IR 05000346/2011009

IR 05000346-11-009(DRS), on 01/14/2011, 01/27/2011, Davis-Besse Nuclear Power Station; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

ML110540503
Person / Time
Site:	Davis Besse
Issue date:	02/22/2011
From:	Daley R C Engineering Branch 3
To:	Allen B FirstEnergy Nuclear Operating Co
References
IR-11-009
Download: ML110540503 (13)

Text

February 22, 2011

Mr. Barry Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2, Mail Stop A-DB-3080 Oak Harbor, OH 43449-9760

SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION, EVALUATIONS OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000346/2011009(DRS)

Dear Mr. Allen:

On January 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) partially completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications inspection at your Davis-Besse Nuclear Power Station. The inspection hours for this inspection were reduced, such that the remaining inspection hours would be completed during our inspection of your reactor vessel head replacement activities. The enclosed inspection report documents the inspection results, which were discussed on January 27, 2011, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure 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/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.: 50-346 License No.: NPF-3

Enclosure:

Inspection Report 05000346/2011009(DRS)

w/Attachment:

Supplemental Information cc w/encl: Distribution via ListServ Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No.: 50-346 License No.: NPF-3 Report No: 05000346/2011009(DRS) Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: January 10 - 14, 2011, and January 24 - 27, 2011 Inspectors: George M. Hausman, Senior Reactor Inspector (Lead) Ronald A. Langstaff, Senior Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure

SUMMARY OF FINDINGS

IR 05000346/2011009(DRS); 01/14/2011 - 01/27/2011; Davis-Besse Nuclear Power Station; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications. This report covers a two-week announced baseline inspection of IP 71111.17, "Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications." The inspection was conducted by Region III based engineering inspectors. The baseline inspection resources were reduced, such that a third of the inspection hours would be completed during performance of IP 71007, "Reactor Vessel Head Replacement Inspection." As a result of this inspection's reduced resources, the baseline inspection program requirements were only partially completed. The remaining required inspection samples and hours shall be completed by the inspectors performing the IP 71007 inspection and will be charged to IP 71111.17 to complete this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified

and Self-Revealed Findings No findings of significance were identified.

B. Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

For this baseline inspection, the hours have been reduced to support the future performance of IP 71007,"Reactor Vessel Head Replacement Inspection." Specifically, the IP 71007 inspection procedure requires that other baseline inspection procedures, such as this inspection, be utilized to credit completion of the IP 71007 inspection. The licensee is currently scheduled to complete their reactor vessel head replacement activities sometime later this year. As a result of this inspection's reduced hours, the baseline inspection program requirements were only partially completed. The remaining required inspection samples (i.e., two evaluations) and inspection hours shall be completed by the inspectors performing the IP 71007 inspection and will be charged to IP 71111.17 to complete this inspection.

.1 Evaluation of Changes, Tests, or Experiments

a. Inspection Scope

From January 10, 2011, through January 27, 2011, the inspectors reviewed four safety evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 14 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests or experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change. The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."

3 Enclosure This inspection constituted four samples of evaluations and 14 samples of changes as defined in IP 71111.17-04.

b. Findings

No findings of significance were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

From January 10, 2011, through January 27, 2011, the inspectors reviewed seven permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the auxiliary feedwater modification associated with ECP 08-0571 and the Rosemount transmitters modification associated with ECP 05-0240-00. The modifications were selected based upon risk-significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated;

• the changes were in accordance with the specified design requirements;

• the procedures and training plans affected by the modification have been adequately updated;

• the test documentation as required by the applicable test programs has been updated; and

• post-modification testing adequately verified system operability and/or functionality. The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report. This inspection constituted seven permanent plant modification samples as defined in IP 71111.17-04.

b. Findings

No findings of significance were identified.

