IR 05000346/2017008

NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000346/2017008

ML17143A342
Person / Time
Site:	Davis Besse
Issue date:	05/23/2017
From:	Ann Marie Stone Division Reactor Projects III
To:	Boles B FirstEnergy Nuclear Operating Co
References
IR 2017008
Download: ML17143A342 (17)

Text

May 23, 2017

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION-NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000346/2017008

Dear Mr. Boles:

On May 17, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans" inspection at your Davis-Besse Nuclear Power Station. On May 17, 2017, the NRC inspectors discussed the results of this inspection with Mr. K. Byrd and other members of your staff. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted un der your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station

personnel.

Based on the results of this inspection, the NRC has identified one finding that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that this finding did not involve a violation of regulatory requirements.

If you contest the finding or significance of the finding, 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 the Davis-Besse Nuclear Power Station. If you disagree with the 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 the Regional Administrator, Region III; and the NRC Resident Inspector at the 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 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,

/RA Karla Stoedter Acting for/

Ann Marie Stone, Team Leader Technical Support Staff

Division of Reactor Projects

Docket No. 50-346 License No. NPF-3

Enclosure: Inspection Report 05000346/2017008 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000346/2017008, 03/13/2017 - 05/17/2017; Davis-Besse Nuclear Power Station; Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel

Pool Instrumentation Orders and Emergency Preparedness Communication/staffing/Multi-Unit

Dose Assessment Plans.

This inspection was performed by three U.S. Nuclear Regulatory Commission (NRC) regional inspectors and one resident inspector. One (Green) finding was identified by the inspectors.

The finding did not involve a violation of NRC requirements. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.

Cornerstone: Mitigating Systems

Green.

A finding of very low safety significance was identified by the inspectors for failing to maintain adequate room temperature in the emergency feedwater facility (EFWF) to support equipment operation. Specifically, the inspectors identified temperatures below freezing in multiple locations on emergency feedwater (EFW)system piping and in the EFWF basement. In response, the licensee installed heaters to raise room temperature. This finding is not a violation of NRC requirements. The inspectors determined that failing to maintain adequate room temperature in the EFWF to support equipment was contrary to Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", Rev. 2 and was a performance deficiency. The finding is of more than minor significance because it was associated with the cornerstone attribute of protection against external factors and adversely affected the mitigating systems cornerstone objective.

A detailed risk evaluation (DTE) determined the finding was (Green). This finding was assigned a cross-cutting of "Challenge the

Unknown". (H.11) (Section 4OA5.1.c.1)

3

REPORT DETAILS

4OA5 Other Activities (TI 2515/191) The objective of Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency

Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans," is to verify the licensee has adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No. ML16267A471), and the NRC's safety evaluation (ADAMS Accession No. ML17017A340) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool.

The purpose of this TI was also to verify the licensee had implemented Emergency

Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such

an event. The inspection also verifies plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262). The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensee's submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections.

.1 Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The inspectors examined the licensee's established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The inspectors assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The inspectors selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; 4 and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The inspectors verified a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and periodic equipment inventories were in place and being conducted. Additionally, the inspectors examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The inspectors also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment. b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:

• developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;

• integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• protected FLEX equipment from site-specific hazards;

• developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and

• developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program (CAP) as appropriate.

c. Findings

(1) Failure to Maintain Adequate Room Temperature in the Emergency Feedwater Facility

Introduction:

A finding of very low safety significance (Green) was identified by the inspectors for failing to maintain adequate room temperature in the EFWF to support equipment operation. Specifically, the inspectors identified temperatures below freezing in multiple locations on EFW system piping and in the EFWF basement.

Description:

On March 14, 2017, the inspectors toured the EFWF and observed cold temperatures in the basement which houses the diesel driven EFW pump credited for phase 1 FLEX implementation. The inspectors later returned with a non-contact thermometer and measured surface temperatures on various sections of EFW piping. The lowest temperature observed was 22 degrees F in the vicinity of the Target Rock 5 discharge flow control valve. The inspectors subsequently notified the shift manager and communicated the conditions observed. As a result, the shift manager declared the EFW pump non-functional at time 1340 and the station entered FLEX specification (NORM-LP-7202) Attachment 4 (EFW Out of Service Requirements), Nonconformance A (Any EFW component nonfunctional such that FLEX strategy cannot be implemented). Required actions are Contingency Action A.1 (Initiate actions to restore FLEX Phase 1 capability with a restoration time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) and A.2 (Implement compensatory action or restore nonfunctional component with a restoration time of 90 days). Additionally, the station entered FLEX specification (NORM-LP-7202) Attachment 2 (FLEX Connection Points Out of Service Requirements), Nonconformance A (One required connection point Nonfunctional). Required actions are Contingency Action A.1 (validate availability of alternate ("N" or "N+1") function with a restoration time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) and A.2 (restore connection point to functional status in 45 days). The licensee initiated 2017-02870; "EFWF Lower Level EFW and Fire Piping Exposed to Freezing Temperatures", and added additional heating units and ventilation fans to the basement of the EFWF in an effort to raise temperature along with enhancing equipment operator monitoring every three hours to ensure a basement recirculation damper that communicated directly with the outside environment stayed closed. The licensee has since installed a damper on the building intake opening and modified the heating, ventilation and air conditioning system to provide better temperature control.

