1 of the Enforcement Policy.
Corrective Action Reference(s): CR202407558, CR202407619, CR202407625 Failure to Incorporate Strategies from FAQ070040 to Reduce Fire Risk During Non-Power Operation High Risk Evolutions Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000346/202500301 Open/Closed None (NPP) 71111.21N.05 The inspection team identified a Green finding and associated non-cited violation (NCV) of the Davis-Besse Operating License Condition 2.C(4), Transition License Condition step 3, for failing to revise procedures to implement Non-Power Operation requirements for National Fire Protection Association (NFPA) 805. Specifically, Davis-Besse failed to incorporate strategies committed by the licensee in response to Frequently Asked Question (FAQ) 070040 to reduce fire risk during Non-Power Operation (NPO) high risk evolutions (HREs) into their procedures.
==
Description:==
During the Fire Protection Team Inspection in 2022, the inspectors identified that the licensee failed to implement part of their NFPA 805 NPO commitments made in response to FAQ 07-0040 during the NFPA 805 license amendment process. Additional information and discussions with the licensee were required to bring the issue of concern to closure, Therefore, an Unresolved Item (URI) 05000346/202201101 was documented in the triennial fire protection inspection report (ADAMS Accession Number ML23004A217). In order to resolve the URI, a review of the licensees NFPA 805 license amendment request (ADAMS Accession Number ML1530A314) and associated supplement (ADAMS Accession Number ML16351A330), dated January 17, 2017, the inspectors found that the licensee stated they would revise plant procedures to incorporate the insights, strategies, and analysis recommended or documented in their NPO Modes Transition Report and add the necessary procedure steps to ensure that key safety functions (KSFs) are achieved and maintained. The inspectors found that the licensee implemented software controls instead of procedure changes and did not incorporate the insights, strategies, and analysis from their NPO Modes Transition Report into their plant procedures. Additionally, the inspectors identified that the licensee did not add the necessary procedure steps to ensure that KSFs were achieved and maintained.
The licensees fire risk software was intended to prohibit hot work permits in fire compartments that contained pinch points during outage HREs. A pinch point is a fire area or compartment where a single fire could cause a loss of all success paths for a specific shutdown KSF. During the inspection, the inspectors identified the software was missing at least 10 fire compartments that should have been flagged as containing pinch points. Some of the missing fire compartments contained multiple KSF pinch points including one compartment that contained 3 KSFs (decay heat removal, inventory control, and support/electrical). These missing fire compartments were unprotected during the 2022 refueling outage HRE (deep drain of the reactor coolant system). In addition, an outage
11 review found that three work orders (200767710, Inspect Main Feedwater Pump Turbine (MFPT) 2 per PM 1557 (overhaul); 200767729, Inspect MFPT 1 per PM 1556 (disassembly/overhaul; and 200851468, Restore Valve Heater Drain HD146 from Temporary Leak Seal) conducted hot work activities in fire area II01 (rooms 252 and 431) during the HRE time frame. In reviewing the work orders, the inspectors noted that, even though hot work activities were not permitted during the HRE, all necessary precautions and compensatory measures were implemented in accordance with the licensees procedure DBFP00018, Control of Ignition Sources, Revision 13.
The inspectors also identified that the licensee did not have procedures for implementing all the necessary NFPA 805 NPO features within their fire risk software but relied on informal notes. The licensees informal notes did not specify that all pinch points needed to be protected during HREs. During the 2022 refueling outage HRE, the licensee only selected inventory control for hot work permit prevention; however, the decay heat removal, reactivity and support/electrical KSFs should have also been selected. The licensees Fire Hazards Analysis Report, which is also their fire protection program design-basis document, contained an NPO Modes Compliance Summary for each fire area/compartment. The NPO Modes Compliance Summary template stated, in part, that each compartment summary will contain any associated pinch points in the fire compartment and any features and/or controls that provide reasonable assurance that the fuel will be maintained in a safe and stable configuration The inspectors found that the NPO Modes Compliance Summary was inaccurate for all fire compartments that contained a pinch point at Davis-Besse. Specifically, all 46 pinch point fire compartments contained the following summary, The potential effects of a fire occurring during NPO modes in this fire compartment were reviewed. This review was conducted using the methodology as described in Calculation ARS-DB11003. This area does not have any associated pinch points. The lack of failures resulting in a pinch point provides reasonable assurance the fuel will be maintained in a safe and stable configuration.
