IR 05000346/2015001

IR 05000346/2015001 and 07200014/2015001; on 1/1/15-3/31/15; Davis-Besse Nuclear Power Station; Routine Quarterly Integrated Inspection

ML15113B387
Person / Time
Site:	Davis Besse
Issue date:	04/23/2015
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Lieb R FirstEnergy Nuclear Operating Co
References
IR 2015001
Download: ML15113B387 (49)

Text

UNITED STATES ril 23, 2015

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION INTEGRATED INSPECTION REPORT 05000346/2015001 AND 07200014/2015001

Dear Mr. Lieb:

On March 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on April 9, 2015, with you and other members of your staff.

Based on the results of this inspection, no findings were identified. One licensee-identified violation which was determined to be of very low safety significance is documented in Section 4OA7 of this report. The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-346;72-014 License No. NPF-3

Enclosure:

IR 05000346/2015001 and 07200014/2015001 w/Attachment: Supplemental Information

REGION III==

Docket Nos.: 50-346;72-014 License No: NPF-3 Report No: 05000346/2015001 and 07200014/2015001 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: January 1, 2015, through March 31, 2015 Inspectors: D. Kimble, Senior Resident Inspector T. Briley, Resident Inspector R. Baker, Operations Licensing Examiner M. Learn, Reactor Engineer, DNMS M. Mitchell, Health Physicist R. M. Morris, Senior Operations Licensing Examiner Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000346/2015001 and 07200014/2015001; 1/1/15-3/31/15;

Davis-Besse Nuclear Power Station; Routine Quarterly Integrated IR.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, Aspects Within the Cross-Cutting Areas effective date December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

Cornerstone: Initiating Events

A violation of very low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program (CAP). This violation and CAP tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period operating at full power. With the exception of small power maneuvers (e.g., reductions of 10 percent power or less) to facilitate planned evolutions and testing, the unit remained operating at or near full power for the balance of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition-Heavy Snowfall Conditions

a. Inspection Scope

On February 1-2, 2015, the site experienced a severe winter storm that resulted in a Level 3 (most severe possible) Snow Emergency in Ottawa County Ohio, where the plant is located, and in many of the surrounding counties as well. The inspectors observed the licensees preparations and planning for the significant winter weather potential. The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel. The inspectors focused on plant managements actions for implementing the stations procedures for ensuring adequate personnel for safe plant operation and emergency response would be available. The inspectors conducted a site walkdown including walkdowns of various plant structures and systems to check for maintenance or other apparent deficiencies that could affect system operations during the predicted significant weather. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report.

These reviews by the inspectors constituted a single readiness for impending adverse weather condition inspection sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Alignment Verifications

a. Inspection Scope

The inspectors performed partial system physical alignment verifications of the following risk-significant systems:

• Containment Spray Train No. 2 during the period when Containment Spray Train No. 1 was out of service for planned maintenance during the week ending January 10, 2015;

• Low Pressure Injection (LPI) Train No. 1 during the period when LPI Train No. 2 was out of service for planned maintenance during the week ending January 31, 2015; and

• High Pressure Injection (HPI) Train No. 2 during the period when HPI Train No. 1 was out of service for planned maintenance during the week ending February 14, 2015.

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report (USAR), technical specification (TS)requirements, outstanding work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions.

The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

These activities by the inspectors constituted three partial system alignment verification inspection samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Alignment Verification

a. Inspection Scope

During the period from March 16, 2015, through March 31, 2015, the inspectors performed a complete system alignment inspection of the station's two emergency diesel generators (EDGs) to verify the functional capabilities of the site's emergency alternating current (AC) power system. This equipment was selected because the EDGs are considered both important to safety and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the EDGs to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the licensees CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report.

These activities constituted a single annual complete system alignment verification inspection sample as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Protection Zone Inspections

a. Inspection Scope

The inspectors conducted fire protection zone inspection tours which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Main and motor-driven feedwater pump room; Turbine Building Elevation 565' (Room 252-Fire Area II) during the period of March 30-31, 2015;

• Hydrogen and nitrogen storage tank construction work area west of the Auxiliary Building; Elevation 585' during the period of March 30-31, 2015;

• Service water pump room; Intake Structure Elevation 576 (Room 52-Fire Area BF) during the period of March 30-31, 2015; and

• Emergency core cooling system (ECCS) pump room 1-1; Auxiliary Building Elevation 555 (Room 105-Fire Area AB) during the period of March 30-31, 2015.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.

