IR 05000346/2017007

NRC Problem Identification and Resolution Inspection Report 05000346/2017007

ML17249A452
Person / Time
Site:	Davis Besse
Issue date:	09/06/2017
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
IR 2017007
Download: ML17249A452 (25)

Text

UNITED STATES ber 6, 2017

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATIONNRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2017007

Dear Mr. Bezilla:

On August 4, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) biennial inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the results of this inspection which were discussed on August 4, 2017, with Mr. D. Imlay and other members of your staff.

The NRC inspection team reviewed the stations corrective action (CA) program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for CA programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment (SCWE), and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations SCWE. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. 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. NPF-3 Enclosure:

Inspection Report 05000346/2017007 cc: Distribution via LISTSERV

SUMMARY OF FINDINGS

Inspection Report 05000346/2017007; 7/17/17-8/04/17; Davis-Besse Nuclear Power Station;

Biennial Problem Identification and Resolution Inspection Report This inspection was performed by three NRC regional inspectors and the Davis-Besse Nuclear Power Station resident inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

Problem Identification and Resolution On the basis of the sample selected for review, the team determined that implementation of the corrective action (CA) program and associated processes at Davis-Besse support nuclear safety. The licensee demonstrated a low threshold for identifying problems and entering them in the CA program. Items entered into the CA program were screened and prioritized in a timely manner using established criteria; were generally evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were performed at a level sufficient to identify most deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to raise and enter safety concerns directly into the CA program or through their supervisors.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in inspection procedure 71152.

Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees CA program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CA program since the last NRC Problem Identification and Resolution (PI&R) inspection in May 2015.

The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed condition reports (CRs) generated during facility personnels performance in daily plant activities. The inspectors also reviewed a selection of work orders (WOs), self-assessment results, audits, performance indicator reports, system health reports, and completed investigations from the licensees various investigation methods, which included root cause evaluation (RCE) and apparent cause evaluation (ACE) processes.

The inspectors selected the boric acid addition system to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of the system and associated components through effective implementation of station monitoring and periodic component replacement programs. The inspectors performed a five-year review of the system to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. In addition to a walkdown of the accessible portions of the boric acid system, the inspectors performed a partial system walkdown of the component cooling water system and the service water system to review whether equipment conditions were appropriately represented in the CA program, work orders, and system health documents.

During the reviews, the inspectors determined whether the licensee staffs actions complied with the facilitys CA program and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined whether licensee personnel were identifying station issues at the proper threshold, entering the station issues into the stations CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected condition reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations.

Documents reviewed are listed in the Attachment to this report.

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and information from interviews, the inspectors determined that the licensee has a low threshold for identifying issues and initiating CRs. From the CRs reviewed, the threshold was appropriate. The inspectors did not identify any safety significant item that was not entered into the CA program. The inspectors assessed the effectiveness of problem identification as supporting nuclear safety.

Observations The inspectors found that issues were being identified and captured in the licensees programs which primarily included the CA program and the work order (WO) program.

During 12 non-outage months of July 2016 to June of 2017 the licensee initiated 3971 CRs. The licensee classified greater than 95 percent of those CRs as low-level CRs and then closed the low-level CRs to a WO or trending, to a fix category, or as a non-CA program issue. No formal cause determination is required for low-level CRs by the licensees programs.

The inspectors also noted that the licensees procedures allowed specific low-level non-safety issues to be addressed through the WO notification/request system without initiating a CR. A licensee Nuclear Maintenance Screening Committee screens equipment WO notifications/requests to determine whether CRs should have been generated. The inspectors reviewed the functioning of that committee by observing a committee meeting. The inspectors did not identify any instances where CRs should have been written and were not.

The inspectors reviewed open corrective WOs, open CA items, and system health reports for the boric acid addition system. Accessible portions of the system were walked down with the system engineer. The inspectors found the system to be in overall good health with a reasonable number of open corrective WOs and CA items.

