IR 05000346/2017011

NRC Supplemental Inspection Report 05000346/2017011

ML17107A387
Person / Time
Site:	Davis Besse
Issue date:	04/17/2017
From:	Jamnes Cameron NRC/RGN-III/DRP/RPB4
To:	Boles B FirstEnergy Nuclear Operating Co
References
IR 20170011
Download: ML17107A387 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ril 17, 2017

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATIONNRC SUPPLEMENTAL INSPECTION REPORT 05000346/2017011

Dear Mr. Boles:

On March 10, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed with you and members of your staff during an exit meeting on March 10, 2017. This exit meeting also served as a Regulatory Performance Meeting. The inspector documented the results of this inspection in the enclosed inspection report.

As required by the NRC Reactor Oversight Process (ROP) Action Matrix, this supplemental inspection was performed in accordance with Inspection Procedure (IP) 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. The purpose of the inspection was to examine the causes for, and actions taken related to, a White performance indicator (PI) in the Initiating Events Cornerstone at the Davis-Besse Nuclear Power Station. Specifically, the PI for Unplanned Scrams with Complications exceeded the Green-to-White threshold as reported in your first, third, and fourth quarter of 2016 PI submittals.

By letter dated April 26, 2016, the NRC informed you that because of the change in your PI status, the performance at Davis-Besse Nuclear Power Station would remain in the Regulatory Response Column of the ROP Action Matrix as of the first quarter 2016 (ADAMS Accession No. ML16118A435). The NRC previously determined the performance at Davis-Besse Nuclear Power Station was to be in the Regulatory Response Column of the ROP Action Matrix beginning in the fourth quarter of 2015 due to

one or more greater-than-Green Security Cornerstone inputs as described in the NRCs Annual Assessment letter dated March 2, 2016, (Accession No. ML16060A258). The NRC documented the inspection of the corrective actions for the Security Cornerstone inputs in report 05000346/2016408 dated August 10, 2016, (Accession No. ML16223A877). You notified the NRC of your readiness for this supplemental inspection by your letter of February 24, 2017, (Accession Number ML17060A237).

The NRC performed this supplemental inspection to determine if: (1) the root and contributing causes of the significant performance issues were understood; (2) the extent of condition and extent of cause for the significant performance issues were identified; (3) the corrective actions taken to address and preclude repetition of significant performance issues were prompt and effective; and (4) the corrective action plans direct prompt actions to effectively address and preclude repetition of significant performance issues. The NRC determined that the root cause evaluations (RCEs) completed for three individual unplanned reactor scrams with complications that resulted in the White PI, as well as the aggregate RCE completed in preparation for this inspection, were conducted to a level of detail commensurate with the significance of the problems and reached reasonable conclusions as to the root and contributing causes of the events. The NRC concluded that you identified reasonable and appropriate corrective actions for each root and contributing cause and that the corrective actions appeared to be prioritized commensurate with the safety significance of the issues. The NRC has determined that completed or planned corrective actions were sufficient to address the performance issue that led to the White PI. Therefore, the NRC concluded that your actions met the objectives of IP 95001. Based on the results of this inspection, no findings were identified.

Davis-Besse Nuclear Power Station remained above the Green-to-White PI threshold as of the end of the fourth quarter 2016. A separate NRC assessment letter will be issued once Davis-Besse Nuclear Power Station returns to the Green PI band for Unplanned Scrams with Complications.

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

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects

Docket No. 50-346 License No. NFP-3 Enclosure:

Inspection Report 05000346/2017011 cc: Distribution via LISTSERV

SUMMARY

Inspection Report (IR) 05000346/2017011; 03/06/2017 - 03/10/2017; Davis-Besse Nuclear Power

Station; Supplemental Inspection - Inspection Procedure (IP) 95001.

This supplemental inspection was conducted by a resident inspector. No findings were identified during this inspection. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

This supplemental inspection was performed in accordance with IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs, dated August 24, 2016, to assess the licensees evaluation associated with an Unplanned Scrams with Complications White performance indicator (PI). As a result of two unplanned scrams with complications between May 2015 and January 2016,

Davis-Besse Nuclear Power Station crossed the Green-White threshold during the first quarter of 2016.