These activities constituted four quarterly fire protection zone inspection tour samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

During the early morning hours on March 20, 2015, the inspectors observed the licensees fire brigade respond to a simulated Class 'C' electrical fire on the 603' elevation of the station's turbine building. Based on their observations, the inspectors evaluated the readiness of the station's fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner during the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

• The proper wearing of turnout gear and self-contained breathing apparatus;

• The proper use and layout of fire hoses;

• The employment of appropriate firefighting techniques;

• That sufficient firefighting equipment was brought to the scene;

• The effectiveness of fire brigade leader communications, as well as command and control;

• The search for victims and propagation of the fire into other plant areas;

• Smoke removal operations;

• The utilization of pre-planned strategies;

• The adherence to the pre-planned drill scenario; and

• The satisfactory completion of the drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted a single annual fire protection drill inspection sample as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

.1 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of ECCS Room Cooler No. 1 heat exchanger to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed for this inspection are listed in the Attachment to this document.

The inspectors' reviews in this area constituted a single annual heat sink performance inspection sample as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Simulator Training

a. Inspection Scope

On February 3, 2015, the inspectors observed a crew of licensed operators in the plants simulator during the performance of an unannounced graded crew simulator casualty drill scenario. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. In addition, the inspectors verified that the licensees personnel were observing NRC examination security protocols to ensure that the integrity of the scenarios was being protected from being compromised. The inspectors evaluated the following areas:

• Licensed operator performance;

• The clarity and formality of communications;

• The ability of the crew to take timely and conservative actions;

• The crews prioritization, interpretation, and verification of annunciator alarms;

• The correct use and implementation of abnormal and emergency procedures by the crew;

• Control board manipulations;

• The oversight and direction provided by licensed Senior Reactor Operators (SROs); and

• The ability of the crew to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

These observations and activities by the inspectors constituted a single quarterly licensed operator requalification program simulator training inspection sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Operator Activities in the Control Room and

in the Plant

a. Inspection Scope

During the course of the inspection period, the inspectors performed numerous observations of operator performance in the plants control room and in the plant to verify that operator performance was adequate and that plant evolutions were being conducted in accordance with approved plant procedures. Specific activities observed that involved a heightened tempo of activities or periods of elevated risk included, but were not limited to:

• Scheduled reactor protection system (RPS) control rod drive (CRD) trip breaker testing and associated unit power maneuvers during the week ending January 24, 2015;

• Actions taken by the on-shift crew in response to malfunctions of the unit load demand load control station computer on the main control board during the week ending January 24, 2015;

• Delta temperature cold (Tc) control system adjustments to support operating steam generator level control during the week ending February 14, 2015;

• Periodic CRD mechanism testing and associated unit power maneuvers during the week ending March 7, 2015; and

• Main turbine valve testing and crew response to Turbine Stop Valve No. 4 testing issues during the weeks ending March 7, 2015, and March 21, 2015.

The inspectors evaluated the following areas during the course of the control room and in-plant observations:

• Licensed operator performance;

• The clarity and formality of communications;

• The ability of the crew to take timely and conservative actions;

• The crews prioritization, interpretation, and verification of annunciator alarms;

• The correct use and implementation of normal operating, annunciator alarm response, and abnormal operating procedures by the crew;

• Control board manipulations;

• The oversight and direction provided by on-watch SROs and plant management personnel; and

• The ability of the crew to identify and implement appropriate TS actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

These observation activities by the inspectors of operator performance in the stations control room and in the plant constituted a single quarterly inspection sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.3 Biennial Review

a. Inspection Scope

The following inspection activities were conducted during the week of January 19, 2015, to assess licensee conformance with both 10 CFR Part 55, Subpart c, Medical Requirements; 10 CFR 55.53, Conditions of Licenses; and allow closure of unresolved item (URI)05000346/2014005-01, Additional Review of Medical Records Needed:

• The inspectors reviewed the facility licensee's program for maintaining documentation required to comply with 10 CFR 55.23; and

• The inspectors reviewed the medical records for all licensed operators to assess compliance with 10 CFR 55.53(i) and (I). (03.08)

The documents reviewed are listed in the Attachment to this report.

