IR 05000346/2020004

Integrated Inspection Report 05000346/2020004

ML21043A444
Person / Time
Site:	Davis Besse
Issue date:	02/12/2021
From:	Billy Dickson Division Reactor Projects III
To:	Tony Brown Energy Harbor Nuclear Corp
References
IR 2020004
Download: ML21043A444 (27)

Text

February 12, 2021

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2020004

Dear Mr. Brown:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On January 28, 2021, the NRC inspectors 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Davis-Besse Nuclear Power Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Davis-Besse Nuclear Power Station. 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,

/RA/

Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Docket No. 05000346 License No. NPF-3

Enclosure:

As stated

Inspection Report

Docket Number: 05000346 License Number: NPF-3 Report Number: 05000346/2020004 Enterprise Identifier: I-2020-004-0028 Licensee: Energy Harbor Nuclear Corporation Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Inspection Dates: October 1, 2020 to December 31, 2020 Inspectors: S. Bell, Health Physicist J. Cassidy, Senior Health Physicist M. Garza, Emergency Preparedness Inspector J. Harvey, Resident Inspector D. Mills, Senior Resident Inspector J. Neurauter, Senior Reactor Inspector Approved By: Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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

Failure to Maintain the Effectiveness of the Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.11] - 71114.04 Preparedness NCV 05000346/2020004-01 Challenge the Open/Closed Unknown The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.54(q)(2) for the licensees failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, on August 11, 2020, the Davis-Besse Nuclear Power Station experienced a phone outage that affected the licensees ability to receive calls from offsite. Since they could not receive calls and an alternate notification method was not available, they could not receive notifications per Emergency Action Level (EAL) HA 1.2. During the communications outage, the licensee did not maintain the emergency plan due to EAL HA 1.2 being rendered ineffective. The licensee did not establish compensatory actions until after inquiry from the Senior Resident Inspector.

The licensees corrective actions included:

• establishing compensatory measures

• updating their procedures to incorporate these actions

• entering this issue into their CAP as CR 2020-06343

Additional Tracking Items

None.

PLANT STATUS

The plant operated at or near rated thermal power for the entire inspection period.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of winter for the following systems:

• Borated water storage tank

• Emergency feedwater system

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 5, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Core spray train 2 during the week ending December 19, 2020

(2) High pressure injection train 2 after planned testing during the week ending

December 26, 2020 Complete Walkdown Sample (IP Section 03.02) (2 Samples)

(1) The inspectors evaluated system configurations during a complete walkdown of the emergency feedwater system during the week ending January 2, 2021.

(2) The inspectors evaluated system configurations during a complete walkdown of the emergency diesel generator system during the week ending December 19, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Mechanical penetration room 1 (room 208), fire area AB, during the week ending November 7, 2020

(2) Control room and control room support rooms (rooms 502-513), fire area FF, during the week ending December 12, 2020

(3) Service water pump room (room 52), fire area BF, during the week ending December 19, 2020

(4) Emergency core cooling system pump room 2 (room 115), fire area A-04, during the week ending December 19, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Emergency core cooling system pump room 2 (room 115)

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification program biennial written examination and annual operating test administered between October 19 and December 11, 2020.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Partial)

(1) (Partial)

Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on 12/4/2020.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test Due to the COVID-19 PHE, the inspectors could not by direct observation, evaluate the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives. Specifically, the inspectors did not observe the administration of simulator scenarios and JPMs during the conduct of an annual requalification operating test required by 10 CFR 55.59(a)(2).

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during power changes, turbine valve testing, and control rod drive exercise during the week ending December 12, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator license requalification simulator scenarios on December 9, 2020 and December 10, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Repeat failure of containment air cooler 2 service water outlet, SW1357 during the week ending September 5, 2020

(2) Borated water storage tank level transmitter replacement due to water intrusion during the week ending June 27, 2020

(3) Programmatic review of the periodic maintenance effectiveness assessment report for May 9, 2018, to March 3, 2020

(4) Emergency diesel generator 1 scheduled 2-year preventive maintenance during the week ending November 14, 2020

(5) Low pressure injection/decay heat pump 2 bearing replacement and constant level oiler installation during the week ending October 31, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR 2020-05932: Incorrect comparison of borated water storage tank concentration to upper technical specification limit

(2) CR 2020-04688: Reactor coolant pump 2-2 seal return flow high

(3) CR 2020-09055: Storm damage to shield building scaffold

(4) CR 2020-05473: AF6451 close mVdc does not meet the minimum value specified in test procedure during minimal time period of power being applied

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Emergency feedwater testing following installation of automatic start function during the week ending November 21, 2020

(2) Component cooling water pump 1 following overhaul during the week ending October 31, 2020

(3) Emergency diesel generator 1 following planned maintenance during the week ending November 14, 2020

