IR 05000346/2022011

Triennial Fire Protection Inspection Report 05000346/2022011

ML23004A217
Person / Time
Site:	Davis Besse
Issue date:	01/05/2023
From:	Richard Skokowski NRC/RGN-III/DORS/EB2
To:	Tony Brown Energy Harbor Nuclear Corp
References
IR 2022011
Download: ML23004A217 (1)

Text

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000346/2022011

Dear Terry Brown:

On November 22, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Richard A. Skokowski, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000346 License No. NPF-3

Enclosure:

As stated

Inspection Report

Docket Number: 05000346

License Number: NPF-3

Report Number: 05000346/2022011

Licensee: Energy Harbor Nuclear Corp.

Facility: Davis-Besse Nuclear Power Station

Location: Oak Harbor, OH

Inspection Dates: October 03, 2022 to November 22, 2022

Inspectors: K. Barclay, Senior Reactor Inspector M. Domke, Reactor Inspector B. Jose, Senior Reactor Inspector

Approved By: Richard A. Skokowski, Chief Engineering Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Davis-Besse Nuclear Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000346/2022011-01 Multiple NFPA 805 71111.21N.05 Open Non-Power Operation Transition Issues URI 05000346/2021050-07 Potential High Emergency 71111.21N.05 Closed Diesel Generator Field Currents When Adding Manual Loads

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

===71111.21N.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Fire Zone 237, AFW Pump 1-1 Room, Fire Compartment E-01, Fire Detectors, Dampers, and Suppression Systems

(2) Auxiliary Feedwater (AFW) Pump 1-1, for Post-Fire Safe Shutdown Review

(3) Fire Pumps and Associated Hydraulic Calculation from SSCs Credited for Fire Prevention, Detection, Suppression Perspective

Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees Fire Protection Program (FPP) contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Combustible Control Program

(2) National Fire Protection Association (NFPA) 805 Monitoring Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c.

Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire Safe Shutdown (SSD) operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) FPPCE 22-001, Replacement Valves for Obsolete Fire Protection United Brass Model 45S

(2) FPPCE 22-003, Replacement of TPCW Pump Motors MP7-1 and MP7-3

INSPECTION RESULTS

Unresolved Item Multiple NFPA 805 Non-Power Operation Transition Issues 71111.21 (Open) URI 05000346/2022011-01 N.05

Description:

During the Fire Protection Team Inspection (FPTI), the inspectors identified multiple issues associated with the licensees implementation of their National Fire Protection Association (NFPA) 805 Non-Power Operation (NPO) program.

A review of the licensees NFPA 805 license amendment request (ADAMS Accession Number ML1530A314) and associated supplement (ADAMS Accession Number ML16351A330), the inspectors found the licensee's statement that they would revise plant procedures to incorporate the insights, strategies, and analysis recommended or documented in their NPO Modes Transition Report and add the necessary procedure steps to ensure that key safety functions (KSFs) are achieved and maintained. The inspectors found that the licensee attempted to implement software controls instead of robust procedures and did not incorporate the insights, strategies, and analysis from their NPO Modes Transition Report into their plant procedures. Additionally, the inspectors found that the licensee did not add the necessary procedure steps to ensure that KSFs were achieved and maintained.

The licensees fire risk software was intended to prohibit hot work permits in fire compartments that contained pinch points during outage high risk evolutions (HREs). A pinch point is a fire area or compartment where a single fire could cause a loss of all success paths for a specific shutdown KSF. The software was found to be missing at least 10 fire compartments that should have been flagged as containing a pinch point. Some of the missing fire compartments contained multiple KSF pinch points including one compartment that contained 3 KSFs (Decay Heat Removal, Inventory Control, and Support/Electrical). These missing fire compartments were unprotected during the 2022 refueling outage HRE. An outage review found that only one fire compartment potentially had hot work conducted during the HRE time frame.

The inspectors found that the licensee did not have procedures for implementing all the necessary NFPA 805 NPO features within their fire risk software but relied on informal notes. The licensees informal notes did not specify that all pinch points needed to be protected during HREs. During the 2022 refueling outage HRE, the licensee only selected Inventory Control for hot work permit prevention; however, the decay heat removal, reactivity and support/electrical KSFs should have also been selected. This software implementation error led to four additional compartments being unprotected.

