IR 05000346/2019003

Integrated Inspection Report 05000346/2019003

ML19317E451
Person / Time
Site:	Davis Besse
Issue date:	11/12/2019
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
IR 2019003
Download: ML19317E451 (25)

Text

ber 12, 2019

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000346/2019003

Dear Mr. Bezilla:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Davis-Besse Nuclear Power Station. On October 8, 2019, 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 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.

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. 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/

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: 05000346/2019003 Enterprise Identifier: I-2019-003-0064 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Inspection Dates: July 01, 2019 to September 30, 2019 Inspectors: J. Cassidy, Senior Health Physicist T. Go, Health Physicist J. Harvey, Resident Inspector D. Mills, Senior Resident Inspector V. Myers, Senior Health Physicist J. Rutkowski, Project Engineer 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 Recognize and Correct Fisher Controls Butterfly Valve Taper Pin Defects Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.12 Systems NCV 05000346/2019003-01 Operating Open/Closed Experience The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings for the licensees failure to prescribe instructions and procedures appropriate to the circumstances for an activity affecting quality. Specifically, the licensee failed to accomplish repairs to a safety-related butterfly valve in accordance with appropriate instructions and procedures. The inspectors identified that actions taken by the licensee to address loose taper pins associated with the safety related component cooling water system were performed without appropriate instructions and procedures that incorporated appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000346/2018-001-00 LER 2019-001-00 for Davis- 71153 Closed Besse, Unit 1, Borated Water Storage Tank Level Transmitter Out of Tolerance Due to Reaching End of Expected Life

PLANT STATUS

The unit began the inspection period operating at full power. On September 7, 2019, during scheduled testing of the main turbine stop valves, the unit tripped from 95 percent power. The licensee determined that the cause of the unit trip was a faulty fast-acting solenoid valve in the main turbine electrohydraulic control system which caused a second stop valve to close while the number two valve was closing as planned per the test. The plant operators started up the unit on September 10, 2019. The unit reached full power operations on September 11. The licensee continued to operate the unit at or near full power through the remainder of the inspection period.

On April 25, 2018, FirstEnergy Solutions (FES) / FirstEnergy Nuclear Operating Company (FENOC) notified the U.S. Nuclear Regulatory Commission (NRC) that they intend to shut down all four of their operating nuclear power plants (ADAMS Accession Number ML18115A007). On March 21, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and FENOC filed for bankruptcy. On July 26, 2019, FES/FENOC submitted a letter to the NRC withdrawing the April 25, 2018, certification of permanent cessation of power operations for Davis-Besse Nuclear Power Station and Perry Nuclear Power Plant (ADAMS Accession Number ML19207A097). The NRC continues to maintain focus on public health and safety and the protection of the environment. This will include a continuous evaluation by inspectors to determine whether the licensee's financial condition is impacting safe operation of the plant.

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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection External Flooding Sample (IP Section 03.04)

(1) The inspectors evaluated readiness to cope with external flooding for the following areas:

• Plant site and service water tunnel flooding due to lake wave run-up and local heavy precipitation

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Low Pressure Injection 2 while Low Pressure Injection 1 was inoperable due to oil sample tube stuck in the outboard pump bearing sump during the week ending July 27, 2019

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) Fire Brigade drill involving simulated fire at Startup Transformer X01 during the week ending August 3, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Emergency Feedwater Facility, Fire area EF, on September 18, 2019

(2) Service Water Pipe Tunnel, Fire area BG, on September 18, 2019

(3) Electrical Penetration Room 1, Fire area DG, on September 17, 2019

(4) Control Room and Adjacent Support Rooms, Fire area FF, on September 20, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Auxiliary Building Rooms 300, 304, 310, 312, 313, 314, 404, and 411 due to roof loading of rain or snow and a feedwater line break