As discussed above, these reviews by the inspectors were a follow-on activity to facilitate closure of URI 05000346/2014005-01, and as such they did not constitute a Biennial Licensed Operator Requalification Program inspection sample as defined in IP 71111.11-05.

b. Findings

(Closed) Unresolved Item 05000346/2014005-01: Additional Review of Medical Records Needed As documented in NRC IR 05000346/2014005 (ADAMS Accession No. ML15028A034),the inspectors reviewed a sample of the licensed operator medical records for compliance with 10 CFR Part 55 as a part of the periodic NRC IP 71111.11B inspection during the week ending December 13, 2014. The inspectors determined that 2 of 12 records reviewed (approximately 17 percent) had apparent discrepancies which potentially affect the conditions required as part of a licensed operators license to maintain medical qualification. The inspectors noted that the medical records were difficult to review due to a lack of succinct filing within the records themselves. The inspectors identified an URI concerning the auditable condition of the medical records and completeness of information retained. Further inspection and review of the medical records were required to ascertain the level of the discrepancy, and to determine if a potential non-compliance condition existed.

During the week ending January 24, 2015, the inspectors performed follow-up inspection activities to disposition the previously identified URI concerning the auditable condition of the licensed operators medical records. The facility licensee had performed an audit of all licensed operator medical records to consolidate retained NRC correspondence and supporting documentation required as part of the operators docket file. The inspectors reviewed the medical records for all of the facility's licensed operators. The inspectors did not identify any deficiencies in the medical record information that:

(1) indicated a licensed operator was currently performing licensed duties while in noncompliance with all conditions of the license; or

(2) indicated a licensed operator required any additional conditions be placed on the license based upon current medical conditions. However, the inspectors did note that the NRC had not been updated in a timely manner with a medication that had changed for several operators. The reason for this failure of the timely notification was that the licensed operators had not notified the licensee's medical staff in a timely manner. In September 2014, the licensee initiated CR 2014-13639 to focus on the trend of operators not notifying the licensee's medical staff of changes in health conditions that may affect the performance of licensed duties, as required by facility procedures. The inspectors reviewed multiple CRs that had been written by the medical staff concerning this issue. The inspectors discussed this issue with the applicable licensee management personnel, who indicated that they were aware of the significance of the issue and were working with their staff to attempt to correct this problem. Since no additional issues with the medical record review were identified, the inspectors determined that URI 05000346/2014005-01, Additional Review of Medical Records Needed, does not require any further action and no findings were identified.

This URI is closed.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated performance issues involving the following risk-significant systems:

• The station's main exhaust ventilation system sample flow;

• The station's steam generator level instrumentation, with particular emphasis on the operating range level; and

• The performance of underground piping and tanks, with particular emphasis on those components and systems that potentially could result in the release of tritium to the environment.

The inspectors reviewed events such as where ineffective equipment maintenance could result in or had resulted in valid or invalid automatic actuations or system transients and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices;

• Identifying and addressing common cause failures;

• Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• Characterizing system reliability issues for performance;

• Charging unavailability for performance;

• Trending key parameters for condition monitoring;

• Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• Verifying appropriate performance criteria for systems, structures, and components (SSC)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

The inspectors reviews constituted three quarterly maintenance effectiveness inspection samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Scheduled work activities to repair and test containment isolation valve (CIV)

RC-240A in containment with the unit operating at power during the week ending March 7, 2015; and

• Issues involving the at-power testing and test circuitry for the main turbine steam valves during the weeks ending March 7, 2015, through March 21, 2015; and

• Scheduled maintenance work on the station's motor-driven feed pump during the week ending March 28, 2015.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the Attachment to this report.

The inspectors' review of these maintenance risk assessments and emergent work control activities constituted three inspection samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Operability of the plant's ultimate heat sink following the restoration and removal of excessive silt buildup during routine surveillance monitoring of the safety-related intake canal depth, as documented in CR 2014-15167, during the period of January 12, 2015, through January 31, 2015;

• Operability and functionality of reactor protection system channel No. 4 with the overpower trip bistable out of tolerance, as documented in CR 2015-00047, during the period of January 19, 2015 through February 14, 2015;

• Operability and functionality of steam generator operate-range level instrumentation following identification of instrument uncertainty not being applied, as documented in CR 2015-01595, during the period of February 9, 2015 through February 21, 2015; and

• Operability and functionality of auxiliary feedwater train No. 1 with an error code indicated on level indicating controller No. 6452, the control room flow controller for that train, as documented in CR 2015-04127, during the week ending March 28, 2015.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors verified, where applicable, that the bounding limitations of the evaluations were valid.

Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report.

The review of these issues by the inspectors constituted four inspection samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Permanent Plant Modification

a. Inspection Scope

The inspectors reviewed the following change to the facility:

• Engineering Change Package (ECP) No. 14-0376-010: "Change Integrated Control System High Level Limit from 92 percent to 93.5 percent."

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation documents against the design basis, the USAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of any safety-related systems, or systems important to safety. The inspectors observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; that the modification operated as expected; and that operation of the modification did not impact the operability of any interfacing systems. The inspectors verified that relevant procedure, design, and licensing documents were properly updated. Finally, the inspectors discussed the plant modification with operations, engineering, and training department personnel to ensure that the individuals were aware of how the operation with the modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

The inspectors review of this permanent plant modification constituted a single inspection sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Quarterly Resident Inspector Observation and Review of Post-Maintenance Testing

Activities

a. Inspection Scope

The inspectors reviewed the following post-maintenance testing (PMT) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• Operational and functional testing of reactor trip breaker 'A' following planned and scheduled breaker replacement during the week ending January 24, 2015;

• Operational and functional testing of LPI train No. 2 following planned maintenance during the week ending January 31, 2015;

• Operational and functional testing of EDG No. 1 following planned maintenance during the week ending February 14, 2015;

• Operational and functional testing of ECCS Room Cooler No. 1 following planned maintenance during the week ending February 21, 2015; and

• Operational and functional testing of CIV RC-240A following repairs during the week ending March 7, 2015.

These activities were selected based upon the SSC's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with the PMTs to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

The inspectors reviews of these activities constituted five PMT inspection samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the results for the following testing activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• Biennial testing of remote shutdown system transfer switches and control circuits for essential 4160 volt bus C1 and essential 480 volt bus E1 during the week ending January 17, 2015 (Routine);

• Monthly testing of EDG No. 2 during the week ending January 31, 2015 (Routine);

• Periodic CRD mechanism exercise testing during the week ending March 7, 2015 (Routine);

• Periodic main turbine stop valve closure time testing during the week ending March 21, 2015 (Routine); and

• Local leak rate testing of CIV RC-240A following replacement of the actuator stem nut during the week ending March 7, 2015 (CIV).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• Did preconditioning occur;

• The effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• Acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;

• Plant equipment calibration was correct, accurate, and properly documented;

• As-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;

• That measuring and test equipment calibration was current;

• That test equipment was used within the required range and accuracy;

• That applicable prerequisites described in the test procedures were satisfied;

• That test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• That test data and results were accurate, complete, within limits, and valid;

• That test equipment was removed after testing;

• Where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• Where applicable, that test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• Where applicable for safety-related instrument control surveillance tests, that reference setting data were accurately incorporated in the test procedure;

• Where applicable, that actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• That prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• That equipment was returned to a position or status required to support the performance of its safety functions; and

• That all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

These activities conducted by the inspectors constituted four routine surveillance testing inspection samples and a single CIV local leak rate testing sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observations

a. Inspection Scope

The inspectors evaluated the conduct of the following planned licensee emergency drills:

• A full scale integrated emergency preparedness (EP) drill conducted on February 24, 2015; and

• A full scale dry run EP drill conducted on March 24, 2015, in preparation for the licensee's graded biennial EP exercise planned for May of 2015.

The inspectors observed emergency response operations in the Emergency Operations Facility and the backup/alternate Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures, and to identify any weaknesses or deficiencies in classification, notification, or protective action recommendation development activities. The inspectors also attended the licensee drill critique to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of their inspection activities, the inspectors reviewed the drill packages for each scenario and other documents listed in the Attachment to this report.

The inspectors' reviews of these EP drill scenarios and other related activities constituted two inspection samples as defined in IP 71114.06-06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

The activities documented in this section constituted a single complete radioactive gaseous and liquid effluent treatment inspection sample as defined in IP 71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

The inspectors reviewed the radiological effluent release reports issued since the last inspection to determine if the reports were submitted as required by the Offsite Dose Calculation Manual (ODCM)/TSs. The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved.

The inspectors selected radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, to review these issues during the onsite inspection, as warranted, given their relative significance and determine if the issues were entered into the CAP, and adequately resolved.

b. Findings

No findings were identified.