In addition to the two unplanned scrams with complications that caused the Unplanned Scrams with Complications PI to cross the Green-to-White threshold, a third unplanned scram with complications occurred in September 2016. The scope of this inspection included the root cause evaluations (RCEs) performed for each of the unplanned scrams and associated complications along with an aggregate review performed to address the White Unplanned Scrams with Complications PI.

The inspector determined that the licensees RCEs completed for three individual unplanned reactor scrams with complications that resulted in the White PI, as well as the aggregate RCE completed in preparation for this inspection, were conducted to a level of detail commensurate with the significance of the problems and reached reasonable conclusions as to the root and contributing causes of the events. The inspector concluded that the licensee identified reasonable and appropriate corrective actions for each root and contributing cause and that the corrective actions appeared to be prioritized commensurate with the safety significance of the issues. The inspector determined that completed or planned corrective actions were sufficient to address the performance issue that led to the White PI. Therefore, the inspector concluded that licensee actions met the objectives of IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. Based on the results of this inspection, no findings were identified. Inspectors will review the licensees implementation of ongoing corrective actions and the effectiveness of those actions during a future inspection.

REPORT DETAILS

4OA4 Supplemental Inspection

.01 Inspection Scope

This inspection was conducted in accordance with IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs, to assess the licensees evaluation of a White Unplanned Scrams with Complications performance indicator (PI), which affected the Initiating Events Cornerstone in the Reactor Safety Strategic Performance Area. The inspection objectives were to:

• assure that the root causes and contributing causes of individual and collective significant performance issues were understood;

• independently assess and assure that the extent of condition and extent of cause of individual and collective performance issues were identified;

• assure that corrective actions taken to address and preclude repetition of significant performance issues are prompt and effective; and

• assure that corrective plans directed prompt actions to effectively address and preclude repetition of significant performance issues.

Two unplanned reactor scrams (May 9, 2015, and January 29, 2016,) with complications caused the Unplanned Scrams with Compilations PI to cross the Green-to-White threshold. A third unplanned scram with complications occurred on September 10, 2016. All three unplanned scrams involved complications with the unavailability of main feedwater due to either automatic or manual actuation of the steam feedwater rupture control system (SFRCS). The unplanned scrams, complications, and associated licensee root cause evaluation (RCE) results are summarized below:

• Reactor Scram Due to Steam Line Rupture in Turbine Building On May 9, 2015, a steam line ruptured in the turbine building in the vicinity of the No. 1 Moisture Separator Reheater as a result of flow accelerated corrosion. Control room operators performed a controlled rapid power reduction to approximately 30 percent reactor power and manually tripped the reactor in accordance with plant procedures.

The operators then manually initiated the SFRCS to isolate the steam leak and start auxiliary feedwater (AFW).

Three root causes were identified (Condition Report (CR) 2015-06691):

o Multiple incorrect orifice sizes were entered into the Checkworks flow-accelerated corrosion modeling software during initial database development and resulted in non-conservative prediction of wear rates in the affected piping; o Four locations with orifices in the reheat system were not systematically inspected based upon operating experience (OE); and o A root cause investigation of a previous steam leak in 2006 was circumvented by focusing on a perceived cause instead of the terminal event which resulted in overlooking flow-accelerated corrosion program implementation details crucial to establishing effective corrective actions. One contributing cause was identified that a root cause investigation of a steam leak in 2006 lacked an effectiveness review on the preventative action which could have identified that the scope of work did not validate all data input of the Checkworks flow-accelerated corrosion modeling software.

Corrective actions taken (all completed as the end of the inspection period) included but were not limited to:

o Replacement of the ruptured pipe elbow and similar components; o Review, validation, and correction of Checkworks flow-accelerated corrosion modeling software inputs; o Revision of the flow-accelerated corrosion management program to reflect current OE; o Development of lessons learned on performing cause evaluations on terminal events and effectiveness reviews of preventative actions; and o An extent of cause review on RCEs performed in the last 10 years Effectiveness reviews (all completed as of the end of the inspection period) included but were not limited to:

o Review Davis-Besse root cause analysis reports to ensure that the problem statement specifically addressed the terminal events, a preventative action was created for the root cause, and an effectiveness review was performed for the preventative action; and o Review for completion that an evaluation of component locations for inspection based on OE and validated a sample of component locations for inspection based on OE during the 2016 fleet assessment of flow-accelerated corrosion program implementation.