Inspectors also walked down with system engineers a portion of the component cooling water system and the service water system. The inspectors did not find any conflicts between the conditions represented by the open WOs, CA documents, system health reports and the actual system conditions. The inspectors, in reviewing component cooling water WOs, identified several older WOs that were associated with administrative issues that could have been closed but were not.

From review of safety conscious work environment (SCWE) surveys and from discussions with plant personnel, the inspectors found that some personnel believed the CA program was ineffective for resolving low-level issues and personnel might not initiate a CR or a WO notification for such issues. The inspectors did not identify any significant issues where CRs should have been written and were not.

The inspectors noted that the licensee has modified and is continuing to gradually modify their CA program governing procedures to align more closely with industry initiatives to provide alternatives to make CA programs generally more effective. The inspectors did not identify any conflicts between the licensees current programs and NRC regulations.

Although there is a low threshold for identifying and entering issues into the CA program, the licensee continues to identify opportunities for improvement through their self-assessment process. The licensees focused self-assessment of the CA program in preparation of this years NRC PI&R inspection (SA-BN-2016-0189) identified instances where CRs had not been initiated where they should have per the site expectations. Instances of late initiation of CRs were also identified in the self-assessment. None of these instances constituted findings or violations of NRC regulatory requirements.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensees overall performance in the prioritization and evaluation of issues was appropriate. The inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were being appropriately screened by the originating departments, the Management Review Board, and Operations shift management for items potentially impacting equipment operability.

Evaluations in ACE and RCE reports reviewed by the inspectors appropriately supported nuclear safety.

The inspectors identified no items in the backlogs of the CA program or maintenance WO system that were risk significant, either individually or collectively. The inspectors reviewed the licensees WO backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

Observations The inspectors reviewed several RCEs and ACEs. The inspectors did not identify any issues that indicated that licensees processes were ineffective. The inspectors identified several non-significant deficiencies in the evaluation of issues. These included:

• The most limiting structural component was not evaluated in an applicable Part 21 review. The condition was associated with error in STAAD.Pro software, a computer tool for the analyses of structures. CR-2015-10482 (Deviations While Utilizing Bentley Software STAAD.PRO on Safety Related Calculations)documented four calculations that required further evaluation. The licensee initially concluded in the equipment evaluations that there were no adverse impacts on adjacent equipment, structures, or components and that there was reasonable assurance that the analyzed equipment would perform its safety function. The licensee evaluation of Calculation C-CSS-099.20-066, CWRT Room 123 Platform along the West Wall, included analyses of various other structural components of the subject platform, including the concrete expansion anchors for the north strut. These components, however, were not evaluated in CR-2015-10482 despite the fact that the availability of design margin was in question when accounting for the software error. In response to inspector questioning, the licensee further evaluated the condition and determined that there was a reasonable assurance of functionality because their Design Criteria Manual includes allowance to use a reduced factor of safety for these components for the interim conditions, which allows for sufficient functionality margin to account for the software error. The licensee entered this issue into their CAP as CR-2017-08010 (2017 NRC PI&R: Calculation C-CSS-099.20-066 Most Limiting Member/STAAD.PRO Part 21). The licensee has ongoing corrective actions from CR-2015-10482 to revise the affected calculations.

• The inspectors questioned licensee conclusions in CRs associated with identified slowness during the backup of control room computer stored data. The licensee had originally stated that there was no effect on Technical Support Center and Emergency Response Group data, but after inspector questioning, potential impacts were identified. CR-2017-06721 (Plant Computer/PI System Communication Problem) identified that the Safety Display Parameter System (SPDS) and the other system data displayed outside the control room experienced delays during scheduled data backups. A delay of up to approximately 20 minutes could occur when the Data Acquisition and Analysis System (DADS) was running a scheduled backup of data during weekday evenings. The inspectors questioned if the delay in updating plant information during the daily data backup might affect the ability to timely classify and declare an emergency if an event occurred during the scheduled data backups.

• The licensee subsequently determined the data delay would not impact displays in the control room but information in the Technical Support Center, Emergency Operations Facility, and the NRC Incident Response Center could be up to 20 minutes out-of-date. The licensee entered this issue into their CAP as CR-2017-08039 (2017 NRC PI&R: ERDS Time Stamp During DADS Backup)and took immediate action to address the identified issue.