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) The inspectors observed and evaluated licensed operator performance in the Control Room during the performance of control rod exercising, turbine valve testing, reactor trip, Mode 3 operation, reactor startup, and reactor power ascension during the week ending September 14, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator performance during the quarterly emergency response integrated drill on September 17, 2019

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Emergent maintenance on Low Pressure Injection Pump 1 requiring disassembly of bearing housing to remove foreign material in the outboard bearing during the week ending July 27, 2019

(2) Reactor Protection System calibration during the week ending July 27, 2019

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Replacement of Component Cooling Water Heat Exchanger 2 outlet isolation valve, Service Water 38, during the week ending August 31, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Emergent maintenance on Low Pressure Injection Pump 1 due to foreign material in the outboard bearing and planned testing during the week ending July 27, 2019

(2) Control Room Emergency Air Temperature Control System out of service for planned maintenance during the week ending August 3, 2019

(3) Replacement of Service Water 38, Component Cooling Water Heat Exchanger 2 Outlet Isolation Valve during the week ending August 31, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Intake canal sediment buildup, CR 2019-02869

(2) Component Cooling Water Heat Exchanger 2 outlet isolation valve leaks by in the closed position, CR 2019-00817

(3) Core Flood Tank 1 fill and pressurization isolation valve leak by, CR 2019-06314

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Reactor Protection System Channel 1 calibration of overpower, power/imbalance/flow, and power/pumps trip functions after flux/delta flux/flow bistable replacement during the week ending July 20, 2019

(2) Reactor Protection System/Safety Features Actuation System Channel 2 Containment Pressure Switches Isolation Valve after planned work during the week ending July 27, 2019

(3) Reactor Trip Breaker response time test after breaker swap of Control Rod Drive System primary trip breaker 2 during the week ending August 31, 2019

(4) Electro Hydraulic turbine control system and Anticipatory Reactor Trip System functional testing following reactor trip and maintenance activities during the week ending September 14, 2019

(5) Station Blackout Diesel testing after replacement of the speed selector switch during the week ending July 13, 2019

(6) Component Cooling Water 2 after replacement of Component Cooling Water Heat Exchanger 2 Outlet Isolation Valve during the week ending August 31, 2019

(7) Station Emergency Ventilation System Train 1 following replacement of Pressure Differential Transmitter PDT5000 during the week ending July 27, 2019

(8) Reactor Protection System Channel 3 after replacement of Channel 3 power supplies during the week ending September 21, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated forced outage activities from September 7 to September 10, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) Channel functional test of Steam Feed Rupture Control System Actuation Channel 1 logic for Mode 1 during the week ending July 27, 2019

(2) Low Pressure Injection/Decay Heat Pump 1 quarterly surveillance test during the week ending July 27, 2019

(3) Control Rod exercising and Turbine Valve testing during the week ending

September 14, 2019 FLEX Testing (IP Section 03.02) (1 Sample)

(1) Emergency Feedwater Pump quarterly surveillance testing following scheduled preventive maintenance during the week ending September 21, 2019

==71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Observation of licensee emergency response organization during the integrated drill on September 17,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walk Downs and Observations (IP Section 02.01)==

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1) Station Vent Normal Range Radiation Monitors Waste Gas System Outlet Radiation Monitors Miscellaneous Waste Radiation Monitors Clean Waste Discharge Radiation Monitors Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

(1) Gaseous - RE-4598 - Station Vent Normal Range Radiation Monitors Liquid - RE-1822 - Waste Gas System Outlet Radiation Monitors Liquid - RE-1878 - Miscellaneous Waste Radiation Monitors Liquid - RE-1770 - Clean Waste Discharge Radiation Monitors

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following:

(1) Radioactive Effluent Sampling and Analysis Activities

• Station Vent Weekly Particulate, Iodine, Noble Gas, and Tritium Effluent Discharges