The licensees Fire Hazards Analysis Report, which is also their fire protection program design basis document, contained a Non-Power Operations (NPO) Modes Compliance Summery for each fire area (compartment). The NPO Modes Compliance Summary template stated, in part, that each compartment summary will contain any associated pinch points in the fire compartment and any features and/or controls that provide reasonable assurance that the fuel will be maintained in a safe and stable configuration The inspectors found that the NPO Modes Compliance Summary was inaccurate for all fire compartments that contained a pinch point at Davis-Besse. Specifically, all 46 pinch-point fire compartments contained the following summary, The potential effects of a fire occurring during NPO modes in this fire compartment were reviewed. This review was conducted using the methodology as described in Calculation ARS-DB-11-003. This area does not have any associated pinch points. The lack of failures resulting in a pinch point provides reasonable assurance the fuel will be maintained in a safe and stable configuration. Therefore, the NFPA 805 performance goal for NPO is satisfied.

Davis-Besse Facility Operating License Condition 2.C.(4), Fire Protection, stated, in part, that the licensee shall implement the items listed in Attachment S, Table S-2, Implementation Items, to the FENOC letter dated November 20, 2018, within 2 years following issuance of the license amendment.

S, Table S-2, Implementation Items, found in FENOC letter dated November 20, 2018 (ADAMS Accession Number ML18324A677), contained item DB-1908, Revise Procedures and Conduct Training to Implement NPO Requirements for NFPA 805, and item DB-2049, Develop the DBNPS NFPA 805 Design Basis Document.

The inspectors were concerned that the licensees overall implementation of their NFPA 805 NPO program was not consistent with their license amendment request and associated supplements.

Planned Closure Actions: The inspectors need to consult with the Office of Nuclear Reactor Regulation (NRR) to determine if these issues represent a failure to complete an NFPA 805 transition license condition or other traditional enforcement violation. Additionally, the inspectors need to determine if the differences in implementation would have changed the Agencys conclusion on approving the NFPA 805 license amendment request.

Licensee Actions: There are no immediate licensee actions needed for this unresolved issue. As the inspectors work with NRR, additional questions may develop that will be communicated to the licensee.

Corrective Action References:

CR-2022-07442: 2022 FP Inspection - FHAR Contains Incorrect NPO Compliance Summary CR-2022-07489: 2022 FP Inspection - Fire Protection Expert Software Issue CR-2022-07930: 2022 FP Inspection - Implementation of NPO Does Not Account for All Key Safety Functions URI Potential High Emergency Diesel Generator Field Currents 71111.21N.

When Adding Manual Loads 05 URI 05000346/2021050-07

Description:

(Closed) URI 05000346/2021050-07 Potential High Emergency Diesel Generator Field Currents When Adding Manual Loads

During the special inspection related to multiple Emergency Diesel Generator (EDG) failures that took place from July 2019 to June 2021, as well as a reactor trip with multiple complicating equipment issues, the inspectors identified an Unresolved Item (URI)05000346/2021050-07 Potential High Emergency Diesel Generator Field Currents When Adding Manual Loads.

On June 24, 2021, while testing the Division 1 EDG, the licensee observed that the EDG output voltage was almost 10 percent above the nominal value. The licensee found that the internal circuit of the RA-70 microprocessor-based reference unit had failed. The RA-70 provides a resistance reference value to the automatic voltage regulator, and it had failed to its high limit setpoint. The licensee repaired the EDG, returned it to service, and performed several assessments to determine if the high voltage condition would have prevented the EDG from performing its safety function and assessed the effects of the high voltage condition on the operation of loads connected to the EDG.

The Team independently reviewed the evaluation and found that the conclusions associated with the downstream EDG loads were reasonable. However, the Team also found that the evaluation did not completely address the effects of adding manual loads to the EDG after automatic load sequencing, and the potential increase in generator exciter current levels.

The Teams concern was that the increased generator exciter currents could cause an exciter component failure and prevent proper operation of the EDG. The licensee subsequently had their contractor (MPR Associates) revise the evaluation to address the concern associated with high generator exciter currents. However, the evaluation was not completed before the conclusion of the special inspection. As a result, the Team was required to document this issue as an Unresolved Item.