They also implemented increased operator monitoring during periods with low outside temperatures.

Analysis:

The inspectors determined that failing to maintain adequate room temperature in the EFWF to support equipment was contrary to NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", Rev. 2 and was a performance

deficiency. Davis Besse Procedure NOP-LP-7200, "FLEX Program For Davis-Besse" states that the program meets the requirements of NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", Rev. 2. NEI 12-06, Rev. 2, defines FLEX equipment as: "Equipment stored on-site or off-site whose primary function is to support FLEX strategies. The on-site equipment may be installed, pre-staged, or portable equipment based on the site-specific sequence of events for the ELAP with LUHS event and may be stored within the owner controlled area or in close proximity to the site". Further, NEI 12-06, Rev. 2, Section 11.3.3 requires FLEX equipment should be stored in a location, or locations, such that no one external event can reasonably fail the site FLEX capability. Although EFWF temperature issues were previously identified by the licensee, the NRC identified inadequacies in the licensee's characterization and evaluation of the issue of concern that had not been previously identified. Therefore, the finding is being treating as NRC-identified. The failure to maintain adequate room temperature in the EFWF to support equipment operation is of more than minor significance because it was associated with the 6 cornerstone attribute of protection against external factors and adversely affected the mitigating systems cornerstone objective "To ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage)." The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of findings," Table 3 for the mitigating systems cornerstone. The inspectors answered "Yes" to question E which directed the inspectors to IMC 0609, Appendix O. As the issue involved equipment credited in the plant's EOPs for any loss of normal f eedwater or auxiliary feedwater, and not just those associated with large external events and extended loss of alternating current (AC) power (ELAP), Appendix O directed the inspectors to Appendix A. The inspectors used Appendix A, Exhibit 2, "Mitigating Systems Screening Questions". The inspectors answered "Yes" to the question in Section B of Exhibit 2, and "Yes" to question 1 of Exhibit 4, screening the issue to a Detailed Risk Evaluation (DRE). The Senior Risk Analyst (SRA) performed a DRE of the performance deficiency.

The Davis Besse simplified plant analysis risk (SPAR) model was used, and assuming an availability/reliability value for the EFW system of 1E-1, the delta-CDF for one year exposure was calculated to be approximately 1E-6. Applying the exposure time of three days yielded a result of approximately 1E-8. The DRE was completed and given an independent review by another SRA on April 13, 2017. The DRE concluded that the issue is (Green). This finding has a cross-cutting aspect in the area of human performance. Specifically, the cross-cutting aspect of "Challenge the Unknown" was assigned to the finding because an equipment operator previously toured the EFWF basement and did not verify adequate temperature of components despite dramatic temperature variations throughout facility indicative of a potential problem. (H.11)

Enforcement:

This finding does not involve enforcement action because no violation of regulatory requirements was identified. Because the finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as FIN 05000346/2017008-01, Failure to Maintain Adequate Room Temperature in the Emergency Feedwater Facility.

.2 Spent Fuel Pool Instrumentation

a. Inspection Scope

The inspectors examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment. b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the spent fuel pool (SFP)7 instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:

• installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s) and safety evaluation;

• installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s);

• trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and

• developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's CAP.

c. Findings

No findings were identified.

.3 Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit ELAP scenario as described in the licensee's staffing asse ssment and the NRC safety assessment.

The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's multi-unit dose assessment submittal. Documents reviewed are listed in the attachment. b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:

• the licensee satisfactorily implemented required staffing changes to support a multi-unit ELAP scenario;

• EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and

• the licensee implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensee's site-specific dose assessment software and approach.

8 The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's CAP.

c. Findings

No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary On May 17, 2017, the NRC inspectors discussed the results of this inspection with

Mr. K. Byrd and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings On March 17, 2017, the NRC inspectors discussed the preliminary results of this inspection with Mr. K. Byrd and other members of the licensee's staff.

At the time, one issue remained open within the mitigating strategies section. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Byrd Director, Engineering

T. Brown Director, Performance Improvement

A. Wise Director, Fleet Engineering

P. McCloskey Manager, Regulatory Compliance

G. Laird Manager, Operations

G. Michael Manager, Design Engineering

B. Pollauf Manager, Plant Engineering

J. Vetter Manager, Emergency Response

K. Zellers Manager, Technical Services

J. Carr Operations (FLEX Team)

T. St. Clair Fleet Engineer (FLEX Team) D. Blakely Engineering Analysis S. Hall Site Communications

D. Gerren Technical Services

J. Greenwood Technical Services

V. Schultz-Wadsworth Regulatory Compliance

G. Wolf Regulatory Compliance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000346/2017008-01 FIN Failure to Maintain Adequate Room Temperature in the Emergency Feedwater Facility (Section 4OA5.1.c.1)

Discussed

None.

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that