• 19-M0022G

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

(1) Work Order 200709102 - Emergency Ventilation Systems (EVS) TRAIN 1 Refueling Interval or Special Test Work Order 200621820 - Emergency Ventilation Systems (EVS) TRAIN 2 Refueling Interval or Special Test

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed the following to asses public dose:

(1) Liquid and Gaseous Discharge Permits

• [List 1-3 of each type of permit reviewed (i.e. liquid discharge permit and gaseous discharge permit)]

• Gaseous, 19-0022G

• Gaseous, 18-B0006G

• Liquid, 18-B0024L

• Liquid, 18-B0023L Annual Land Use Census Reports

• Completed October 2018

• Completed October 2017 Abnormal Gaseous or Liquid Tank Discharges

• None were available for review during this inspection]

71124.07 - Radiological Environmental Monitoring Program Site Inspection (IP Section 02.01)

The inspectors evaluated the radiological environmental monitoring program implementation.

(1) The inspectors reviewed the following:

Walkdowns, Calibrations, and Maintenance Record Review

• T-1; Air Sampler Located at Site Boundary 0.6 mile ENE of the Station

• T-2; Air Sampler Located at Site Boundary 0.9 mile E of the Station

• T-3; Air Sampler Located at Site Boundary 1.4 miles ESE of the Station

• T-9; Air Sampler Located at Oak Harbor, OH; 6.8 miles SW of the Station

• T-27; Air Sampler Located at Crane Creek 5.3 miles WNW of the Station

• T-1; Thermoluminescent Dosimeter (TLD) Monitoring Station Located at Site Boundary 0.6 mile ENE of the Station

• T-2; TLD Monitoring Station Located at Site Boundary 0.9 mile E of the Station

• T-3; TLD Monitoring Station Located at Site Boundary 1.4 miles ESE of the Station

• T-27; TLD Monitoring Station Located at Crane Creek 5.3 miles ENE of the Station Environmental Sample Collections and Preparation Observation

• T-3; Untreated Surface Water Location; Site Boundary 1.4 miles ESE of the Station

• T-19; Broad-leaf Vegetation and Fruit Locations; L. Bowyer, 1.0 mile W of the Station

• T-22B; Treated Surface Water Location at Carrol Water Treatment Plant

• T-11; Treated Surface Water Location at Ottawa County Regional Water Intake Facility; 9.5 miles SE of the Station Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement

• During the walk-down, Location T-27 Air Sampler ODCM Control Location was found that Leaves near the Air Inlet Pathway Interfering with the Air Sampling Function and T-9 Air Sampler was found not Running for a week

• REMP Air Monitor Failure Trend from April 2018 through February 2019; REMP Air Monitors tripped; Manufacturer replaced defective motors

• Milk Sampling was eliminated due to unavailability this including the Control Sample Location, licensee replaced the unavailability with Broad Leaves Vegetation grown in the highest D/Q.

Sampling Program for the Potential of Licensed Material Entering Groundwater

• April 2018; a pipe containing Borated Water Storage Tank water found Leaking from Flange Connection onto a Concrete Pad and Reaching adjacent Area of Soil. Soil samples identified to contain mixed a Activation Products; however 2018 Groundwater Well Sample results and analysis did not Indicate a potential impact to the Groundwater to the surrounding Protected Area

• February 2015 Groundwater Monitoring Wells indicated that seven wells had higher than normal Tritium Concentrations, this was caused by Primary Water storage Tank construction activities Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)

(1) Inspectors Evaluated of Discharges from onsite water bodies that could have the potential to contain radioactivity and properly accounted all discharges.