The licensee provided the updated high voltage assessment; MPR Associates Report 0200-0213-RPT-001, Revision 3 to the Team on October 11, 2021. The NRC Region 3 inspectors reviewed the report and solicited a peer review by NRC Head Quarters electrical engineering branch. After reviewing the MPR report in detail, both NRC Head Quarters team and the Region 3 team agreed with the MPR report conclusions that potential increase in exciter current while adding manual loads to the EDG after automatic load sequencing, will not damage the exciter components and prevent the EDG from performing its safety function. The NRC inspectors did not identify any violations of more than minor significance. Therefore, this URI is closed.

Corrective Action Reference(s):

CR 2021-04913, EDG Overvoltage During Monthly Run

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On November 22, 2022, the inspectors presented the triennial fire protection inspection results to Terry Brown, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Calculations ARS-DB-11-003 Davis-Besse Non-Power Operational (NPO) Modes 6

Transition Report

71111.21N.05 Calculations ARS-DB-13-071 Davis-Besse General Variances from Deterministic 2

Requirements (VFDR) Report

71111.21N.05 Calculations ARS-DB-13-078 Recovery Actions for Transition Report Attachment G 4

71111.21N.05 Calculations ARS-DB-15-085 Fire Protection Safe Shutdown NFPA 805 Recovery Action 0

Feasibility Study

71111.21N.05 Calculations ARS-DB-17-112 Fire Risk Evaluation of No. 2 Auxiliary Feedwater Pump 0

Room (F-01)

71111.21N.05 Calculations ARS-DB-19-114 Davis-Besse Fire Protection Safe Shutdown Recovery 0

Action Report

71111.21N.05 Calculations C-EE-002.01-011 Low Voltage Coordination Calculation 7

71111.21N.05 Calculations C-FP-013.10-018 Davis-Besse Power Station - NFPA 805 Safe Shutdown, 1 & A02

Non-Power Operation, and Fire PRA Cable Selection

Calculation

71111.21N.05 Calculations C-FP-013.10-020 Davis-Besse Nuclear Power Station - NUREG / CR-6850 1

Task 9 - Detailed Circuit Failure Analysis

71111.21N.05 Calculations C-FP-013.10-022 Detailed Fire Modeling - Fire Compartment F-01 1

71111.21N.05 Calculations C-FP-013.10-045 Fire Compartment E-01, No. 1 Auxiliary Feedwater Pump 2

Room

71111.21N.05 Calculations C-NSA-064.02-Davis-Besse Appendix R Overheating Summary Report 1

2

71111.21N.05 Calculations C-NSA-064.02-Davis-Besse Appendix R Overcooling Summary Report 0 & A01

033

71111.21N.05 Calculations FEM-021-01 Turbine Building Elevation 603 Sprinkler System 6

71111.21N.05 Calculations FEM-021-02 Turbine Building Elevation 603 Sprinkler System 6

71111.21N.05 Calculations PRA-DB1-17-021 PRA Input to Fire Risk Evaluation for Compartment E-01 3

71111.21N.05 Corrective Action 2005-05472 Fire Protection 5 Year Flow Test Results do not Meet 12/30/2005

Documents Acceptance Criteria

71111.21N.05 Corrective Action 2008-40704 Fire Protection 5 Year Flow Test Results do not Meet 06/21/2008

Documents Acceptable Range for C Value

71111.21N.05 Corrective Action 2014-12504 Fire Protection: 5-Year Flow Test Results do not Meet 08/01/2014

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Acceptable Range for C-Value

71111.21N.05 Corrective Action 2020-03744 MS5889A Steam Admission to Auxiliary Feed Pump Turbine 04/27/2020

Documents #1 Valve Dust Boot Separated

71111.21N.05 Corrective Action 2020-04512 Auxiliary Feed Water Pump 1, PSL106D Failed to Close 05/24/2020

Documents MS106, MS106A

71111.21N.05 Corrective Action 2021-00610 Service Water (SW) 1382, Supply to Auxiliary Feed Water 01/31/2021

Documents Pump (AFP) #1, Stroke Time Outside of Expected Range

71111.21N.05 Corrective Action 2022-02204 Indications on Welding Around Auxiliary Feed Water Pump 03/15/2022

Documents Trip (AFPT) #2 Valve Seat

71111.21N.05 Corrective Action 2022-02209 Indications on Welding Around AFPT #1 Valve Seat 03/15/2022