The inspectors determined from licensee data that as of June 21, 2017, the CA program had approximately 92 open CRs that had been approved for follow-up investigation and were initiated prior to June 2017. Of those, 46 CRs were initiated prior to 2017. The licensee information also listed that 3617 CRs had been closed during 2016. The largest backlog of open actions was in the engineering groups.

As of June 2017 the station had a WO backlog of 246 activities classified as corrective maintenance. The station uses the industry classification scheme in AP-928, Work Management Process Description, for grouping WOs. The inspectors review concluded that the numbers appeared consistent with industry averages and classifications. From the documents reviewed and partial walkdown of several plant systems, the inspectors did not identify any current significant corrective maintenance issues.

The inspectors reviewed selected Prompt Operability Determinations and did not detect any deficiencies in the selected determinations.

(3) Effectiveness of Corrective Actions On the basis of the CAs documents reviewed, the inspectors concluded that the CAs appeared generally appropriate for the identified issues. Those CAs addressing selected NRC documented violations were also determined to be generally effective and timely. The inspectors review of the previous five years of the licensees efforts to address issues with the boric acid addition system did not identify any negative trends or inability by the licensee to address long-term issues. Sampled WOs and notifications used to close CRs were appropriate for the identified issues and the process was consistent with relevant procedures, although the inspectors identified some instances where notifications were not initially tied to CRs by notations in both documents as required by plant procedures.

Observations The inspectors reviewed various cause analyses and CA documentation associated with systems, structures, components (SSCs), classified as (a)(1) status in accordance with the maintenance rule (10 CFR 50.65), to determine whether the trending analysis associated with the SSCs and the CA program should have prevented entry into (a)(1)status. The inspectors did not identify any occurrences where the completed CAs or trending analyses should have prevented entry of a SSC into (a)(1) status.

The inspectors performed a review of the licensees CA program and associated documents focusing on the boric acid addition system to determine whether any obsolescence and aging issues existed for the last five years. The inspectors review found that reviewed corrective actions were complete, accurate, and timely; considered extent of condition; provided appropriate classification and prioritization; provided identification of root and contributing causes; appropriately focused actions that resulted in the correction of the identified problem; and identified negative trends. In the documents reviewed, operating experience was adequately evaluated for applicability and applicable lessons learned were communicated to appropriate organizations.

Licensee procedures allow closure of some low-level issue CRs to the WO system for tracking completion of CAs. The process requires cross-referencing in both the CR and WO system. The inspectors questioned the efficiency of this allowance since the licensee had identified examples where the cross-referencing was not apparent. The inspectors reviewed a sample of work order notifications and orders and did not independently identify any examples that would negate the licensees ability to track and verify the closure of corrective actions.

Findings No findings were identified.

Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys operating experience (OE) program. Specifically, the inspectors reviewed OE program implementing procedures, attended CA program meetings, reviewed completed evaluations of OE issues and events, and selected assessment of the OE performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, and whether the licensees program was sufficient to prevent future occurrences of previous industry events. The inspectors also assessed whether corrective actions (CAs), as a result of OE, were identified and implemented in an effective and timely manner.

Assessment Overall, the inspectors determined that the licensee was effective at evaluating NRC and industry OE for relevance to the facility. The inspectors also verified that the use of OE in formal CA program products such as RCEs and ACEs was appropriate and adequately considered. The OE that was applicable to the facility was appropriately evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Observations The licensee maintains control of 10 CFR Part 21 review activity under the station program per NOP-CC-1003, Vendor Manuals and Vendor Technical Information. The program governs the receipt, review, approval, and control of the vendor manuals and vendor technical information. The inspectors found that the 10 CFR Part 21 notifications have been adequately evaluated since the NRC problem identification and resolution inspection in 2015 which found continuing weakness in maintaining the 10 CFR Part 21 notification database up-to-date to ensure appropriate screening and timely evaluations.