(4) Low pressure injection/decay heat pump 1 following planned maintenance during the week ending December 12, 2020

(5) Emergency core cooling system room cooler 4 following planned maintenance during the week ending December 12, 2020

(6) Auxiliary feedwater pump 1 following planned maintenance during the week ending September 12, 2020

(7) Low pressure injection/decay heat pump 2 following bearing replacement and constant level oiler installation during the week ending October 31, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Emergency diesel generator 1 184-day run during the week ending

November 28, 2020 Inservice Testing (IP Section 03.01) (3 Samples)

(1) Emergency core cooling system train 1 quarterly valve testing during the week ending December 5, 2020

(2) Turbine valve testing during the week ending December 12, 2020

(3) Control rod drive exercise during the week ending December 12, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Emergency feedwater pump quarterly testing during the week ending November 28, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 31, 2020. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Integrated emergency preparedness/emergency response drill held on October 6,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) Shepherd Model 89 calibrator repair under RWP 120-1048. This work involved high activity sources and significant dose gradients.

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (11 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) MG Telepole, SN 2.7.338, calibrated on March 22, 2020

(2) Fluke 451B, SN 2.7.526, calibrated on April 3, 2020

(3) Canberra Cronos-4, SN 2.12.99, calibrated on November 4, 2019

(4) Tennelec S5XLB, SN 2.12.56, calibrated on November 17, 2019

(5) MG AMP 100, SN 2.7.501, calibrated September 9, 2020

(6) Eberline AMS-4, SN 2.8.183, calibrated on August 3, 2020

(7) Apex High Purity Germanium Gamma Spectroscopy Detector, SN 3, calibrated on September 11, 2019

(8) Ludlum Model 12, SN 2.7.667, calibrated on August 19, 2020

(9) Canberra Fastscan Whole Body Counter, calibrated on August 8, 2019

(10) Ludlum Model L177, SN 2.7.541, calibrated on April 23, 2020

(11) Hi Range Containment Radiation Monitor, RE4596B, calibrated on March 24, 2020 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Radioactive Liquid Discharge Monitor, RE1770A

(2) Radioactive Gaseous Vent Stack Discharge Monitor, RE4598BA

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS09: Residual Heat Removal Systems (IP Section 02.08) ===

(1) July 1, 2019 through September 30, 2020

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) October 1, 2019 through September 30, 2020 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) July 1, 2019 through June 30, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) October 1, 2019 through September 30, 2020

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) January 1, 2019 through September 30, 2020 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) July 1, 2019 through June 30, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in communications systems that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) 2020 Inspection campaign as part of long-term monitoring for the shield building laminar cracking condition, EN-DP-01511

(2) Licensee effectiveness in maintaining minimum staffing levels

(3) Unintended power change during feedwater flow transmitter calibration

INSPECTION RESULTS

Failure to Maintain the Effectiveness of the Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.11] - 71114.04 Preparedness NCV 05000346/2020004-01 Challenge the Open/Closed Unknown The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.54(q)(2) for the licensees failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, on August 11, 2020, the Davis-Besse Nuclear Power Station experienced a phone outage that affected the licensees ability to receive calls from offsite. Since they could not receive calls and an alternate notification method was not available, they could not receive notifications per Emergency Action Level (EAL) HA 1.2. During the communications outage, the licensee did not maintain the emergency plan due to EAL HA 1.2 being rendered ineffective. The licensee did not establish compensatory actions until after inquiry from the Senior Resident Inspector.

The licensees corrective actions included:

• establishing compensatory measures

• updating their procedures to incorporate these actions

• entering this issue into their CAP as CR 2020-06343

Description:

On August 11, 2020, security staff at the Davis-Besse Nuclear Power Station discovered that offsite phone calls were not being received to onsite phone lines, including the NRC and Emergency Notification System phone lines. The unexpected outage began at approximately 1315 EDT and affected the inbound calling capability of all hardwired phones onsite. The outbound calling ability was not affected. The shift manager contacted the senior resident inspector (SRI) as a courtesy notification regarding the outage and provided a personal cell phone number. Upon receipt of the call, the SRI inquired about compensatory actions to allow the station to receive notifications from offsite entities, including the NRC Operations Center. The SRI noted that cell phone reception is deficient in the control room, making it an unreliable communication method for receiving notifications. Following this discussion, the licensee established compensatory measures to allow offsite communications with control room operators. The licensee informed the NRC Operations Center of the compensatory measures.

Corrective Actions: The licensee entered this issue into their corrective action program. The corrective actions included a revision to plant procedures governing equipment important to EP, and include appropriate compensatory actions in the event of a loss of phone lines.