OTHER ACTIVITIES - BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) July 1, 2018 - June 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) July 1, 2018 - June 30, 2019 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) Unit 1 October 2018 - June 2019 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) October 2018 - June 2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends related to design drawing inaccuracy

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000346 (ADAMS accession: ML19050A166), Borated Water Storage Tank Level Transmitter Out of Tolerance due to Reaching End of Expected Life

Personnel Performance (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated licensee performance during and following the unexpected reactor trip on September 7,

INSPECTION RESULTS

Failure to Recognize and Correct Fisher Controls Butterfly Valve Taper Pin Defects Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.12 Systems NCV 05000346/2019003-01 Operating Open/Closed Experience The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings for the licensees failure to prescribe instructions and procedures appropriate to the circumstances for an activity affecting quality. Specifically, the licensee failed to accomplish repairs to a safety-related butterfly valve in accordance with appropriate instructions and procedures. The inspectors identified that actions taken by the licensee to address loose taper pins associated with the safety related component cooling water system were performed without appropriate instructions and procedures that incorporated appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Description:

On June 4, 2019, the licensee was preparing to replace the Component Cooling Water heat exchanger #2 outlet isolation butterfly valve with a new valve received from the vendor, Fisher Controls International LLC, in 2017. Prior to installation the inspectors questioned the licensee as to why one of the three taper pins holding the disk to the butterfly appeared to be loose. In response to the inspectors question, the licensee performed repairs by resetting and staking the pins in accordance with mechanical maintenance procedure DB-MM-09317 Fisher type 9100 butterfly control valve maintenance. This resulted in the ends of the taper pins being flush with the surface of the disk.

Information Notice 2005-23, and Part 21 report 2005-42 described the issue of loose taper pins, with corrective actions to include the proper seating and staking of the pins. These references state that degradation of butterfly valves supplied by Fisher Controls and other manufacturers has occurred during plant operation as a result of the loss of taper pins used to connect the valve disc to stem. The degradation can involve leakage and affect valve operation. Taper pins lost from butterfly valves can also interfere with the operation of other plant components in fluid systems. The vendor manual details the requirement for the pin ends to be below the surface of the disk before peening. After review of the licensees actions taken to repair the valve, the inspectors noted that the pins were improperly set and staked and brought the concern to the licensee. Additionally, the inspectors identified the mechanical maintenance procedure, DB-MM-09317, included the vendor manual as a reference, but did not incorporate the vendor manual quantitative criteria ensuring the ends of the pins were below the surface of the disk before peening.

The licensee returned the valve to the vendor, who determined the pins were in fact improperly installed. This resulted in NRC Event Notification 54238, Part 21 report 2019-24, and Fisher (vendor) Information Notice 2019-01, which revised and clarified the steps necessary to achieve the quantitative criteria that the large end of the taper pins be driven below the surrounding surface and then the surrounding material peened over the heads.

Corrective Actions: The licensee entered this issue into their corrective action program. The Vendor, Fisher Controls International, submitted a Part 21 report (2019-21) detailing the issue. Additionally, mechanical maintenance procedure DB-MM-09317 Fisher type 9100 butterfly control valve maintenance was revised to include the updated vendor guidance regarding pin setting and peening.

Corrective Action References: CRs 2019-04914, 2019-05843, 2019-07152, 2019-06157, and 2019-07139

Performance Assessment:

Performance Deficiency: The inspectors determined that performing work on safety-related equipment without appropriate instructions and appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished was a performance deficiency that was reasonably within the licensees ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The performance deficiency was more than minor because if left uncorrected, it has the potential to become a more significant safety concern. Specifically, attempting to repair and place into service the valve without prescribed instructions or procedures incorporating vendor recommended corrective actions would not have ensured the capability of the Component Cooling Water system to provide its mitigating function. Additionally, if left uncorrected, this performance deficiency could have led to failures in other safety-related fluid systems.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The finding had a cross-cutting aspect in the area of Problem identification and Resolution, cross-cutting area of Operating Experience, because the licensee did not systematically and effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner. Specifically, the licensee did not effectively evaluate and update the mechanical maintenance procedure even though the vendor manual was incorporated into it as a reference and included the necessary information. Additionally, there were multiple references available including recently updated vendor guidance, NRC Information Notice 2005-23, Part 21 report 2005-42 and other external operating experience. (P.5)

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, in August 2019, the licensee failed to include in instructions and procedures that include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, mechanical maintenance procedure DB-MM-09317 failed to provide appropriate criteria to ensure butterfly valve taper pins were seated correctly.