Therefore, the NFPA 805 performance goal for NPO is satisfied.
Corrective Actions: Davis-Besse documented the performance deficiency in their corrective action program. Davis-Besses actions included completing the procedure revisions and instituting necessary changes to the software to comply with the requirements.
Corrective Action References: CR202207442, CR202207489, CR202207930.
Performance Assessment:
Performance Deficiency: The inspection team determined the licensee failed to revise procedures to implement NPO requirements for NFPA 805. Specifically, Davis-Besse failed to incorporate strategies from FAQ 070040 to reduce fire risk during Non-Power Operation HREs.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, Davis-Besse not incorporating the strategies from FAQ 070040 into site approved procedures, resulted in hot work being performed during Non-Power Operation HREs.
12 Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process, Phase 1, Initial Screening and Characterization of Findings, Exhibit 2-Initiating Events Screening Questions. The inspectors reviewed Section D External Event Initiators, Question 10, Does the finding increase the likelihood of a fire or internal/external flood that could cause a shutdown initiating event? The inspectors answered No to this question because, all necessary precautions and compensatory measures were implemented to prevent a fire from causing a shutdown initiating event. Therefore, the finding screened as Green.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Davis-Besse Operating License Condition 2.C(4), Transition License Condition step (3), required Davis-Besse, in part, to implement the items listed in Attachment S, Table S2, Implementation Items committed by the licensee in response to FAQ 07-0040, to the First Energy Nuclear Operating Company (FENOC) \
letter dated November 20, 2018, within 2 years following issuance of the license amendment. Table S2 requires, under item DB1908, the licensee to revise procedures and conduct training to implement NPO Requirements for NFPA 805 in accordance with license amendment request (LAR) Attachment D.
Contrary to the above, as of November 22, 2022, at the time of the exit meeting, Davis-Besse failed to revise procedures to implement NPO requirements for NFPA 805. Specifically, Davis-Besse failed to revise procedures reduce fire risk during Non-Power Operation HREs as required by their LAR and did not prohibit or limit hot work in fire areas during periods of increased vulnerability.
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 finding and associated violation closes URI: 05000346/2022011-01.
Enforcement Discretion Enforcement Action EAF-RIII20250160: Failure to Comply with 10 CFR Part 37 71124.08
==
Description:==
On November 29, 2016, the licensee was issued NRC Inspection Report No.
05000346/2016403, which documented a licensee identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for enforcement discretion as described in Enforcement Guidance Memorandum (EGM) 14001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.
13 Subsequently, the inspectors reevaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within the interim Enforcement Policy discussed within NRC's Enforcement Policy, Section 9.3.
Corrective Actions: As specified in the NRCs Enforcement Policy, Section 9.3, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action.
Enforcement:
Violation: On November 29, 2016, a violation of 10 CFR Part 37 was documented in Davis-Besse Inspection Report Number 05000346/2016403. The inspectors determined that the previously identified violation remains.
Basis for Discretion: This violation met all of the criteria for enforcement discretion as described in NRC's Enforcement Policy, Section 9.3, Enforcement Discretion for Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material (10 CFR Part 37).
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On December 2, 2025, the inspectors presented the integrated inspection results to R. Craven, Site Vice President, and other members of the licensee staff.
On July 10, 2025, the inspectors presented the radiation protection inspection results to A. Filipiak, Organizational Effectiveness Director, and other members of the licensee staff.
On August 28, 2025, the inspectors presented the ISFSI program review and license renewal inspection results to T. Brown, Site Vice President, and other members of the licensee staff.
On September 17, 2025, the inspectors presented the URI closure for multiple NFPA 805 Non-Power Operation Transition Issues and URI closure for failure to correctly implement 10 CFR 50.59 administrative procedures inspection results to R. Craven, Site Vice President, and other members of the licensee staff.