Corrective Action References: CR-2020-06343; Site Phones Experiencing Issues Receiving Outside Calls

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee failed to maintain the effectiveness of the Davis-Besse emergency plan due to an ineffective EAL because plant operators were unable to receive timely notifications from offsite entities including the NRC Operations Center. The inspectors also determined that this was a performance deficiency within the licensees ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. In this case the licensee may not have received a notification of a hostile threat with enough time to implement the required procedures and declare an Alert prior to the event. Inspection manual chapter 0612 Appendix E example 4.i is similar to this issue.

Significance: The inspectors assessed the significance of the finding using Manual chapter 0609 Appendix B, Emergency Preparedness Significance Determination Process.

Appendix B table 5.4-1 and figure 5.4-1 provide significance determination examples for an ineffective EAL. Since the licensee would not have received notifications and thus, would not have been able to be declare an Alert under HA1.2 during the time that the phone lines were out, this finding screens as GREEN.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. This finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because the licensee did not stop and assess all vulnerabilities when presented with the unexpected loss of inbound communications capabilities. Specifically, the licensee failed to fully evaluate and manage the risk presented by the inability to declare an emergency under HA1.2 and enter the proper response procedures due to the loss of inbound communications capability.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Contrary to the above, the licensee failed to maintain the effectiveness of the emergency plan. Specifically, on August 11, 2020, the licensee failed to maintain a standard emergency classification and action level scheme as the site could not receive incoming phone calls and there were no compensatory actions in place to receive notifications that would meet the initiating condition of the sites emergency action level, HA 1.2.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: 2020 Inspection Campaign as Part of Long-Term Monitoring for the 71152 Shield Building Laminar Cracking Condition As part of the continued long-term monitoring of the shield building laminar cracking condition, the licensee subjected a sample of existing shield building core bores to visual examination as prescribed by licensee procedure EN-DP-01511, "Structures Monitoring."

One purpose of the core bore visual examinations conducted under this procedure was to determine if any growth or change in the nature of the cracks had occurred by measurement of crack width and comparison to historical values. In areas of identified laminar crack planar propagation, the licensee performed additional impulse response mapping to provide a relative indication of the extent of propagation.

During this in-depth review, the inspectors verified the status of the licensee's core bore visual examinations and their evaluations and corrective actions resulting from shield building laminar cracking not identified by previous visual examinations. The inspectors reviewed the licensee's plans for follow-on examinations and corrective actions that they had established to verify that the classification, prioritization, focus, and timeliness of these actions were commensurate with the safety significance of the issue.

During the 2020 periodic examination, the licensee identified additional growth in laminar crack width. In some instances, the measured laminar crack width exceeded the crack widths induced during testing previously performed at selected universities referenced in IR 05000346/2014008 to credit full reinforcement capacity in those areas. The licensee documented measured laminar crack widths that exceeded the testing limit in the corrective action program. The licensee observed laminar crack propagation at some locations based on visual examination. The inspectors verified that the licensee determined the extent of laminar crack growth by a combination of additional impulse response mapping and confirmatory concrete cores. As a result of the increased crack widths, the licensee performed operability evaluations of the shield building and determined that the shield building remained operable because the increased crack widths were localized in nature.

The inspectors reviewed the licensee's operability determinations, engineering analyses, and assessment that the shield building remained capable of performing its intended safety functions and identified no concerns. The inspectors identified no findings.

Observation: Trend of Communication System Issues 71152 The inspectors reviewed the licensees corrective action program for potential adverse trends involving communication systems that might be indicative of a more significant safety issue.

During the review period for this inspection sample, the inspectors noted several phone system problems challenged the licensee. The inspectors determined that though these issues were identified and corrected by the licensee, several could have negatively impacted plant safety. Specific examples associated with this trend included but were not limited to:

• During the third quarter of 2020, the licensee was notified by an offsite employee that he could not reach anyone onsite by landline. The licensee identified that incoming calls could not reach any onsite phones even though they maintained the ability to call out and to call numbers onsite. Operators notified the NRC Resident Inspectors of the condition and provided personal cell phone number of an operator. The inspectors requested an alternate method of communication. The licensee provided an acceptable alternate communication method for the NRC emergency operations center to reach the unit control room in response to inspector requests. This issue is discussed in more detail in section 71114.04 of this report (ineffective EAL HA1.2).

(CR 2020-06343 - August 11, 2020)

• While performing a monthly walkdown of the Joint Information Center, the licensee discovered three phone lines and two fax lines were nonfunctional.

(CR 2020-06399 - August 13, 2020)

• The licensee discovered that five plant cell phones were not able to receive incoming phone calls. (CR 2020-08623 - November 3, 2020)

• The licensee discovered that hardwired phone lines were once again not able to receive incoming phone calls. (CR 2020-08623 - November 7, 2020)

• The licensee discovered that several security cell phones were not working.

(CR 2020-09147 - November 30, 2020)

Individually, none of these examples may suggest an ongoing problem, but the inspectors determined that they may indicate a potential weakness when viewed in the aggregate.