Documents

71111.21N.05 Corrective Action 2022-02236 AFPT 1 Governor DB-ICS38B: Crank Pivot Pin Boss 03/15/2022

Documents Extends Out of Fulcrum Support Preventing Jam Nut

Contact

71111.21N.05 Corrective Action 2022-05577 Missed Surveillance FP4023-018 08/15/2022

Documents

71111.21N.05 Corrective Action 2022-05675 Fire Protection 5-year Flow Test Results do not Meet 07/21/2022

Documents Acceptable Range for C Value

71111.21N.05 Corrective Action 2022-05857 2022 Fire Protection Team Inspection Self-Assessment - 08/26/2022

Documents Performance Monitoring Program

71111.21N.05 Corrective Action 2022-07575 North Underground Fire Protection Loop Pipe Rupture 10/09/2022

Documents

71111.21N.05 Corrective Action 2022-12602 DB-FP-04023 Attachment 25 - Barriers Need Moved to 10/12/2022

Documents Attachment 45

71111.21N.05 Corrective Action 2022-07442 2022 Fire Protection Inspection (FPI) - Fire Hazards 10/04/2022

Documents Analysis Report (FHAR) Contains Incorrect Non Power

Resulting from Operations (NPO) Compliance Summary

Inspection

71111.21N.05 Corrective Action 2022-07489 2022 NRC FPI - Fire Protection Expert Software Issue 10/06/2022

Documents

Resulting from

Inspection

71111.21N.05 Corrective Action 2022-07499 2022 NRC Fire Protection Inspection - Fire Protection Piping 10/06/2022

Documents Corrosion and Coating Degradation

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

71111.21N.05 Corrective Action 2022-07920 2022 NRC Fire Protection Inspection: Inaccurate 10/19/2022

Documents Information Provided in Response to NRC Question

Resulting from

Inspection

71111.21N.05 Corrective Action 2022-07930 2022 NRC FPI - Implementation of NPO does not Account 10/19/2022

Documents for All Key Safety Functions

Resulting from

Inspection

71111.21N.05 Drawings E-44B Sheet 14B Elementary Wiring Diagram Feed Water System Auxiliary 11

Feed Water Pump (AFP) Discharge to Steam Generator

71111.21N.05 Drawings M-0006D Auxiliary Feedwater System 60

71111.21N.05 Drawings M-0007B Piping & Instrument Diagram Steam Generator Secondary 63

System

71111.21N.05 Drawings M-309AQ-00004-Installation Drawing Modulating Valve Models 87J-001 & 0

0001 87J-002

71111.21N.05 Engineering 0200-0213-RPT-Evaluation of High Emergency Diesel Generator 1-1 Voltage 3

Evaluations 001 at Davis-Besse

71111.21N.05 Engineering ARS-DB-13-071 Davis-Besse General VFDR Report 2

Evaluations

71111.21N.05 Engineering ARS-DB-17-111 Fire Risk Evaluation of No. 1 Auxiliary Feedwater Pump 0

Evaluations Room (E-01)

71111.21N.05 Engineering ARS-DB-17-112 Fire Risk Evaluation of No. 2 Auxiliary Feedwater Pump 0

Evaluations Room (F-01)

71111.21N.05 Miscellaneous Fire Hazard Analysis Report 03/31/2021

71111.21N.05 Miscellaneous Davis-Besse Nuclear Power Station NFPA 805 Nuclear 3

Safety Capability Assessment Report

71111.21N.05 Miscellaneous Davis-Besse 1R22-1: Contingency Plan for Reactor Coolant 03/07/2022

System (RCS) Drain Below Flange Level and Operation

Below 80 Inches Above the RCS Hot Leg Centerline

71111.21N.05 Miscellaneous Davis-Besse 1R21-1: Contingency Plan for RCS Drain 02/11/2020

Below Flange Level and Operation Below 80 Inches Above

the RCS Hot Leg Centerline

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Miscellaneous ARS-DB-13-071 Davis-Besse General VFDR Report 2

71111.21N.05 Miscellaneous ATL-2021-0118-DB-1908: NPO Implementation Plan 02/25/2021