Offsite Dose Calculation Manual and Final Safety Analysis Report Review Inspection Scope The inspectors reviewed USAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they could be evaluated during inspection walkdowns.

The inspectors reviewed changes to the ODCM made by the licensee since the last inspection against the guidance in NUREGs 1301, 1302, and 0133, and Regulatory Guides (RGs) 1.109, 1.21, and 4.1. When differences were identified, the inspectors reviewed the technical basis, or evaluations of the change, during the onsite inspection to determine whether they were technically justified, and maintain effluent releases as-low-as-reasonably-achievable.

The inspectors reviewed licensee documentation to determine if the licensee had identified any non-radioactive systems that have become contaminated as disclosed either through an event report or the ODCM since the last inspection. This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations, and allowed a determination if any newly contaminated systems have an unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways, and whether the associated effluents were reported in accordance with RG 1.21.

Findings No findings were identified.

Groundwater Protection Initiative Program Inspection Scope The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

Findings No findings were identified.

Procedures, Special Reports, and Other Documents Inspection Scope The inspectors reviewed Licensee Event Reports (LERs), event reports and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed the effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations.

The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensees program and aid in selecting areas for inspection review (smart sampling).

Findings No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration, and flow paths align with the documents reviewed in 02.01 above, and to assess equipment material condition.

Special attention was made to identify potential unmonitored release points (such as temporary structures butted against turbine, auxiliary or containment buildings), building alterations which could impact airborne, or liquid effluent controls, and ventilation system leakage that communicate directly with the environment.

For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable.

The inspectors walked down filtered ventilation systems to assess for conditions such as degraded high-efficiency particulate air /charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.

As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent (including sample collection and analysis) to evaluate whether appropriate treatment equipment was used and the processing activities align with discharge permits.

The inspectors determined if the licensee has made significant changes to their effluent release points (e.g., changes subject to a 10 CFR 50.59 review or require NRC approval of alternate discharge points).

As available, the inspectors observed selected portions of the routine processing and discharging of liquid waste (including sample collection and analysis) to determine if appropriate effluent treatment equipment is being used, and that radioactive liquid waste is being processed and discharged in accordance with procedure requirements and aligns with discharge permits.

b. Findings

No findings were identified.

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and assessed whether adequate controls have been implemented to ensure representative samples were obtained (e.g., provisions for sample line flushing, vessel recirculation, composite samplers, etc.).

The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to assess whether controls were in place to ensure compensatory sampling was performed consistent with the radiological effluent ODCM/TSs, and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory comparison program to evaluate the quality of the radioactive effluent sample analyses, and assessed whether the inter-laboratory comparison program includes hard-to-detect isotopes as appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

The inspectors reviewed the methodology the licensee uses to determine the effluent stack and vent flow rates to determine if the flow rates were consistent with radiological effluent ODCM/TSs or USAR values, and that the differences between assumed and actual stack and vent flow rates did not affect the results of the projected public doses.

b. Findings

No findings were identified.

Air Cleaning Systems Inspection Scope The inspectors assessed whether surveillance test results since the previous inspection for TS required ventilation effluent discharge systems (high-efficiency particulate air and charcoal filtration), such as the containment/auxiliary building ventilation system, met TS acceptance criteria.

Findings No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

The inspectors reviewed all significant changes in reported dose values compared to the previous radiological effluent release report (e.g., a factor of five, or increases that approach Appendix I criteria) to evaluate the factors which may have resulted in the change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to assess whether the projected doses to members of the public were accurate, and based on representative samples of the discharge path.

The inspectors evaluated the methods used to determine the isotopes that are included in the source term to ensure all applicable radionuclides are included within detectability standards. The review included the current Part 61 analyses to ensure hard-to-detect radionuclides are included in the source term.

The inspectors reviewed changes in the licensees offsite dose calculations since the last inspection to evaluate whether changes were consistent with the ODCM and RG 1.109. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to evaluate whether appropriate factors were being used for public dose calculations.

The inspectors reviewed the latest Land Use Census to assess whether changes (e.g., significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public or critical receptor, etc.) have been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) are within the 10 CFR Part 50, Appendix I, and TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

No findings were identified.

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the groundwater protection initiative to determine if the licensee had implemented its program as intended and to identify any anomalous results. For anomalous results or missed samples, the inspectors assessed whether the licensee had identified and addressed deficiencies through its CAP.