Specifically, for these and other issues, the station may be missing the opportunity to identify and resolve deficiencies before the failure manifests, potentially resulting in an adverse impact on the plant. The inspectors provided these observations to the licensee. The inspectors will continue monitoring the licensees actions to identify and correct similar issues.

Observation: Inspector verification of licensee minimum staffing levels 71152 The inspectors reviewed the licensee's pandemic response plan, condition reports, staffing plans, and licensee use of NRC exemption from certain portions of part 26 and part 73.

The inspectors verified that the licensee maintained sufficient staffing levels in key positions (e.g., operations, emergency response organization, security). Additionally, the inspectors evaluated for deferred maintenance and other activities, use of overtime, and the use of NRC enforcement discretion.

The inspectors also assessed licensee preparations and planning for potential staffing challenges at the facility or in the conduct of activities related to operations, emergency response organization, and security.

No issues were identified.

Observation: Unintended Power Change during Feedwater Flow Transmitter 71152 Calibration On March 29, 2020, as operators were starting up the reactor following the refueling outage, the control room received feedwater flow deviation alarms, and the operators halted the power ascension. The licensee determined that the issue was caused by the loop 1 feedwater flow instrument channel being out of calibration. The licensee commenced a calibration of the instrument channel using the approved calibration procedure. While performing the calibration, a plant transient resulted, during which the control rods automatically inserted and resulted in a 2.5 percent power reduction. The operators halted the transient by placing rod control and reactor demand hand/auto stations in hand (manual operation), and the calibration was completed. The licensee conducted an apparent cause evaluation that identified the apparent cause: the procedure failed to include steps to direct the operators to place the rod control and reactor demand hand/auto stations in hand before conducting the calibration. The licensee also identified that contributing causes included failures to identify the procedural deficiency. The licensee previously performed the procedure during plant conditions when control rod movement was not possible.

Inspectors reviewed procedures, logs, and the apparent cause evaluation. The inspectors identified no findings, but the licensee's failure to identify this issue before the performance of this work activity may indicate a weakness related to work planning and job preparation. The licensee had multiple opportunities to identify the issue during work planning, pre-job brief, and other work preparation activities. The inspectors will continue to monitor the licensee's focus on addressing work planning and work management issues.

EXIT MEETINGS AND DEBRIEFS

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

• On January 28, 2021, the inspectors presented the integrated inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.

• On November 4, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. T. Brown, Site Vice President, and other members of the licensee staff.

• On December 9, 2020, the inspectors presented the radiation protection inspection results to Mr. M. Sidoti, Radiation Protection Support Manager, and other members of the licensee staff.

• On December 17, 2020, the inspectors presented the Davis-Besse Biennial Licensed Operator Requalification Program Inspection Results inspection results to Mr. D. Huey, Operations Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures DB-OP-06913 Seasonal Plant Preparation Checklist 39

RA-EP-02870 Station Isolation 07

71111.04 Corrective Action 2020-07572 Relay Failed as Found Testing for BF1141TD 10/29/2020

Documents

Drawings M-017A Diesel Generators 22

M-017B Diesel Generators Air Start 47

M-017C Fuel Oil 32

OS-003 High Pressure Injection System 25

Procedures DB-OP-06011 High Pressure Injection Operating Procedure 34

DB-OP-06013 Containment Spray System 27

DB-OP-06234 Emergency Feedwater System 07

DB-OP-06316 Diesel Generator Operating Procedure 63

71111.05 Fire Plans PFP-AB-115 ECCS Pump Room 1-2 Room 115 06

PFP-AB-208 No. 1 Mechanical Penetration Room and Pipe Way Area 08

Rooms 202, 208, and 208DC

PFP-AB-505 Control Room and Adjacent Support Rooms 09

PFP-IS-52 Service Water Pump Room 04

71111.06 Drawings A-2111 Barrier Penetration Drawing Intake Structure 0

Procedures NORM-ER-3208 Penetrations and Barriers 1

Work Orders 200720548 ECCS Sump 1-2 Pump B 08/25/2020

71111.11A Miscellaneous Davis-Besse Annual Licensed Operator Requalification 12/14/2020

Program Results Information

71111.11B Corrective Action 2018-10895 Ops Training- Potential Exam Security Event, Cell Phone 12/12/2018

Documents 2019-03972 Negative Performance Trend with Respect to EAL 04/30/2019

Classification

20-02741 Unexpected Rod Insertion During FW Flow Calibration 03/29/2020

20-08032 Senior Reactor Operator May Have Not Have Met the 10/16/2020

Minimum Watch Standing Requirements

20-08446 ILT Exam Security - SCANNER 10/26/2020

ATL-2019-0015- Effectiveness Evaluation for EAL Performance Gap 10/19/2020

ATA-1 l

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action 2020-09464 2020 NRC IP 71111.11 Issue of Concern; the Amount of 12/15/2020

Documents Overlap Between the 2018 and 2020 Written Exams.