U. S. Nuclear Regulatory Commission Inspection Reports (IRs) 05000346/2015002 (ADAMS Accession No. ML15202A203) dated July 21, 2015, and 05000346/2015003 (ADAMS Accession No. ML15295A107), dated October 21, 2015, documented the inspection results of this event and closure of Licensee Event Report (LER) 2015-002-00, Improper Flow Accelerated Corrosion Model Results in 4-Inch Steam Line Failure and Manual Reactor Trip.

• Reactor Trip During Nuclear Instrumentation Calibration On January 29, 2016, a Reactor Protection System (RPS) Flux/Delta Flux/Flow trip occurred from 100 percent power due to a fuse failure in RPS Channel No. 4, while nuclear instrumentation (NI) calibrations were performed in RPS Channel No. 2. RPS Channel No. 1 was previously inoperable and in a tripped condition due to a failed reactor coolant system hot leg temperature indicator. The scram was complicated when an automatic SFRCS actuation subsequently occurred due to high water level in Steam Generator No. 1. The high water level was a result of the Integrated Control System (ICS) Rapid Feedwater Reduction (RFR) circuitry not being wired correctly.

The root cause for the unplanned reactor scam determined the manufacture and design of the element in Shawmut A25X series fuses rated less than or equal to thirty amperes resulted in intergranular tearing with a reduction in current carrying potential of fuse Y414 which provided power to RPS Channel No. 4 (CR 2016-01364).

A contributing cause was a deficient trend evaluation of spurious failures of Shawmut A25X fuses similar to that installed in Y414 despite preventative maintenance for periodic replacement.

Two root causes were identified for the complication (CR 2016-01365):

o The work package instructions for replacement ICS module 5-2-8 did not ensure the bench check prior to installation adequately tested its intended function; and o Procedural guidance for making life cycle changes to site internal software was less than adequate to ensure changes do not introduce new failure modes or adequately document the basis for testing, and testing to ensure the change corrects the initial issue.

A contributing cause was the May 9, 2015, post-trip review lacked sufficient rigor to ensure all potential RFR failure modes were fully assessed. A second contributing cause was less than adequate methods available for testing software changes to ICS.

Corrective actions taken and/or planned included but were not limited to:

o Replacement of failed fuse Y414 and its associated power supply (complete);o Repair of the failed resistance temperature detector (RTD) in RPS Channel No. 1 (complete);o Replacement of the existing stock of uninstalled A25X fuses with a different style by a different vendor (complete);o Development of an engineering change package to replace Shawmut A25X fuses installed in the plant (complete);o Replacement of all Shawmut A25X fuses (planned);o Replacement of the improperly configured ICS RFR module and verification of correct wiring (complete);o Creation of a data package that provides guidance for proper bench testing of RFR modules (complete); and o Modification of SG/Rx Demand control circuitry to prevent an unintended transfer from automatic to manual control during reactor trip (complete).

Effectiveness reviews planned include but are not limited to:

o Following implementation of the preventative actions to replace Shawmut A25X series of fuses, the fuse performance will be monitored for two years to ensure no spurious failures of the replacement fuses occur; and o Performance of an assessment to ensure no events occur related to life cycle software changes on control systems.

NRC IR 05000346/2016001 (ADAMS Accession No. ML16118A435) dated April 26, 2016, and 05000346/2016002 (ADAMS Accession No. ML1607A600) dated July 25, 2016, documented the inspection results of this event and closure of LER 2016-001-00, Reactor Trip during Nuclear Instrumentation Calibrations, and Steam Feedwater Rupture Control System Actuation on High Steam Generator Level.

• Reactor Trip Due to Water Intrusion Into Automatic Voltage Regulator Cabinet On September 10, 2016, a main generator lockout and reactor scram occurred due to water intrusion into the automatic voltage regulator (AVR) cabinet from a stuck-open roof vent during a period of heavy rain. The scram was complicated when an automatic SFRCS actuation subsequently occurred due to high water level in Steam Generator No.