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

Observation: Semi-Annual Trend Review of Condition Reports Documenting 71152 Discovered Issues with Existing design Drawings The inspectors reviewed the licensee's corrective action program searching for condition reports that were coded with a cause code of CM.3 (Changes to plant configuration, design and licensing bases are evaluated, controlled, tested and implemented while consistency is maintained among the physical plant configuration, design and licensing requirements and the documented plant configuration). The inspectors were aware that some planned and scheduled plant work was held up because of differences between the physical plant and existing drawings that showed the current existing as-built plant. The inspectors wanted to determine the extent of the issue and licensee's actions to address any significant issues.

The inspectors' search encompassed condition reports initiated in 2019 to approximately September 1, 2019. The search identified seven condition reports that involved planned work where discrepancies were found between plant installed configurations and plant drawings.

The plant has four drawing categories/levels with each level reflecting the relative importance to safe and efficient operation. Level 1 drawings are used by plant operators and others to ensure safe and reliable operations. These drawings, that are in the operations Control Room, must be updated to reflect as-built configuration before a modified structure, system, or component is placed into service. Level 2 drawings are those that are critical to safe and effective operation, maintenance, and engineering but are not required in the Control Room.

Changes can be posted to these drawings with a Drawing Update Notice (DUN) but must have those changes incorporated in the drawing within 90 days of the third change being posted against the drawing.

Level 3 drawing are those deemed not critical to day-to-day operation, maintenance, and engineering of the plant but generally depict the as-designed plant and are retained for historical or regulatory purposes. DUNs are posted to the drawing but are not required to be incorporated in the drawing. Level 4 drawings depict a past configuration and do not need to be updated to display current plant configuration.

As of the end of August 2019, there 443 DUNs outstanding on Level 2 drawings and 1416 DUNs on Level 3 drawings. Also during August the licensee reported that 54 drawings were updated by incorporation of five Level 1 drawing DUNs, 19 Level 2 drawing DUNs, and 30 Level 3 drawings DUNs. The number of DUNs remained relatively flat with some small decrease in the total number of DUNs; the number of Level 2 DUNs in January 2019 was 468 and Level 3 DUNs totaled 1530.

The inspector's review of the backlog data and the results of the condition report search did not identify any safety significant issues. While the number of DUNs appears high, DUNs do represent corrections to the drawings that, for Level 2 drawings, will eventually be incorporated in the drawing. The licensee does have a program to control and process needed drawing changes and does require that Level 1 drawings in the Control Room are updated before a system with a new modification can be considered functional or operable.

EXIT MEETINGS AND DEBRIEFS

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

• On October 8, 2019, the inspectors presented the integrated inspection results to Mr. M. Bezilla, Site Vice President, and other members of the licensee staff.

• On August 22, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. D. Huey, General Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Calculations Calc 54.22 Effect of Flooding from Water Treatment Building into Tunnel 00

Miscellaneous L-17-176 Davis-Besse Focused Evaluation Regarding Near-Term 07/11/2017

Task Force Recommendation 2.1 for Flooding

UFSAR Section Hydrology 31

2.4

Procedures RA-EP-02830 Flooding 6

71111.04Q Drawings OS-004 SH 1 Decay Heat Removal/ Low Pressure Injection System 61