Resulting from

Inspection

Miscellaneous 2020 CT List Davis-Besse Licensed Operator Critical Task List 12/03/2020

20 DB Biennial 2020 Davis-Besse Biennial Written Exam 1 09/29/2020

Written Exam 1

20 DB Sample 2020 Davis-Besse Examination Sample Plan and Outlines Various

Plan

20 JPM Crew 1 2020 Davis-Besse Annual Operating Test Job Performance 11/30/2020

Measures Crew1 (001, 045, 227, 285, 308)

20 JPM Crew 2 2020 Davis-Besse Annual Operating Test Job Performance 10/19/2020

Measures Crew 2 (027, 166, 120, 283, 193)

20 Scn Crew 1 2020 Davis-Besse Annual Operating Test Crew 1 Scenarios 11/30/2020

(S109R14, S132R8, S137R5)

20 Scn Crew 5 2020 Davis-Besse Annual Operating Test Crew 5 Scenario 11/09/2020

(S134R12)

CREW Scenarios #1 - #3: for Crew 1 12/02/2020

EVALUATION

ANNUAL EXAM

FORM (from

NOBP-TR-1112)

CYCLE 22 TAB Simulator Transient Test 11/23/2020

MANUAL REACTOR TRIP

DB 2020 Biennial LORT Biennial Written Exam Failed by an Applicant 08/27/2020

Exam 2

DB 2020 Biennial LORT Remedial Biennial Written Exam Passed by an 11/18/2020

Exam 3 Applicant

DBBP-TRAN- Simulator Scenario Based Testing Documentation 07/13/2020

21 for Scenario

ORQ EPE S101

Procedures DBBP-OPS-1013 Control of Time Critical Actions 2

DBBP-TRAN- Conduct and Development of Job Performance Measures 10

Inspection Type Designation Description or Title Revision or

Procedure Date

0501

NOP-TR-1010 Requal Exam Development and Administration 4

71111.12 Corrective Action 2017-10018 SW1357 Failed to Close During Air Drop Test due to 10/01/2017

Documents SV1357B Continuously Venting

2018-02603 SW1357, CAC 2 Service Water Outlet, Would Not Stroke 03/18/2018

Closed during Test

20-01255 Difficulty Installing Split Ring on New Cartridge Style Seals 02/17/2020

for the Decay Heat Pump

20-01305 P42-2, Decay Heat Pump 2, Seal Leakage 02/19/2020

20-01363 BACC: Decay Heat Pump 2 Inboard Seal Package Leakage 02/21/2020

DPM

20-01382 Oil Sample on Decay Heat Pump 2 O.B. Pump Bearing 02/21/2020

Grayish in Color

20-01458 Decay Heat Pump 2 Mechanical Seal Replacement Post Job 02/25/2020

Comments

20-01909 1R21 BACC Boric Acid Build Up on 2 Decay Heat Pump 03/07/2020

Inboard Pump Seal

20-02616 Minor Oil Leakage from Decay Heat/Low Pressure Injection 03/25/2020

Pump 2 Outboard Bearing Inside Cover

20-02856 Vibration Point on Decay Heat Pump 1 is in the Alert Range 04/01/2020

20-03031 Required Actions Not Completed for HPI Pump 2 D-H 04/09/2020

Vibrations in Alert Range from 1R21 Comprehensive Test

20-05230 SFAS Channel 4 BWST Level Erratic 06/24/2020

20-06179 Suction Pressure Spike Following LPI Pump 2 Jog 08/05/2020

20-06619 SW1357 Would Not Stroke Closed 08/23/2020

20-07101 Alpha Level 3 Contamination Found Inside RCS Piping 09/11/2020

20-07724 EDG FOST 1 Internal Oxidation at Top of Tank 10/06/2020

20-07821 EDG Week Tank 1 Refill Delayed Retest and Operability 10/08/2020

Determination

20-07826 EDG 1 FOST Fuel Found with Water/Sediment Post 10/08/2020

Maintenance

20-07844 High Pressure at P12987 (1 Emergency Diesel Generator 10/09/2020

South Air Start)

20-08296 As Found Thrust on P42-2 Found Outside the Procedural 10/26/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Specifications in DB-MM-09174

20-08671 Pitting Noted n EDG 1-1 HX E10-1 Tubing 11/09/2020

20-08678 As-Found Visual Inspection for Piston Oil Piping was 11/10/2020

Discovered Out Alignment

20-08705 EDG 1 Jacket Water Hose Replacement Parts Not Correct 11/11/2020

Size

20-08740 EDG 1 Exhaust Temp Thermocouples Read Outside of 11/11/2020

Required Value

20-08742 EDG 1 Outage Critical Path Delay 11/11/2020

20-08743 EDG 1 Failed the Overspeed Trip Test 11/11/2020

20-08826 Control Room Annunciator 1-1-K EDG 2 Trouble Failed to 11/15/2020

Alarm

20-09073 Old Removed EDG 1 Speed Switch Signs of Overheating 11/25/2020

Corrective Action 2020-09755 Maintenance Rule Program Missed Condition Monitoring 12/30/2020