14 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date CR202208332 Missing FME Plugs on DBHSM1 to DBHSM4 11/02/2022 CR202403283 MSC2403-30: Dry Cask Storage Records are Located Under Wrong Folder Unique Identifier in Records Management 04/15/2024 CR202407523 2024 CETI - ISFSI Pad Survey 09/24/2024 CR202407557 Formation of Ground Depression Beginning Near ZR3004 (HSM Area) 09/25/2024 Corrective Action Documents CR202505939 ISFSI Pad Broken Ground Cables 08/20/2025 Miscellaneous Davis-Besse Nuclear Power Station Emergency Plan 38 DBNE03400 Horizontal Storage Module (HSM) Monitoring 14 NOP-LP2001 Corrective Action Program 50 Procedures NOP-LP4003 Evaluation of Changes, Tests and Experiments 10 DBM202306131 2023 Dry Fuel Storage Pad Annual Radiological Survey 06/13/2023 DBM202406122 2024 Dry Fuel Storage Pad Annual Radiological Survey 06/12/2024 Radiation Surveys DBM202506048 2025 Dry Fuel Storage Pad Annual Radiological Survey 06/10/2025 60855 Self-Assessments ATA20248686 2025 Pre-NRC Inspection Assessment for ISFSI, 72.48 &
72.212 Programs 05/02/2025 CR201312587 HSM Concrete, Conduit, Coating Rework 08/15/2013 CR202007215 DSC 24P-R01 Was Not Rotated 180Degrees Prior to Loading in 1996 09/16/2020 CR202007216 Foreign Material Identified on the Rail During AMP Inspections 09/16/2020 CR202008358 Davis-Besse ISFSI Aging Management Program -
Groundwater Sampling Results Exceeded Limits in NOPM-NF3203 10/28/2020 CR202103959 Results from the 2020 Levelness Survey of the HSM Basemats 05/15/2021 Corrective Action CR202308176 ISFSI Pad Levelness Survey 11/01/2023 60859 Miscellaneous Davis-Besse Tollgate Assessment 3
15 ATA202112864 Perform ISFSI & HSM Basemat Levelness Surveys 09/27/2022 ATA202216483 Perform ISFSI & HSM Basemat Levelness Surveys 10/30/2023 ATA202318701 Perform ISFSI & HSM Basemat Levelness Surveys 03/28/2025 Miscellaneous NPE2500015 Review of Contracted NDE Personnel Certifications and Procedures being used under the Contractors QA Program 08/18/2025 Quality Assurance Program Manual 04/19/2024 DBNE06471 Dry Fuel Storage Unloading 1
NOP-CC5708 Written Practice for the Qualification and Certification of Nondestructive Examination Personnel 17 NOP-CC5709 Review and Approval of Contracted Nondestructive Examination Activities 7
NOP-LP2022 Administration of the Quality Assurance Program Manual (QAPM) 7 NOP-NF3203 Independent Spent Fuel Storage Installation Aging Management Program (AMP) 4 NOPM-NF3203 Davis-Besse Aging Management Program Basis Document for the Standardized NUHOMS System 06/12/2025 PTIP 3530210.1 Davis-Besse AMP Inspections 2
QCP 10 Purchasing Requirements for NDT Vendors 30 QCP 101 Qualification and Certification of NDT Personnel 60 Procedures SPM 10.5 Visual Inspection of Dry Shielded Canisters, Transfer Casks, and Bolted Storage Casks 5
200802045 Perform Aging Management Inspections on HSM1 and DSC1 installed in 1996 12/18/2020 60859 Work Orders 200832101 Perform Aging Management Inspections on HSM1 and DSC1 Installed in 1996 05/12/2025 M017A Diesel Generators 22 Drawings M017B Diesel Generators Air Start 47 71111.04 Procedures DBSC03071 Emergency Diesel Generator 2 Monthly Test 45 71111.05 Corrective Action Documents Resulting from Inspection CR20255046 NRC Question to the Work Support Center
16 DBFP00005 Fire Brigade 15 PFP-AB325 High Voltage Switchgear Room A, Room 325, Fire Area S 6