1. The high water level was a result of degradation of an operational amplifier on ICS module 5-6-6 that adversely impacted the ICS RFR circuitry.

Two root causes were identified for the scram (CR 2016-10725):

o Operations section shift managers did not advocate adequate and timely compensatory actions to eliminate the risk to generation posed by rain falling onto energized equipment through a stuck open turbine building roof vent; and o Station management including the operations section staff and the Management Review Board failed to recognize the rain through a stuck-open turbine building roof vent as a potential imminent risk to generation.

A contributing cause was long-standing issues with the degraded material condition of the turbine building ventilation system fostered an increasing reliance upon the turbine building roof vents to help moderate the ambient temperature in the turbine building.

A second contributing cause was the operating crews had a less than adequate understanding of the collective significance of the turbine building roof vent material condition due to the substandard configuration control utilized for the roof vents.

The root cause for the complication was determined to be corrective actions to address vulnerabilities in ICS through module calibration and/or refurbishment were not adequate to prevent future events (CR 2016-10724).

A contributing cause was the design of the ICS RFR circuit was not fault tolerant, and a single failure could prevent the system from functioning properly. A second contributing cause determined modifications for fault tolerance and corrective actions for RFR testing were deferred or not performed.

Corrective actions taken and/or planned included but were not limited to:

o Repair and replacement of components internal to the AVR (complete);o Closure and subsequent repair of turbine building roof vents (closure complete, repairs nearing completion at the end of the inspection period);o Development of a case study focusing on turnover, operational challenges, compensatory measures or mitigating actions and ownership, elevated risk, and issue knowledge for staff and management (planned);o Establishment of configuration control tools commensurate with the identified risk for open turbine building roof vents and other plant areas (complete);o Assessment of turbine building ventilation to restore system function to design capacity (planned);o Repair and replacement of select ICS modules in the RFR circuitry (complete);o Replacement of additional RFR modules and additional preventative maintenance testing of the RFR circuit in its entirety (planned); and o Performance of a deep dive assessment on the ICS to address performance issues, single-point vulnerabilities, operating experience, and outstanding plant modifications (complete).

Effectiveness reviews planned include but are not limited to:

o Assessment of the Management Review Boards performance at three meetings held during three different weeks for thoroughness in addressing issue knowledge, operational challenges, intrusiveness, compensatory measures or mitigating actions, and elevated risk; o Assessment of the thoroughness and effectiveness of CR Senior Reactor Operator reviews in the areas of risk recognition and compensatory or mitigating actions; and o Following implementation of corrective actions to improve the function of or decrease the reliance on the RFR circuit, ICS RFR performance will be monitored for two years to ensure no further failures related to the operation of the RFR circuit during a trip or complication, otherwise verification that the RFR circuit successfully passes the recommended testing during the next two refueling outages.

NRC IR 05000346/2016003 (ADAMS Accession No. ML16309A098) dated November 4, 2016, and 05000346/2016004 (ADAMS Accession No. ML17027A319) dated January 26, 2017, documented the inspection results of this event and closure of LER 2016-009 Reactor Trip Due to Rainwater Intrusion and Auxiliary Feedwater Actuation on High Steam Generator Level.

• White Unplanned Scrams With Complications PI Aggregate Analysis (CR 2016-07455)

The licensee performed an aggregate analysis on the three unplanned scrams with complications. The root cause for the unplanned scrams with complications was determined to be less than adequate commitment by Davis-Besse leaders to the assessment and mitigation of risks to plant operation commensurate with the potential consequences or safety significance. A contributing cause was some aspects of industry OE with scrams were not utilized effectively to manage the risk and vulnerabilities of scrams or transients and the resultant complications at Davis-Besse. Multiple examples were referenced for each cause.