The inspectors determined that screening is now performed periodically (i.e. two to three times a month) by the Part 21 coordinator for applicability to the station. The applicable Part 21 issues are distributed to the staff member knowledgeable in the subject matter who then evaluates the condition to determine the appropriate course of action.

Evaluations reviewed were performed in a timely manner, CRs were generally written to document the review results, and the database was maintained up-to-date.

The inspectors noted that the self-assessment performed for the 2017 Problem Identification and Resolution (PI&R) Inspection readiness (SA-BN-2016-0189)identified a few instances where the CRs were not written in a timely manner to prompt review of Part 21 notifications. The self-assessment identified two instances where the CRs were not written until March of 2017 for conditions identified in July of 2016 and one instance where a CR was not written until April 2017 for a November 2016 condition.

b. Findings

No findings were identified.

Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.

Observations Licensees focused self-assessment in preparation of this NRC PI&R inspection (SA-BN-2016-0189) identified that Davis-Besses implementation of an integrated performance assessment and trending (IPAT) process as described in licensee procedure NOBP-LP-2018, Integrated Performance Assessment and Trending, had gaps in implementation of the program. The licensees review of the effectiveness of the process concluded that managers and analysts had not fully demonstrated ownership of the IPAT process, with timely completion of the IPAT reports remaining a gap in performance.

The inspectors sampled self-assessments and determined that they were thorough, self-critical and identified many deficiencies, did not minimize the significance of the deficiencies, and recommended CAs for the identified deficiencies. The self-assessments that evaluated corrective actions were also thorough, self-critical and identified many instances of CAs that were not implemented appropriately or in a timely manner.

b. Findings

No findings were identified.

Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees SCWE through reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from 2015 and 2016 internal SCWE surveys and an organizational effectiveness survey conducted in 2017.

As part of the overall inspection effort, inspectors discussed department and station programs with a variety of personnel in formal and informal settings. The inspectors held two focus group sessions with individuals randomly selected by the inspectors. The inspectors also interviewed personnel in informal settings in their work location.

Approximately 50 personnel, from various station departments, were questioned to assess their willingness to raise nuclear safety issues. Additionally, personnel were asked their views of the effectiveness of the CA program.

The inspectors also discussed the functioning of the ECP with the program coordinator, reviewed program logs from 2016 and 2017, and reviewed two case files.

Assessment The inspectors did not identify any issues of concern regarding the licensees safety conscious work environment (SCWE). Information obtained during the interviews indicated that an environment was established where the majority of licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CA program and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised. Interviewed personnel stated that safety significant issues could be freely communicated to supervision. The inspectors did not observe and were not provided any examples of retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews even with survey issues identifying conditions in at least one department that might act to inhibit discussion of items.

Observations The inspectors noted that the 2015 and 2016 SCWE surveys identified groups where some 20 percent or more of respondents did not affirmatively indicate that there was no retaliation for bringing up issues or that their supervisors put safety over cost and schedule. The inspectors did not identify any substantiation that people were retaliated against for bringing up issues or that cost and schedule were considered to the detriment of safety.

All interviewees indicated that they could and would bring up safety issues with supervision, management, and through the CA program. None of the interviewed personnel stated that there was intimidation or retaliation when they brought up issues.

Those same interviewees predominantly said they would use the ECP but saw no need to have to resort to the ECP for issue reporting.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 4, 2017, the inspectors presented the inspection results to the General Plant Manager, Mr. D. Imlay, 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 and that all material considered proprietary by the licensee was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Imlay, General Plant Manager

J. Johnson, Performance Improvement

J. Aldrich, Technical Engineering Services

K. Oxendale, System Engineering

P. McCloskey, Manager Regulatory Compliance

J. Sturdavant, Regulatory Compliance

R. Patrick, Manager Work Management

J. Johnson, Regulatory Compliance

K. Byrd, Director Engineering

S. Hower, Operations

M. Murtha, Design Engineering

J. Fawcett Work Management

K. Browning, Performance Improvement

G. Ellithorpe, Performance Improvement

U.S. Nuclear Regulatory Commission

J. Cameron, Chief, Reactor Projects Branch 4

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Closed

None.