Documents Failure CR in Periodic Assessment Cycle 21

Resulting from

Inspection

Miscellaneous MRPM Maintenance Rule Program Manual 38

Procedures NOBP-LP-2001 Self-Assessment and Benchmarking 31

NOP-ER-3004 Maintenance Rule Program 6

Self-Assessments ATA-2020-9407 Cycle 21 Periodic Maintenance Effectiveness Assessment Cycle 21

Report (PMEAR)

SA-BN-2018- Cycle 20 Periodic Maintenance Effectiveness Assessment Cycle 20

1138 Report (PMEAR)

Work Orders 200700254 PM 8878 GK5-1 Check Slip Ring Runout 11/09/2020

200709265 Decay Heat Pump Outboard Bearing Housing Interior 10/26/2020

Coating

200755711 Replace Decay Heat Pump Seals with Cartridge Type Seals 02/16/2020

200759589 PM 10851 Engine Analysis on EDG 1 11/09/2020

200766360 PM 0723 K5-1 24-Month Check EDG 1 11/08/2020

200767926 Emergency Diesel Generator 1 Static Exercise 11/09/2020

200771879 Diesel Generator and Auxiliary 11/08/2020

200772284 EDG 1 Overspeed Trip Test 11/08/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

200772284 Emergency Diesel Generator 1 Overspeed Trip Test 11/08/2002

200784743 Recommendations from EDG 1 Engine Analysis 11/09/2020

200784759 Borated Water Storage Tank Level SFAS Channel 4 Level 06/24/2020

TA

200826241 Borated Water Storage Tank Level SFAS Channel 4 Level 06/24/2020

TA

71111.15 Corrective Action 2012-18810 DB-SP-03161 AF6451 Closed Voltage Out of Spec 12/02/2012

Documents 2020-04688 RCP 2-2 Seal Return Flow High 05/31/2020

20-05473 AF6451 Close mVdc Does Not Meet the Minimum Value 07/05/2020

Specified in Test Procedure During Minimal Time Period of

Power Being Applied

20-05932 Incorrect Comparison of BWST Concentration to Upper Tech 07/24/2020

Spec Limit

20-09055 Storm Damage to Shield Building Scaffold 11/24/2020

G201-2008- Boron Concentrations Do Not Include Sample Accuracy 03/11/2008

36648

Procedures DBBP-OPS-0011 Protected Equipment Posting 14

Work Orders 200683357 Auxiliary Feedpumps and Piping 09/09/2020

200684824 Auxiliary Feedpump 1 to Steam Generator 09/09/2020

200714135 Auxiliary Feedwater Pump Turbines 09/09/2020

200765006 AFW Train 1 Valve Testing 09/09/2020

71111.19 Procedures DB-MM-09180 Component Cooling Water Pump Maintenance 06

DB-PF-03572 Component Cooling Water Pump 1 Baseline Test 06

DB-PF-03572 Component Cooling Water Pump 1 Baseline Test 07

Work Orders 200683357 Motor for AFP 1 Discharge to SG 1 09/09/2020

200684824 Auxiliary Feed Pump 1-1 to SG 1-2 Stop Valve 09/09/2020

200714135 Main Steam Line 1 to AFPT 1 Isolation Valve Motor 09/09/2020

200765030 AFP 1 Quarterly Test 09/08/2020

200770852 Decay Heat Train 2 Pump and Valve Test 12/26/2020

200770857 Emergency Feedwater Pump Monthly Test 10/29/2020

200772760 Monthly PMT Order 11/18/2020

200775489 Emergency CR RM CLR FAN 4 12/03/2020

200776052 ECCS Room 105 Cooler Fan 4 Motor Refurbish 12/04/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

200837784 CCW Pump 1 Quarterly Test 11/23/2020

71111.22 Procedures DB-SS-04201 Emergency Feedwater Pump Quarterly Test 05

Work Orders 200764576 MTSV Main Turbine Stop Valves Test 12/05/2020

200764577 Main Turbine Control Valve 12/05/2020

200764578 Main Turbine CIV Test 12/05/2020

200772722 EDG 2 184 Day Test 11/25/2020

200773169 CRD Exercise Test 12/05/2020

200774425 DH14B Mech Stop POS Test 11/30/2020

200840154 Quarterly PMT Test 11/18/2020

71114.04 Corrective Action 2019-08756 Need to Perform 50.54(q) Reviews on Three Procedures 10/22/2019

Documents That Were Revised and Made Effective Without These

Reviews

20-06343 Site Phones Experiencing Issues Receiving Outside Calls 08/11/2020

Miscellaneous DB-2019-022-01 10 CFR 50.54(q)(2) Analysis 11/15/2019

DB-2019-026-00 10 CFR 50.54(q)(3) Screen/Evaluation 10/22/2019

DBRM-EMER- Equipment Important to Emergency Response 19

5003

DBRM-EMER- Equipment Important to Emergency Response 20

5003

NOBP-OP-1015 Event Notifications 17

71124.01 ALARA Plans 120-1048 Repair of Gamma Irradiator Shepherd Model 89 1

Radiation Work 120-1048 Repair and Maintenance of the Shepherd Model 89 1

Permits (RWPs)