Corrective actions taken/and or planned included but were not limited to:

o Select management changes to promote sound decision-making capabilities to address performance shortfalls (complete);o Development and presentation of case-study of engineering products challenging operations was presented during engineering continuing training in the fourth quarter of 2016 (complete);o Reinforcement and affirmation of expectations with site managers for implementation of risk management through existing guidance for coping with risk at FENOC (complete);o Discussion on what risks, with associated probabilities and potential costs, should be incorporated into the stations risk heat map (complete); and o Development and implementation of supervisory continuing training on updates to industry risk management guidance (planned).

Effectiveness reviews planned include but are not limited to:

o An interim effective review six months after completion of planned actions for the root cause to validate site management understanding of the integrated guidance on coping with risk at FENOC. Remediation will be provided to any managers not achieving at least 80 percent comprehension of the enabling objectives; and o A final effectiveness review one year after completion of planned actions to verify risk management heat maps align with the reviews of internal and external stakeholders including the Plant Health Committee, Project Review Committee, Regulator Compliance, Corporate Functional Area Managers, Oversight, Company Nuclear Review Board, Institute of Nuclear Power Operations (INPO), and the NRC.

The inspector reviewed corrective actions that were taken or planned to address the identified causes. The inspector also held discussions with licensee personnel to ensure that the root and contributing causes, and the contribution of safety culture components, were understood and corrective actions taken or planned were appropriate to address the causes and preclude repetition.

The following inspection results are organized by the specific inspection objectives of IP 95001. Documents reviewed are listed in the Attachment to this report.

.02 Evaluation of the Inspection Requirements

02.01 Problem Identification a. Determine that the evaluation documented who identified the issue(s)

(i.e., licensee-identified, self-revealed, or NRC-identified) and under what conditions the issues(s) were identified.

Each of the events described in Section 4OA4.01 were the result of self-revealing issues.

The inspector determined that the licensees RCEs adequately documented who and under what conditions the issues were identified.

b. Determine that the evaluation documented how long the issue(s) existed and prior opportunities for identification.

The licensee evaluations of the events generally documented when the issues originated, the circumstances in which each issue could have been previously identified, and documented the conditions, when applicable, involving similar events that had occurred.

The inspector determined that the licensees evaluations were adequate with respect to identifying how long the issues existed and if there were any prior opportunities for identification.

c. Determine that the evaluation documented significant plant-specific consequences, as applicable, and compliance concerns associated with the issues(s).

The licensee evaluations included a discussion on the plant-specific consequences and discussed compliance concerns associated with the issues. The reportability of each event was also discussed. Specific changes in core damage frequency as a result of the events were referenced and/or discussed in the associated LERs for each event.

The inspector concluded that the licensee evaluations appropriately documented significant plant-specific consequences and compliance concerns associated with each issue and in aggregate.

d. Findings

No findings were identified.

02.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation a. Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes.

The inspector determined that the RCEs adequately applied systematic methods in evaluating the issues in order to identify root causes and contributing causes. The RCEs generally consisted of a timeline/sequence of events, event and causal factor charting, barrier analysis, equipment apparent cause evaluation, failure modes analysis, latent organizational weakness evaluation, and review of OE.

The inspector determined that the licensee selected appropriate analysis methods to ensure thorough and complete evaluations and adequately evaluated each issue using a systematic methodology to identify the root and contributing causes.

b. Determine that the RCE was conducted to a level of detail commensurate with the significance of the problem.

The licensees RCEs included sufficient information for each event regarding event timelines, event descriptions, previous occurrences, missed opportunities, and analysis discussion. Each RCE used multiple evaluation methodologies, as discussed in Section 02.02.a, to ensure the level of details matched the significance of the event.

The inspector determined that the RCEs were conducted to a level of detail commensurate with the significance of each of the events.

c. Determine that the RCE included a consideration of prior occurrences of the problem and knowledge of prior OE.

The licensees RCEs included a review of internal and external OE. For each of the RCEs, the licensee documented extensive OE. The licensee found multiple examples of internal and external OE and recognized, in multiple instances, that there were missed opportunities where the station could have taken actions to prevent events.