ATA-23

71111.21N.05 Miscellaneous BOP-VT-16-124 Visual Test (VT)-1 of Internal Surfaces: P14-1 Lube Oil 04/25/2016

Cooler

71111.21N.05 Miscellaneous LRAMR-M06 Aging Management Review of the Auxiliary Feedwater and 7

Condensate Storage Systems

71111.21N.05 Miscellaneous OPS-JPM-130 Non-Licensed Operator (NLO), Reactor Operator (RO), 11/11/2006

Senior Reactor Operator (SRO) - Actions for a Serious

Station Fire, Area F

71111.21N.05 Procedures DB-FP-00007 Control of Transient Combustibles 7

71111.21N.05 Procedures DB-FP-00018 Control of Ignition Sources 13

71111.21N.05 Procedures DB-FP-04035 5 Year Flow Test 07

71111.21N.05 Procedures DB-OP-02501 Serious Station Fire 24, 26 & 28

71111.21N.05 Procedures DB-OP-02519 Serious Control Room Fire 21 & 28

71111.21N.05 Procedures DB-OP-02529 Fire Procedure 12

71111.21N.05 Procedures DB-OP-02802 Serious Station Fire - Generic Train 2 Affected 00

71111.21N.05 Procedures DBBP-OPS-1113 Control of Time Sensitive Operator Actions 03

71111.21N.05 Procedures LRPD-05 Aging Management Program Evaluation Results -One Time 7

2.11 Inspection Program

71111.21N.05 Procedures LRPD-05 Aging Management Program Evaluation Results -Fire Water 2

2.8a Program

71111.21N.05 Procedures LRPD-05 Aging Management Program Evaluation Results -Fire 1

2.8b Protection Program

71111.21N.05 Procedures NG-DB-00117 Shutdown Defense in Depth Assessment 20

71111.21N.05 Procedures NG-DB-00302 DBNPS Fire Protection Program 12

71111.21N.05 Procedures NOBP-OM-2031 Outage Management Scheduling Process 12

71111.21N.05 Procedures NOBP-OP-1113 Control of Time Sensitive Operator Actions 2

71111.21N.05 Procedures NOP-OP-1005 Shutdown Defense in Depth 17

71111.21N.05 Procedures NOP-OP-1007 Risk Management 37

71111.21N.05 Self-Assessments ATL-2018-2226-2022 Fire Protection Self Assessment 08/10/2022

ATA-141

71111.21N.05 Work Orders 200759717 FP4035-001 04.000 5 Year Flow Test 07/21/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Work Orders 200761805 FP4023-03104.000 Attachment 8 Barrier Visual Inspection 10/03/2021

Month

71111.21N.05 Work Orders 200775095 FP4023-018 04.000 Attachment 25 Barrier Visual Inspection 06/28/2022

Month

71111.21N.05 Work Orders 200785600 FP4036-001 04.000 Fire Door 18 Month Inspection 07/23/2021

71111.21N.05 Work Orders 200800008 FP4049-001 05.000 P5-2 Diesel Fire Pump Test 07/21/2022

71111.21N.05 Work Orders 200809818 FP4047-002 05.000 P5-2 Diesel Fire Pump Test 01/19/2022

71111.21N.05 Work Orders 200810087 FP4048-003 04.5.1 P5-1 Electric Fire Pump Lube Oil 12/04/2021

Sample

71111.21N.05 Work Orders 200810300 FP4048-002 P5-1 Electric Fire Pump Local 05/22/2022

71111.21N.05 Work Orders 200810301 FP4050-001 04.000 P5-1 Electric Fire Pump Flow Test 09/24/2021

71111.21N.05 Work Orders 200816116 Functional Location DB-T81 Fire Water Storage Tank TK 1-04/10/2022

71111.21N.05 Work Orders 200828720 FP4048-004 04.001 P5-1 Electric Fire Pump 15 Minimum 07/14/2022

Run

71111.21N.05 Work Orders 200828735 FP4048-001 04.002 P5-1 Electric Fire Pump Remote 09/06/2022

71111.21N.05 Work Orders 200830264 FP4048-003 04.5.1 P5-1 Electric Fire Pump Lube Oil 08/13/2022

Sample

71111.21N.05 Work Orders 200831519 FP4047-002 05.000 P5-2 Diesel Fire Pump Test 08/31/2022

2