The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75

(g) records. The inspectors reviewed evaluations of leaks or spills and reviewed any remediation actions taken for effectiveness. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:

• Assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term and assessing whether a survey/evaluation had been performed to include consideration of hard-to-detect radionuclides; and

• Determining whether the licensee completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contain or potentially contain radioactivity, and the potential for ground water leakage from these onsite surface water bodies. The inspectors assessed whether the licensee was properly accounting for discharges from these surface water bodies as part of their effluent release reports.

The inspectors assessed whether on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year were documented in the annual radiological environmental operating report for the radiological environmental monitoring program or the annual radiological effluent release report for the radiological effluent TSs.

For significant, new effluent discharge points (such as significant or continuing leakage to ground water that continues to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. In addition, they evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Occupational Radiation Safety, Public Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours Performance Indicator (PI) for the period from January 2014 to December 2014.

To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operations narrative logs, CRs, event reports and NRC integrated IRs for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this report.

These reviews by the inspectors constituted a single unplanned scrams per 7000 critical hours inspection sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams with Complications PI for the period from January 2014 to December 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CRs, event reports and NRC integrated IRs for the period to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the to this report.

These reviews by the inspectors constituted a single unplanned scrams with complications inspection sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Unplanned Transients per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours PI for the period from January 2014 through December 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CRs, maintenance rule records, event reports and NRC integrated IRs for the period to validate the accuracy of the submittals.

The inspectors also reviewed the licensees CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this report.

These reviews by the inspectors constituted a single unplanned transients per 7000 critical hours inspection sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily CR packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Follow-Up Sample for In-Depth Review: Review of Medical Items Entered into the

Corrective Action Program for Operator Licensing

a. Inspection Scope

The inspectors performed a review of documents in the licensees CAP related to medical issues associated with licensed operators for the previous two-year period.

Identified CRs were compared to the medical records and documentation sent to the NRC to access implementation of the licensees CAP process for initiating and submitting CRs focused on licensed operator medical conditions and reporting identified changes in those medical conditions to the licensee's applicable health services personnel.

This review by the inspectors constituted a single in-depth problem identification and resolution inspection sample as defined in IP 71152-05.

Observations The inspectors noted that the licensee had identified a trend with licensed operators not notifying the medical staff of changes in health conditions as soon as issues were identified. Per the facility licensees procedure, changes in medication for licensed operators who had a license condition to take medications as prescribed to maintain their medical qualifications must be reported to the applicable licensee health services personnel prior to performing licensed duties. The inspectors noted that failures to notify the medical staff had resulted in the NRC not being updated in a timely manner concerning a medication that had changed for several operators.

The untimely notification of the licensee's medical staff of changes in medical conditions had been an identified by the licensee as a trend. In September 2014, the licensee initiated CR 2014-13639 to focus on the trend of operators not notifying the medical staff of changes in health conditions which could have affected the performance of licensed duties, as required by facility procedures. The inspectors reviewed multiple CRs that had been written by the medical staff concerning this issue. The inspectors discussed this issue with members of the licensee's management team, who indicated that they were aware of the significance of the issue and were working with their staff to attempt to correct this problem.

The CRs, although somewhat vague, were accurate for the medical conditions. The information sent to the NRC contained all of the recent documentation from the licensee's medical review officer and the individuals personal physician. In summation, the inspectors concluded that:

• There was no indication of any attempt to omit pertinent information on the part of the facility licensee;

• The relevant communications in this area between the licensee's medical staff and the licensee's regulatory compliance personnel could be improved;

• The CRs that were written by the licensee's medical staff were discussed and reviewed by the manager of their department prior to being submitted to the system;

• Because of the personal medical nature of the information, the CRs had to be carefully worded; and

• If there were any questions about the wording of the CR, the licensee's regulatory compliance personnel were contacted.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Fall 2014 Groundwater Sampling Results

a. Inspection Scope

The inspectors reviewed the results of groundwater samples taken from wells in the plant owner-controlled area. The sampling of wells was completed as part of the licensees voluntary groundwater monitoring initiative. A sample taken during the licensee's autumn 2014 routine periodic monitoring for a well located outside the northwest corner of the turbine building and designated MW-37S contained approximately 3,230 picocuries per liter (pCi/L) of tritium. Sample results above the 2,000 pCi/L groundwater monitoring program threshold require making courtesy notifications to state and local government officials and the NRC resident inspectors.