The inspector determined that the RCEs included a consideration of prior occurrences of the problem and knowledge of prior OE. The inspector noted that although the aggregate analysis review contained an extensive review of OE, there was not a direct discussion on the effectiveness of the OE program given the number of missed opportunities identified in each of the individual RCEs that resulted in events. CR 2017-02651 was generated to perform an assessment of OE program implementation. The inspector also noted that a reactor trip reduction plan, created in July 2015 after the first unplanned scram with complications to prevent additional complicated scrams and a white PI resulting in IP 95001, was outdated and provided little value given the two additional scrams with complications despite the latest revision dated February 1, 2017. CR 2017-02652 was generated to update the trip reduction plan.

d. Determine that the RCE addressed the extent of condition and the extent of cause of the problem.

The RCEs addressed the extent of condition and extent of cause of the issues.

For the aggregate analysis, the licensee performed a single point vulnerability assessment as recommended by industry guidance in an effort to reduce the susceptibility to unplanned scrams. To reduce unplanned scrams with complications, the licensee performed a multi-discipline deep-dive assessment on the ICS. Additionally, the licensee determined that leadership behavior influenced the common factors such as RFR, implementation of problem identification and resolution, and engineering when a consequence-biased approach was not applied to decisions affecting risk. Risk management heat maps were updated to maintain appropriate risk management focus.

Each of the other RCEs addressed the extent of condition and extent of cause of the problem that resulted in the scrams and/or complications. Corresponding corrective actions appeared to be appropriate to address the problems.

The inspector determined that the RCEs addressed the extent of condition and extent of cause.

e. Determine that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture traits in NUREG-2165, Safety Culture Common Language, referenced in Inspection Management Chapter (IMC) 0310, Aspects Within Cross-Cutting Areas.

The licensees RCEs included a review of whether a weakness in any safety culture component contributed to the issues. The licensees evaluations identified weaknesses in safety culture components that were related to the identified root causes and contributing causes. In particular, the licensee identified, in the aggregate analysis, conservative bias as a significant contributor and OE as a weakness/missed opportunity. The licensee established adequate corrective actions to address the safety culture weaknesses that were identified.

The inspector determined that the licensees RCEs included proper consideration of whether the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components.

f. Examine the common cause analyses for potential programmatic weaknesses in performance when a licensee has a second White input in the same cornerstone.

The licensee does not have a second White input in the same cornerstone; therefore, this inspection item was not applicable.

g. Findings

No findings were identified.

02.03 Corrective Actions Taken a. Determine that appropriate corrective actions are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary.

The licensees RCEs identified numerous corrective actions taken to address the root and contributing causes. Various corrective actions for each event are described in Section 4OA4.01.

The inspector reviewed each of the corrective actions and determined they adequately addressed the identified root and contributing causes.

b. Determine that corrective actions have been prioritized with consideration of the risk significance and regulatory compliance.

The licensees corrective actions taken following each event generally restored the impacted systems to functional/operable in order to restore regulatory compliance.

The inspector reviewed and discussed with station personnel the prioritization of the corrective actions taken and verified that, within reason, actions of a generally higher priority were completed ahead of those of a lower priority.

The inspector determined that the licensee adequately prioritized the corrective actions with consideration of the risk significance and regulatory compliance.

c. Determine that corrective actions taken to address and preclude repetition of significant performance issues are prompt and effective.

The licensees RCEs identified numerous corrective actions to prevent recurrence of the significant performance issues. Those corrective actions were adequate to address the adverse conditions. Some actions of previous events were not originally effective in precluding repetition as discussed in Section 4OA4.1. Additional corrective actions were taken subsequent to identification to address and preclude repetition of the issue.

The inspector determined that overall corrective actions taken to preclude repetition of significant performances issues were prompt and effective.

d. Determine that each Notice of Violation (NOV) related to the supplemental inspection is adequately addressed, either in corrective actions taken or planned.

The NRC staff did not issue an NOV to the licensee; therefore, this inspection requirement was not applicable.

e. Findings

No findings were identified.

02.04 Corrective Action Plans a. Determine that appropriate corrective action plans are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary, and that corrective action plans have been prioritized with consideration of significance and regulatory compliance.

The licensees RCEs specified corrective action plans for each root and contributing cause and prioritized plans with defined due dates. The licensee also accounted for significance of the issues when prioritizing the actions, and considered regulatory compliance when applicable.