Work Orders 200833345 Source Rod of JL Shepherd Model 89 Calibrator has 11/17/2020

Become Detached

71124.05 Calibration Canberra Fastscan Whole Body Counter Calibration 08/08/2019

Records DB-MI3401-001 Radioactive Liquid Discharge Monitor, RE1770A, Calibration 06/17/2019

DB-MI3408-001 Hi Range Containment Radiation Monitor, RE4596B, 03/14/2020

Calibration

DB-MI3413-001 Radioactive Gaseous Vent Stack Discharge Monitor, 05/14/2019

RE4598BA, Calibration

RE4596B Hi Range Containment Radiation Monitor Calibration 03/24/2020

SN 2.12.56 Tennelec S5XLB Calibration 11/17/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

SN 2.12.99 Canberra Cronos-4 Calibration 11/04/2019

SN 2.7.338 MG Telepole Calibration 03/22/2020

SN 2.7.501 MG AMP 100 Calibration 09/09/2020

SN 2.7.526 Fluke 451B Calibration 04/03/2020

SN 2.7.541 Ludlum Model 177 Calibration 04/23/2020

SN 2.7.667 Ludlum Model 12 Calibration 08/19/2020

SN 2.8.183 Eberline AMS-4 Calibration 08/03/2020

SN Number 3 Apex High Purity Germanium Gamma Spectroscopy 09/11/2019

Detector Calibration

Corrective Action 2018-08094 JL Shepherd Model 89 Requires Repair 10/12/2020

Documents 2019-09708 Shepherd Model 89 Gamma Irradiator Failure 11/16/2019

2019-09708 Shepherd Model 89 Gamma Irradiator Failure 11/16/2019

20-00942 Incorrect Alarm Setpoints in RE8406, Miscellaneous Waste 02/07/2020

Evaporator Room Area Monitor

20-01010 Initial Part 21 Notification from Fluke Regarding to 02/10/2020

Compliance Gap on Nickel Seal Rings for Victoreen CTMT

High Range (Model 977) Ion Chamber Area Radiation

Monitors

20-01025 Telepole 2.7.343 Taken Out of Service 02/20/2020

20-04503 JL Shepherd 89 Gamma Irradiator Failure 05/24/2020

20-05419 10 CFR 21 Notice of Deviation for Victoreen Model 876A-1, 07/01/2020

P/N 3649559, Radiation Monitor

20-06066 Stop Work Criteria for Shepherd was Met 07/30/2020

20-06730 Telepole 2.7.339 Failed Daily Check 08/26/2020

71151 Corrective Action 2019-10166 Elevated Dose Rates Identified in Dry Shielded Container 12/05/2019

Documents Drain Port

Miscellaneous Cycle 21 Chemistry Dose Equivalent Iodine Data Undated

Cycle 22 Chemistry Dose Equivalent Iodine Data Undated

Radiological Effluent Dose Summary Information from Various

07/01/2019 through 06/30/2020.

71152 Corrective Action 2016-07491 Unit Load Demand Transferred to Manual Due to Feedwater 06/07/2016

Documents Flow Divergence

2018-09568 Integrated Control System Unit Load Demand in Alarm Due 10/30/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

to Loop 2 Feedwater Flow Deviation

20-02414 Re-Evaluate Medical Screening of Ill Personnel for 03/19/2020

Departments and Health Services

20-02733 Unit Load Demand Transferred to Manual Due to Feedwater 03/29/2020

Flow Divergence

20-02741 Unexpected Rod Insertion During FW Flow Calibration 03/29/2020

20-02818 Hospital Inventories not Completed for 1st Quarter 2020 per 03/31/2020

RA-EP-00600 due to Covid-19

20-02854 Monthly JIC Walkdown/RA-EP-04010 Quarterly 04/01/2020

Communication Test

20-03386 Concern with How Range Masks are Cleaned/Disinfected 04/18/2020

20-03473 Recommendation for Hand Search PPE Requirements 04/21/2020

20-05090 Shield Building Inspection Results - Shoulders 3, 4, 5, 6, 8, 06/16/2020