4 Enclosure

4OA2 Identification and Resolution of Problems

.1 Routine Review of Condition Reports

a. Inspection Scope

From January 10, 2011, through January 27, 2011, the inspectors reviewed seven corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent pant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On January 27, 2011, the inspectors presented the inspection results to Mr. B. Allen, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Allen, Site Vice President - Davis-Besse Nuclear

C. Atkinson, Advance Nuclear Engineer - Design Engineering (Mechanical/Structural)

A. Bless, Electrical Engineer - Design Engineering

K. Byrd, Director - Performance Improvement

J. Cuff, Manager - Maintenance

V. Kaminskas, Director - Site Engineering

P. McCloskey, Manager - Site Regulatory Compliance

M. Murtha, Staff Engineer - Design Engineering (Electrical/I&C)

G. Olson, Project Manager - Site Projects

S. Osting, Supervisor - Design Engineering (Mechanical/Civil)

C. Price, Director - Special Projects

J. Tabbert, Engineer - Procurement Engineering

V. Wadsworth, Nuclear Specialist - Regulatory Compliance

G. Wolf, Supervisor - Regulatory Compliance

K. Zellers, Engineering Analysis Supervisor - Design Engineering

Nuclear Regulatory Commission

J. Rutkowski, Senior Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened, Closed, and Discussed

None

Attachment

LIST OF DOCUMENTS REVIEWED

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

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. 10

CFR 50.59 EVALUATIONS Number Description or TitleDate or Revision

07-00509 Dose Increase Caused by ECCS Leakage Into The Auxiliary Building and BWST, Revision 00 April 12, 2007 07-02986

DB-OP-02000 - RPS, SFAS, SFRCS Trip or SG Tube Rupture, Revision 20 and Supporting Documents, Revision 00 June 28, 20007 08-00442 36 inch Main Steam Line Break in Room 601 and 602, Revision 00 May 16, 2008 08-03618 Allowable SW Flow Diversion During Cold Weather, Revision 00 November 13, 2008

CFR 50.59 SCREENINGS Number Description or TitleDate or Revision

07-03797 RPS Rx Power Related Field Trip Setpoints, Revision 00 December 19, 200708-01800 Replace RCP Seal Injection Flow Transmitters, Revision 00 August 29, 2008 09-01396 Reroute AFW Common Suction Piping, Revision 05 April 19, 2010 09-04856 TM - Add Boric Acid to

CFT-2 November 19, 200910-00302 TM - Remove Valve Internals from SW110, Revision 00 February 1, 2010 10-02545 Revise AFW Pump Suction Pressure Switch Setpoint and Tolerance, Revision 00 June 7, 2010 10-04024 TRM Section 8.1.1 Changes, Revision 00 September 27, 201010-04028 TRM Section 8.3.7 Changes, Revision 00 September 27, 201010-04088 TRM Section 8.4.1 Changes, Revision 00 September 27, 201010-04088 TRM Section 8.4.4 Changes, Revision 00 September 27, 201010-04103 TRM Section 8.7.6 and TRM 8.7.6 Bases Changes, Revision 00 September 27, 2010

CALCULATIONS Number Description or Title Date or Revision

C-ICE-050.03-003 AFW Low Pressure Suction Setpoint, Revision 1 June 7, 2010 C-ICE-058.01-008 RPS Rx Power Related Field Trip Setpoints, Revision 4 December 20, 2007MPR-3332 Davis-Besse AFW Piping System Modification Analysis, Revision 0 July 2009

MPR-3373 Evaluation of Davis-Besse Modification

ECP 08-0571, AFW System Modification, Revision 2 December 2010

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or TitleDate or Revision

11-88717

NRC 2011, 50.59 Inspection January 25, 2011 11-88784 2011 50.59 Inspection,

ECP 08-0571-006 Confusing Statement January 25, 2011 11-88850 2011 MOD/50.59 Inspection; Calculation and TRM Discrepancy on Calibration Period January 27, 2011

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or TitleDate or Revision

CR08-37919 Contractor Signed 50.59 After Qualification Lapsed April 8, 2008 CR08-42414 NRC MOD/50.59: 50.59 Review May Not Be Complete June 26, 2008

CR08-47595 10CFR50.59 Review May Not Be Complete October 9, 2008 CR08-48790 50.59 Reviews Performed After Qualifications Expired October 31, 2008 CR10-70203 Matrix Not Updated For 50.59 Review Qualification January 19, 2010