These courtesy notifications were performed by the licensee on January 7, 2015 in accordance with their programmatic requirements after the laboratory results for the fall 2014 samples had been received and reviewed by station personnel. The formal reporting limit threshold is 30,000 pCi/L, as documented in the licensees ODCM.

The licensee continues to investigate and monitor wells in accordance with their groundwater monitoring program. The inspectors reviewed the licensees compliance with their stated offsite agency reporting requirements.

These routine reviews for samples to detect tritium in groundwater did not constitute any additional inspection samples. Instead, they were considered as part of the inspectors daily plant status monitoring activities.

b. Findings

No findings were identified.

.2 Winter 2015 Groundwater Sampling Results

a. Inspection Scope

The inspectors reviewed the results of a series of expanded groundwater samples taken from wells in the plant owner-controlled area. The sampling of wells was completed as part of the licensees voluntary groundwater monitoring initiative and in response to the results obtained earlier, as discussed in Section 4OA5.1 above. Several of the monitoring well locations sampled as part of the licensee's ongoing investigations indicated tritium levels above the 2,000 pCi/L groundwater monitoring program threshold requiring courtesy notifications to state and local government officials and the NRC resident inspectors. The highest tritium concentration, approximately 10,527 pCi/L from a sample obtained on February 10, 2015, was located in a monitoring well, designated MW-22S, on the west side of the plant near the borated water storage tank.

The licensee continues to investigate and monitor wells in accordance with their groundwater monitoring program. The inspectors reviewed the licensees compliance with their stated offsite agency reporting requirements.

These routine reviews for samples to detect tritium in groundwater did not constitute any additional inspection samples. Instead, they were considered as part of the inspectors daily plant status monitoring activities.

b. Findings

No findings were identified.

.3 Operation of an Independent Spent Fuel Storage Installation

a. Inspection Scope

The inspectors conducted document reviews, held discussions with licensee staff, and performed a walkdown of the Independent Spent Fuel Storage Installation (ISFSI) to assess compliance with the ISFSI Certificate of Compliance, TS, and the USAR.

The inspectors performed a walkdown and evaluated the condition of the spent fuel horizontal storage modules (HSMs) and ISFSI pad. The inspectors reviewed the licensees last structural inspection of the ISFSI pad and HSMs. The inspectors observed the licensee perform routine surveillance activities, including inspections of the vent screens and taking thermocouple readings. The inspectors reviewed the licensees associated completed procedures for routine surveillance.

Plant procedures were reviewed to determine whether the licensee had adequate controls in place to monitor the radiation dose resulting from the operation of the ISFSI.

The inspectors reviewed several routine radiation surveys performed by the licensee around the pad. The inspectors determined if the site had an unloading procedure and reviewed the control of transient combustible material procedure and contingency procedure.

Condition reports, and the associated follow up actions, were reviewed to assess the adequacy and timeliness of the licensees corrective actions. The inspectors reviewed quality assurance audits associated with the ISFSI. A number of 10 CFR 72.48 screenings were reviewed for compliance with the 72.212 report, Certificate of Compliance, TS, and the USAR.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 9, 2015, the inspectors presented the inspection results to the Site Vice President, Mr. R. Lieb, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received and reviewed during the inspection was returned to the licensee.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The inspection results for the routine periodic radiation protection inspection items documented in Section 2 of this report with the Site Vice President, Mr. R. Lieb, and other members of the licensee staff on March 16, 2015; and

• The results of the ISFSI operational inspection with the Director of Site Operations, Mr. T. Summers, and other members of the licensee staff on February 19, 2015.

The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received and reviewed during the inspection was returned to the licensee.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as an NCV.

.1 Failure to Properly Perform Required Fire Watch

Plant TS 5.4.1(d), requires, in part, the licensee to establish, implement, and maintain applicable written procedures covering fire protection program implementation. The fire protection program was implemented, in part, by Davis-Besse Procedure DB-FP-00009, Fire Protection Impairment and Fire Watch, Revision 20. Procedure DB-FP-00009, Step 6.3.4, states: Roving Fire Watches shall observe the assigned patrol area(s)/room(s)/panel(s) which is (are) to be observed as related to the impairment, for example, room associated with impaired door, damper, penetration seal, detector, etc. Contrary to this requirement, for several hours on February 16, 2015, the licensee failed to observe the interior of Room 425, the Radiation Protection (RP)

Instrument Calibration Room, when an applicable fire impairment had existed.