and 11

20-05091 Shield Building Inspection Results - Shoulder 16 06/16/2020

20-05388 Telephone Lines Out of Service at Lindsey Emergency 06/30/2020

Response Facility

20-05400 New Alternate Davis-Besse 4-Way Phone Number Did Dot 07/01/2020

Work

20-05524 Telephone Lines Out of Service at Lindsey Emergency 07/07/2020

Response Facility

20-05546 Unsafe Mandatory Wearing of Face Masks 07/08/2020

20-05926 Knowledge and Ownership of Equipment Previously 07/24/2020

Supported by FirstEnergy IT

20-06004 Shield Building Inspection Results - Shoulder 1 07/28/2020

20-06019 Shield Building Inspection Results - Shoulder 2 07/29/2020

20-06055 Shield Building Inspection Results - Shoulder 15 07/30/2020

20-06224 First Half 2020 IPA Site Gap Identified for Equipment 08/06/2020

Reliability

20-06280 Evaluate the Effectiveness of Curtain on PSF Rooftop 08/09/2020

20-06343 Site Phones Experiencing Issues Receiving Outside Calls 08/11/2020

20-06399 Phones/Fax Lines Not Working at Joint Information Center 08/13/2020

During Monthly Walkdown

20-06481 Safety Condition Report Social Distancing Separation Not 08/17/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

being Maintained

20-06552 Covid-19 PHE Related Violation of 10 CFR 73 Appendix B, 08/20/2020

VI.C.3.(I)(1) Subject to NRC Enforcement Guidance

Memorandum 20-002

20-07727 Failure Analysis Report - 4 Control Valve Intermittently 10/06/2020

Changes Position During Transfers of ICS SG/RX Demand

Station from Manual to Auto

20-07764 EP Drill: Network and Miscellaneous Technical Issues 10/07/2020

During 10/06/2020 ERO Drill

20-07776 Post 1R21 Code Safety Valve RC13A As-Found Setpoint 10/07/2020

Tested High

20-07779 EP Drill: EOF Fax Did Not Receive Messages During 10/07/2020

10/06/2020 Drill

20-07834 Sprinkler Guard Hanging Improperly 10/08/2020

20-07840 Revised Reactor Vessel P-T Curves Limited to 43 EPY 10/09/2020

20-07851 Shield Building Inspection Results - Shoulder 13 10/09/2020

20-07929 Shield Building Inspection Results - Shoulder 14 10/13/2020

20-08032 Potential Licensed Operator Watch Standing Requirements 10/16/2020

Not Met

20-08039 Foreign Material/Obstruction Identified at the Bottom of the 10/17/2020

West-Most Drainpipe of EDG 1 FOST (FME Unrecovered)

20-08070 Post 4 Floor Degradation 10/19/2020

20-08076 Contraband Identified at Entrance 10/19/2020

20-08088 Hydrogen Orbisphere Will Not Communicate with Computer 10/19/2020

Preventing Instrument Calibration

20-08096 Received Unexpected Annunciator Alarm 5-1A CRD System 10/19/2020

Fault

20-08135 MS107A Static Test Not Performed 10/20/2020

20-08152 Security Radio Degradation 10/21/2020

20-08169 RPS Channel 2 Scaled Difference Amplifier Found Out of 10/21/2020

Tolerance

20-08211 Conduit to MS100-1 is Separated 10/23/2020

20-08215 Electrical Manhole Inspection Sump Pump Failures 10/23/2020

20-08222 Startup Transformer 01 Trouble 10/23/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

20-08300 DB-FP-04035 Fire Suppression System 5-Year Test Not 10/26/2020

Completed as Required

20-08443 Emergency Plan Drills Not Conducted Due to Pandemic 10/30/2020

20-08519 Security B5b Phones Not Working as Designed 11/03/2020

20-08623 Site Phones Experiencing Issues Receiving Outside Calls 11/07/2020

20-09012 Inadequate Covid-19 prevention and Planning 11/21/2020

20-09036 Non-CDC Approved Disinfectant 11/23/2020

20-09147 CAS/SAS/SSS Cell Phone Failure Noted During 11/30/2020

Computerized Automated Notification System Weekly Test

(CANS)

Miscellaneous Energy Harbor Pandemic Health Emergency Response Plan 2

Nuclear Generation Pandemic Health Emergency Response 2

Plan

DBRM-EMER- Davis-Besse Emergency Action Level Basis Document 09

1500A

NDE Reports Construction 2020 Shield Building Inspections 05/26/2020 -

Technology 10/09/2020

Laboratories

(CTLGroup)

Project 263453

Procedures EN-DP-01511 Structures Monitoring 11

Work Orders 200743529 Steam Room Work Online 05/26/2020

200743529 Shield Building Long Term Monitoring for the Laminar 10/27/2020

Cracking Condition Under EN-DP-01511, Structures

Monitoring - 2020 Inspection Campaign

24