The inspector reviewed and discussed with station personnel the prioritization of the corrective actions planned and verified that, within reason, actions of a generally higher priority were completed ahead of those of a lower priority. The inspector noted that planned corrective actions associated with replacement of installed A25X fuses susceptible to failure (most of which are in safety-related components) were adequately prioritized to complete all replacements by the next refueling outage; however, the prioritization for each individual fuse and associated determination for online or outage replacement was still under review by the licensee at the end of the inspection period.

The inspector determined that appropriate corrective action plans were specified for each root and contributing cause and that corrective action plans were prioritized with consideration of significance and regulatory compliance.

b. Determine that corrective plans direct prompt actions to effectively address and preclude repetition of significant performance issues.

The licensees RCEs included numerous corrective action plans to ensure significant performance issues are effectively addressed and to preclude repetition. The inspector reviewed the corrective action plans and verified the licensee had established a formal tracking mechanism for each specific corrective action.

The inspector determined that the corrective plans directed prompt actions to effectively address and preclude repetition of significant performance issues.

c. Determine that appropriate quantitative or qualitative measures of success have been developed for determining the effectiveness of planned and completed corrective actions.

The licensees RCEs developed effectiveness reviews as discussed in Section 4OA4.1 that contained quantitative and/or qualitative measures of success for determining the effectiveness of planned and completed corrective actions.

The inspector determined that adequate measures of success had been developed for determining the effectiveness of the corrective actions planned and completed.

d. Determine that each Notice of Violation (NOV) related to the supplemental inspection is adequately addressed in corrective actions taken or planned.

The NRC staff did not issue a NOV to the licensee; therefore, this inspection requirement was not applicable.

e. Findings

No findings were identified.

02.05 Evaluation of Inspection Management Chapter 0305 Criteria for Treatment of Old Design Issues The inspector determined the issues did not meet the IMC 0305 criteria for treatment as an old design issue.

4OA6 Exit Meeting

.1 Exit Meeting Summary

On March 10, 2017, the inspector presented the inspection results to Mr. B. Boles, the Site Vice President, and other members of the licensee staff. The inspector asked the licensee if any of the material examined during the inspection should be considered proprietary. The licensee did not identify any proprietary information.

.2 Regulatory Performance Meeting

During the March 10, 2017, exit meeting, the NRC discussed with the licensee its performance at Davis-Besse Nuclear Power Station in accordance with IMC 0305, Section 10.01.a. The meeting was attended by the Region III Projects Branch 4, Branch Chief, NRC resident and senior resident inspector, the Davis-Besse Site Vice President, and other senior licensee staff. During this meeting, the NRC and licensee discussed the issues related to the White PI for Unplanned Scrams with Complications that resulted in Davis-Besse Nuclear Power Station remaining in the Regulatory Response Column of the Action Matrix. This discussion included the causes, corrective actions, extent of condition and extent of cause, and other planned licensee actions for the issues identified as a result of the individual scram events. The criteria required for returning to the Licensee Response Column of the Action Matrix was discussed given the Unplanned Scrams with Complications PI had not returned to Green as of the end of the inspection period.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Boles, Site Vice President

K. Byrd, Director, Site Engineering

T. Brown, Director, Site Performance Improvement

J. Cuff, Manager, Training

J. Cunnings, Manager, Site Maintenance

A. Dawson, Manager, Chemistry

D. Hartnett, Superintendent, Operations Training

T. Henline, Manager, Site Projects

B. Howard, Manager, Site Outage Management

D. Imlay, General Plant Manager

G. Laird, Manager, Site Operations

B. Matty, Manager, Recovery Team

G. Michael, Manager, Design 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

V. Schultz, Regulatory Compliance

L. Thomas, Manager, Nuclear Supply Chain

J. Vetter, Manager, Emergency Preparedness

L. Willis, Manager, Site Protection

G. Wolf, Supervisor, Regulatory Compliance

K. Zellers, Manager, Technical Services Engineering

U.S. Nuclear Regulatory Commission

J. Cameron, Chief, Reactor Projects Branch 4

LIST OF ITEMS

Opened

None

Closed

None