PFP-AB328 Component Cooling Water Heat Exchanger and Pump Room, Room 328, Fire Area T 5
PFP-AB422B Cable Spreading Room Ladder Space, Fire Area CC 4
PFP-AB601W No. 1 Main Steam Line Area and Purge Inlet Equipment Room, Fire Area DH 5
PFP-AB602 No. 2 main Steam Line Area, Fire Area DH 5
Fire Plans PFP-S60000 Service Building 6, Laydown Area, Station Blackout Diesel 4
71111.05 Miscellaneous 13-08/08/251 Fire Brigade Drill Record Miscellaneous CNSA011.01019 Analysis of Service Water System Online Flow Verification Data for Train 2 6
71111.07A Procedures DBSP03006 Service Water Train 2 Cold Forebay Design Flow Verification 12 CR202504921 SW1379 Evaluated Over Thrust During Diagnostic Testing 07/08/2025 CR202506204 3 Purification Demin Inlet Valve MU1903 OPEN With No Pressure Drop 09/02/2025 Corrective Action Documents CR202506824 Misconfiguration of Battery Test Set Leads 09/29/2025 CME011.01109 Valve Factor Methodology for Determining Required Thrust 6
Miscellaneous PMR 601495 Perform PM 11099 More Often (SW1379) 10yr to 6yr 07/09/2025 DBME03003 Station Battery Charger Test 17 DBME09209 BCT2000 Operating Guide 6
71111.12 Procedures NOBP-ER3204A Check Valve Condition Monitoring Program 3
Corrective Action Documents CR202301493 SAC 1 Auto Trips on Startup 0
Corrective Action Documents Resulting from Inspection CR202505430 NRC Identified Items 0
71111.13 Procedures NOBP-OP001502 Davis-Besse Nuclear Power Station Daily Status Report 11 CR202505442 PAM Temperature Instruments Not Calibrated within Their Required Frequency 07/30/2025 CR202505483 Recirculation Flow for HPI 2 out of Band 08/01/2025 CR202505675 Received Unexpected Annunciator ICS Input Mismatch 08/09/2025 71111.15 Corrective Action Documents CR202505736 Spiking on SP988 and SP989 for SG1 Level Indication 08/12/2025
17 CR202505747 LCO 3.3.11 Required Action B3 Not Completed in Completion time 08/13/2025 CR202505854 NI2 SUR and CPS Reading Erratically 08/17/2025 C-ME-050.03-111 MOV Thrust / Torque Calculation for AF599 12 C-ME-050.03-112 MOV Thrust / Torque Calculation for AF608 9
C-ME-050.03-117 Limiting Differential Pressure for AF3870 and AF3872 0
C-ME-050.03-120 MOV Thrust / Torque Calculation for AF3870 9
C-ME-050.03-121 MOV Thrust / Torque Calculation for AF3872 12 C-ME-050.03-122 Differential Pressures for AF599 and AF608 1
Calculations C-ME-050.03-130 PPM Analysis for AF3869, AF3970, AF3871, and AF3872 1
15-00776 50.59 Screening - Switchyard 345kV Breaker Replacement 16 24-01449 50.59 Screening - Calculation C-ME-050.03-112, 111 & 112 0
71111.21M Miscellaneous 24-01590 50.50 Screening - Calculation C-ME-050.03-117, 120, 121, 130 0
CR20255363 Small Oil Puddle Found In Front of SAC 2 07/28/2025 CR20255532 Station Air Compressor 2 Tripped 08/04/2025 CR20255535 SV676 SAC 2 LP Intercooler Moisture Separator Drain Solenoid Valve Clogged with Sediment 08/04/2025 Corrective Action Documents CR20255566 Debris in SAC 2 Intercooler and Aftercooler Condensate Drain Bowls 08/05/2025 DbOP06251 Station and Instrument Air System Operating Procedure 54 DBPF09301 Preventive Maintenance for Type SMB and SB Limitorque Operators 12 DBPF09302 Testing Motor Operated Valves 12 DBPF09302 Testing Motor Operated Valves 12 DBSC03070 Emergency Diesel Generator 1 Monthly Test 51 DBSP03151 AFP 1 Quarterly Test 33 DBSP03218 HPI Train 1 Pump and Valve Test 36 DBSP03446 Decay Heat Train 1 Pump and Valve Test 14 DBSS03091 Motor-Driven Feed Pump Quarterly Test 23 DBSS04202 Emergency Feedwater Pump Monthly Test 9