Procedures DB-OP-06012 DH Loop Normal Lineup Valve Checklist 73

DB-OP-06900 Plant Heatup 69

71111.05A Miscellaneous 2-3-07/14/19-1 X01 Auxiliaries Fire 07/14/2019

2-3-08/01/19-1 X01 Auxiliaries Fire 08/01/2019

71111.05Q Fire Plans PFP-EFW-All Emergency Feedwater Facility 0

Procedures PFP-AB-402 No. 1 Electrical Penetration Room Room 402 Fire Area DG 5

PFP-AB-505 Control Room and Adjacent Support Rooms, Rooms 502, 8

503, 504, 505, 506, 507, 510, 511, 512, and 513, Fire Area

FF

PFP-TB-250 Service Water Pipe Tunnel Room 250 Fire Area BG 5

71111.06 Calculations 54.22 Effect of Flooding from Water Treatment Building into

Tunnel, Lowest Essential Valve Located at 574'6" in Valve

Room

Calc 05.039 Feedwater Flooding in Aux. Building 0

Miscellaneous Davis-Besse Nuclear Power Station Emergency 09/17/2019

Preparedness Integrated Drill

UFSAR Section Protection Against Dynamic and Environmental Effects 31

3.6 Associated with Postulated Rupture of Piping

Procedures DB-OP-01001 Administrative Control of Containment Isolation Valves 7

RA-EP-02810 Tornado or High Winds 15

RA-EP-02830 Flooding 6

RA-EP-02880 Internal Flooding 4

Work Orders 2007088771 PM 5318 Cln-Insp Bldg Roof

71111.11Q Miscellaneous Davis-Besse Nuclear Power Station Emergency 09/17/2019

Preparedness Integrated Drill

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Calibration FT-RC01A4 Reactor Coolant Loop 2 Hot Let Flow, RPS Ch 4 Flow 7

Records Transmitter

Corrective Action CR 2018-02217 Reactor Coolant Loop 2 Hot Leg Flow Transmitter Found 03/10/2018

Documents Out-of-Tolerance

CR 2018-03798 System Monitoring Identified Unexpected Increase in 04/24/2018

Response Times for Reactor Protection System (RPS)

Channel 4

CR 2018-07215 System Monitoring Identified Increased AC Ripple on ARTS 08/15/2018

Channel 1 +10 VDC Power Supply

CR 2019-05883 RPS Channel 1 Trip on Flux/Delta Flux/Flow 07/11/2019

CR G-201-2003- Excessive Flow Through DH13B and/or DH14B - DB-SP- 09/04/2003

272 04455 Driven CR

CR G201-2002- F890 has Inaccurate Indication for Service Water Flow to 10/01/2002

07065 Collection Box

CR G201-2003- Observed Degraded Condition of DH14B 05/01/2003

03385

CR G201-2003- Missing Taper Pins 08/28/2003

07037

CR G201-2003- DH13B and DH14B Degraded Seat Condition 08/29/2003

07066

CR G201-2003- DH14A and DH13A Disc Pin Staking 09/01/2003

07177

CR G201-2003- DH14A and DH13A Disc Pin Staking 09/01/2003

07177

CR G201-2003- LPI Train 1 Flow Does not Meet LOCA Requirements 09/08/2003

07455

CR G201-2003- DH14A Valve Seat is Damaged 10/09/2003

08626

CR G201-2003- CAP/SA Deficiencies in the Generic Implications Evaluation 11/26/2003

10165 for CR 2003-7049

CR-G201-2002- F890 has Inaccurate Indication for Service Water Flow to 10/01/2002