CR10-76194 MRB Comment Review Condition Identified for Past Operability May 7, 2010 CR10-77485 Individual Signed 50.59 After Qualification Lapsed May 28, 2010

MODIFICATIONS Number Description or TitleDate or Revision

ECP 05-0240-00 Replace RCP Seal Injection Flow Transmitters, Revision 00 September 5, 2008ECP 08-0571-006 Replace Low AFW Suction Pressure Switches and Resolve Margin Issue Identified In

MPR-3332, Revision 0 January 21, 2010

PART/COMPONENT EQUIVALENT

REPLACEMENT PACKAGE (PERP) Number Description or TitleDate or Revision

00129 Replace Motor

DB-MC58, Revision 01 February 6, 2009

PROCEDURES Number Description or TitleDate or Revision

DB-OP-02000 RPS, SFAS, SFRCS Trip, or SG Tube Rupture, Procedure Approval Form dated June 29, 2007

DB-OP-06015 BWST Operating Procedure 13 & 14 NOP-CC-2003

Engineering Changes 15

Attachment REFERENCES Number Description or TitleDate or Revision

CFR 50.36 Technical Specifications

A21672 Commitment Closeout / Extension

DBE-10-00077 (TSTF - 493) July 6, 2010 M-327AQ-00036 Vendor Manual:

Rosemount Inc. Instruction Manual for Model 1152 Alphaline Pressure Transmitter for Nuclear Service (Revision BA, April 1, 2007)

Notification

600625175 Adopt TSTF - 493, Revision 4, Option B July 6, 2010 TRM 8.7.6 TRM AFW System, Technical Verification Requirements 7

REGULATORY APPLICABILITY DETERMNATIONS (RADs) Number Description or TitleDate or Revision

08-01484 RPS Power Related Setpoint Changes for Measurement Uncertainty Recapture Power Up Rate, Including Addition To TRM, Revision 00 June 3, 2008 08-04589 Replacement Motor for

DB-MC58, Revision 01 February 6, 2009 09-04014 BWST Operating Procedure, Revision 00 September 25, 2009

Attachment

LIST OF ACRONYMS

USED [[]]

ADAMS Agencywide Documents Access and Management System

AFW Auxiliary Feedwater System

BWST Borated Water Storage Tank

CFR Code of Federal Regulations

CFT Core Flood Tank

DRP Division of Reactor Project

DRS Division of Reactor Safety

ECCS Emergency Core Cooling System

ECP Engineering Change Package FENOC FirstEnergy Nuclear Operating Company

I&C Instrumentation and Control

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

MOD Modification

MPR [[]]

MPR Associates

MRB Management Review Board

NEI Nuclear Energy Institute

NPF Nuclear Power Facility

NRC U.S. Nuclear Regulatory Commission

NUREG [[]]

NRC Technical Report Designation

OA Other Activities

PARS Public Available Records System

PERP Part/Component Equivalent Replacement Package

RCP Reactor Coolant Pump

RPS Reactor Protection System Rx Reactor

SDP Significance Determination Process

SFAS Safety Features Actuation System

SFRCS Steam and Feed Rupture Control System

SG Steam Generator

SW Service Water

TM Temporary Modification

TRM Technical Requirements Manual

TSTF Technical Specification Task Force

B. Allen -2- 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/

Robert

C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.: 50-346 License No.:

NPF -3 Enclosure: Inspection Report 05000346/2011009(DRS) w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ DISTRIBUTION

RidsNrrDorlLpl3-2 Resource Daniel Merzke RidsNrrPMDavisBesse Resource

RidsNrrDirsIrib Resource Cynthia Pederson Steven Orth Jared Heck Allan Barker

Carole Ariano

Linda Linn

DRPIII [[]]

DRSIII Patricia Buckley

Tammy Tomczak ROPreports Resource

DOCUME NT NAME:G:\DRSIII\DRS\Work in Progress\-DAV-BESSE 2011-009

MOD 50 59

GMH.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE [[]]

RIII E

RIII [[]]

NAME GHausman:ls RDaley

DATE 02/18/11 02/22/11

OFFICI AL

RECORD [[]]

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