Procedures NOP-WM4004 Foreign Material Exclusion 0
200811203 PM 10919 MVHP2 Diagnostic Static Test 09/10/2025 200898569 PM2041 Clean/Inspect MDP Coolers 09/17/2025 71111.24 Work Orders 200922321 Test Motor Operated Valve 07/08/2025
18 200926037 P241 Motor-Driven Feed Pump Quarterly Test 09/17/2025 200947502 PM 2070 MVHP32 Insp HPI 1 Recirc 09/10/2025 200977794 Remove and Clean Intercooler/Aftercooler Drain Bowls 08/05/2025 CR202400592 Type B Fuel Shipping Container Not Shipped due to Not Being Able to be Properly Closed 01/23/2024 CR202401446 Radioactive Material identified During Baseline Survey 02/23/2024 Corrective Action Documents CR202500576 LLRWSF Roll Up Door Would Not Close 01/28/2025 Corrective Action Documents Resulting from Inspection CR202504934 WO 200883155 Cover Page Requires Updating (NRC 71124.08) 07/09/2025 2023 Secondary Resin Analysis 03/03/2023 2024 Primary Resin, DAW Smears, PDI, SFP, and Duratek Resin Analysis 01/25/2024 Radioactive Material Transportation Specialist Training Records various Miscellaneous Material List Grouped by Location 07/08/2025 Davis-Besse PCP Process Control Program 09 DBHP01502 Dewatering of Filter Media 08 DBHP01510 Solid Radioactive Waste Processing and Handling 06 DBHP01511 Low-Level Radioactive Waste Storage Facility (LLRWSF) 09 DBHP01712 10 CFR 61 Sampling for Waste Classification 02 DBHP06120 Miscellaneous Liquid Waste Demineralizer Skid Operations 18 DBHP06121 Portable Demineralizer Sluice and Fill Operations 02 DBMM09226 Nuclear Filter Replacement Using Transfer Cask 06 DBMM09228 Nuclear Filter Replacement without Using Transfer Cask 03 NOP-OP4504 Requirements for Radioactive Materials Stored Outdoors 06 Procedures NOP-OP5103 Category 1 and 2 Radioactive Material Accountability 02 2023 Secondary Resin Liners 12/27/2023 20231001 Filter 11/18/2023 Shipping Records 20251001 Primary Resin Liner 06/27/2025 200867808 H3000001 06.000 Licensed Courses Leak Test 11/30/2023 200883155 HP3000001 06.000 Licensed Sources Leak Test 05/30/2024 71124.08 Work Orders 200915104 HP3000001 06.000 Licensed Sources Leak Test 05/20/2025
19 CR202107917 Trend - Increased makeup Rate to Fire Water Storage Tank 10/20/2021 Corrective Action Documents CR202504947 Trending of Jockey Fire Pump Identified Unexplained Step Change 07/09/2025 71152S Corrective Action Documents Resulting from Inspection CR202503529 LR Phase IV NRC Inspection Self-Assessment: Trending of Jockey Fire Pump Gap 05/08/2025 CR202100920 EDG 2 Speed Switch Failure from 09/04/2020 Past Operability 02/1/2021 Corrective Action Documents CR202105657 2021 EDG Reliability Evaluation: Speed Switch Design Concern for Application in DC System 07/26/2021 CR202200079 NRC Apparent Violation: Failure to Install EDG Speed Switch That Was Suitable to the Application CR202206570 NRC 2022 EDG Inspection: Potential Failure Mechanism for EDG Speed Switches Not Identified for EDG Speed Switch Failure 09/01/2022 CR202407266 NRC Identified a New Failure Mechanism for Previously Installed EDG Speed Switches 09/12/2024 Corrective Action Documents Resulting from Inspection CR-202407935 EDG Speed Switch Evaluation Concludes an Unanalyzed Condition Existed 10/10/2024 71153 Miscellaneous LER 21084/2021001 Emergency Diesel Generator Speed Switch Failure due to Direct Current System Ground 02