07065 Collection Box

CR-G201-2003- Operability Evaluation 03-07177 Comments 09/12/2003

07698

Inspection Type Designation Description or Title Revision or

Procedure Date

Drawings FIG. 7.4-1 CRDM Reactor Trip and Power Supply Configuration 2

Figure 7.2-1 Reactor Protection System M-536-1 21

M-041B Primary Service Water System 72

Engineering 19-0069-001 Install Blind Flange at SW38 00

Changes

Miscellaneous 45554743 Quality Control Purchase Order Closeout Checklist 3

Instruction Type 9100 Butterfly Control Valve Body 02/1972

Manual

LER 2005-002-00 Missing Taper Pins on CCW Valve Cause Technical 04/12/2005

Specification Required Shutdown

M-215-0095 Instruction Manual 9100 Series Butterfly Control Valve 04/30/2007

Bodies

Quality Control Valve-Butterfly 1/11/2017

Receiving

Inspection Report

TRM 8.3.1 Reactor Protection System Instrumentation Parameters 3

Procedures DB-ME-03020 Reactor Trip Breaker Response Time Test 4

DB-MI-09024 Installation and Removal of Foxboro I/A Series Differential 4

Pressure Transducers

DB-MM-09097 Limitorque Manual Actuator Maintenance 4

DB-MM-09266 Torquing 12

DB-MM-09317 Fisher Type 9100 Butterfly Control Valve Maintenance 3, 4

DB-MM-09330 Installation of Stud Type Expansion Anchors 12

DB-MS-09253 Application of Protective Coatings Outside Containment 8

DB-SC-03077 Emergency Diesel Generator 2 184 Day Test 32

NA-QC-01191 Liquid Penetrant Examination 8

NOBP-LP-2100 Operating Experience Process 20

NOP-CC-1003 Vendor Technical Information 3

NOP-ER-3900 Equipment Reliability Common Definitions and Structure 11

NOP-LP-2020 Quality Control Receipt Inspection 18, 20

NOP-LP-2601 Procedure/Work Instruction Use and Adherence 6

NOP-WM-4006 Conduct of Maintenance 10

Work Orders 200777472 CCW Heat Exchanger 2 Outlet Isolation 08/26/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Corrective Action CR 2019-06415 CREATCS Train 2 Compressor Replacement Under Order 07/30/2019

Documents 200582815 was not Identified as Yellow Nuclear Safety and

Generation Risk

CR 2019-06472 Failure to Initiate an ICES Report for CR 2019-05091 07/31/2019

CR 2019-06496 Unsat Electrical Terminations Found in S33-2 08/01/2019

Drawings M-041B Primary Service Water System 72

Engineering 19-0069-001 Install Blind Flange at SW38 00

Changes

Miscellaneous LER 2005-002-00 Missing Taper Pins on CCW Valve Cause Technical 04/12/2005

Specification Required Shutdown

M-215-0095 Instruction Manual 9100 Series Butterfly Control Valve 04/30/2007

Bodies

P 42 - 1,2; MP 42 Lubrication Data Sheet, Decay Heat Pumps and Motors 07/23/2019

- 1,2

Procedures DB-MI-09024 Installation and Removal of Foxboro I/A Series Differential 4

Pressure Transducers

DB-MM-01009 Lubricant Sampling Methods 10

DB-MM-09097 Limitorque Manual Actuator Maintenance 4

DB-MM-09266 Torquing 12

DB-MM-09317 Fisher Type 9100 Butterfly Control Valve Maintenance 3, 4

DB-MM-09330 Installation of Stud Type Expansion Anchors 12

DB-MS-09253 Application of Protective Coatings Outside Containment 8

NA-QC-00191 Liquid Penetrant Examination 8

NOP-OP-1007 Risk Management 29

Work Orders 200777472 CCW Heat Exchanger 2 Outlet Isolation 08/26/2019

71111.15 Corrective Action CR 2019-06097 CV5000A, EVS Fan 1 Discharge Damper not Operating 07/19/2019

Documents Properly

CR 2019-06314 CF 1544 Leaking By 07/26/2019

CR 2019-06322 ROCA Zone 95 Damaged Detection Wire 07/27/2019

CR 2019-06613 EVS Train 1 Past Operability 08/06/2019

Work Orders 200715407 EVS Train 1 Monthly Test 04/27/2019

71111.18 Corrective Action CR 2019-05707 C30205 SBODG Ground Meter Low mAMPs 07/03/2019

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.19 Calculations C-ICE-058.01- RPS Reactor Power Related Field Trip Sepoints 4