Late in the morning on February 16th, plant maintenance technicians began a planned work activity to replace 27 smoke detectors in Fire Detection Zone 412A. To compensate for this planned loss of fire detection capability, the licensee's fire protection program required an hourly fire watch patrol to be performed for each of the 17 rooms covered by Fire Detection Zone 412A. This hourly fire watch patrol was instituted by the on-watch Operations crew at 12:00 p.m., and assigned to a member of the site's Security Department, as was the standard station practice. Because the door to Room 425 was locked, however, the individual performing the hourly fire watch patrol did not enter Room 425, as required, and only checked the door to the room. This practice was repeated again at 2:00 p.m., and continued hourly by each individual who performed the fire watch patrol until 8:00 p.m. At that time, the individual performing the hourly fire watch patrol raised a question about the locked door to Room 425 to the Operations supervisors who were on watch, and it was confirmed that the room needed to be entered to adequately perform the fire watch patrol. A key for Room 425 was obtained from RP, and the fire watch patrol performed correctly from that point on.

The inspectors reviewed this violation using the guidance contained in Appendix B, Issue Screening, of IMC 0612, Power Reactor Inspection Reports. The inspectors determined that the licensees failure to properly implement plant procedures for performing compensatory fire watches was a performance deficiency that was reasonably within the licensees ability to foresee and correct and should have been prevented. This violation was associated with the Initiating Events cornerstone of reactor safety and was of more than minor significance because it was associated with the Initiating Events cornerstone attribute of Protection Against External Factors (Fire)and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations.

Specifically, required fire watch patrols established as compensatory measures should have been properly performed for the duration of the impairment so that the sites ability to promptly detect and suppress a fire would be maintained.

The inspectors evaluated the violation using IMC 0609, Attachment 4, Phase 1-Initial Screening and Characterization of Findings. Because it involved fire protection, the inspectors transitioned to IMC 0609, Appendix F, Fire Protection Significant Determination Process (SDP). The violation was characterized according to IMC 0609, SDP, Appendix F, Attachment 1, "Fire Protection SDP Phase 1 Worksheet," dated September 20, 2013. The violation screened as of very low safety significance (Green),per Attachment 1, Question 1.3.1.A, because it did not affect the ability of the reactor to reach and maintain safe shutdown.

The licensee had entered this issue into their CAP as CRs 2015-02119, 2015-02126, 2015-04246, and 2015-04248. A limited apparent cause evaluation was performed and corrective actions included, but were not limited to:

• Creation of a formal pre-job brief check list for fire watch patrols to be used and maintained at the Work Support Center desk for ready reference, and maps for multiple room fire watch patrols; and

• Communication of lessons learned, identification and discussion of knowledge gaps and reinforcement of the site's human performance tools with respect to fire watch patrol expectations.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Lieb, Site Vice President

K. Byrd, Director, Site Engineering

G. Cramer, Manager, Site Protection

J. Cuff, Manager, Training

J. Cunnings, Manager, Site Maintenance

A. Dawson, Manager, Chemistry

D. Dibert, Reactor Engineer, Plant Engineering

D. Hartnett, Superintendent, Operations Training

J. Hook, Manager, Design Engineering

M. Hoffman, Access Authorization Supervisor

D. Imlay, Director, Site Performance Improvement

G. Kendrick, Manager, Site Outage Management

B. Kremer, Manager, Site Operations

G. Laird, Manager, Technical Services Engineering

B. Matty, Manager, Plant Engineering

P. McCloskey, Manager, Site Regulatory Compliance

D. Noble, Manager, Radiation Protection

W. OMalley, Manager, Nuclear Oversight

R. Oesterle, Superintendent, Nuclear Operations

R. Patrick, Manager, Site Work Management

M. Roelant, Manager, Site Projects

D. Saltz, Director, Site Maintenance

J. Sturdavant, Regulatory Compliance

T. Summers, Director, Site Operations

L. Thomas, Manager, Nuclear Supply Chain

M. Travis, Superintendent, Radiation Protection

J. Vetter, Manager, Emergency Response

G. Wolf, Supervisor, Regulatory Compliance

K. Zellers, Supervisor, Reactor Engineering

LIST OF ITEMS

Opened

None

Closed

05000346/2014005-01 URI Additional Review of Medical Records Needed (Section 1R11.3)

Discussed

None