008

Corrective Action CR 2017-10465 Recent Hope Creek EDG OE: Failure of New Dynalco Speed 10/16/2017

Documents Switch

CR 2017-10873 10 CFR Part 21 Notice from Engine Systems Inc. for EDG 10/30/2017

Speed Switch

CR 2019-05707 C30205 SBODG Ground Meter Low mAMPs 07/03/2019

CR 2019-05883 RPS Channel 1 Trip on Flux/Delta Flux/Flow 07/11/2019

Drawings M-041B Primary Service Water System 72

OS-033F Containment Vessel Isolation and Vacuum Relief Systems 12

Engineering 19-0069-001 Install Blind Flange at SW38 00

Changes

Miscellaneous LER 2005-002-00 Missing Taper Pins on CCW Valve Cause Technical 04/12/2005

Specification Required Shutdown

Letter to NRC 10CFR21 Reporting of Defects and Non-Compliance - 10/26/2017

from Engine Engine Systems, Inc. Report No. 10CFR21-0118, Rev. 0

Systems, Inc.

M-215-0095 Instruction Manual 9100 Series Butterfly Control Valve 04/30/2007

Bodies

Procedures DB-ME-03020 Reactor Trip Breaker Response Time Test 4

DB-MI-03057 RPS Channel 1 Calibration of Overpower, 39

Power/Imbalance/Flow, and Power/Pumps Trip Functions

DB-MI-09024 Installation and Removal of Foxboro I/A Series Differential 4

Pressure Transducers

DB-MM-09097 Limitorque Manual Actuator Maintenance 4

DB-MM-09266 Torquing 12

DB-MM-09317 Fisher Type 9100 Butterfly Control Valve Maintenance 3, 4

DB-MM-09330 Installation of Stud Type Expansion Anchors 12

DB-MS-09253 Application of Protective Coatings Outside Containment 8

DB-PF-03272 Post Maintenance Valve Test 15

DB-PF-09301 Preventive Maintenance for Type SMB and SB Limitorque 9

Operators

DB-PF-09307 Operation of Motor Monitoring Equipment 4

NA-QC-00191 Liquid Penetrant Examination 8

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 200607286 PM 7919 - Replace RPS Channel 3 Power Supplies

200637629 PM 0747 MV2001 Inspect RPS/SFSAS 2 07/22/2019

200707506 PM 7369 C4606 Swap Breaker

200724974 RPS Channel 1 Calibration of Overpower, 07/12/2019

Power/Imbalance/Flow and Power/Pumps Trip Functions

200777472 CCW Heat Exchanger 2 Outlet Isolation 08/26/2019

71111.20 Corrective Action CR 2019-00296 MFPT 2 Failed to Trip in Response to a Manual Trip Initiated 01/12/2019

Documents from the Control Room

CR 2019-05397 Failed MFPT 1 HP Stop Valve Test 06/23/2019

CR 2019-07441 ARTS Failed to Receive Trip Input from MFPT #2 Following 09/08/2019

Reactor Trip

CR 2019-07832 MFPT #2 Trip Relay Valve As-Found Condition 09/24/2019

Miscellaneous Outage Control Center Shift Turnover Report 09/08/2019

Outage Control Center Shift Turnover Report 09/09/2019

EN 54263 Automatic Reactor Trip During Main Turbine Valve Testing 09/07/2019

71111.22 Corrective Action CR 2019-07705 Water was Flowed from the EFWST to OTSG1 While 09/18/2019

Documents Running the EFW Pump to Recirc Engine Coolant

CR 2019-07722 EFWP Recirculation Line Flow not Within Desired Band 09/19/2019

Drawings E-18 SH 1 SFRCS Logic Diagram Logic Channels 1 and 3 and 7

Actuation Channel 1

OS-062 SH1 Emergency Feedwater System 3

SF-003E SH 1 Power Distribution Logic Cabinet 0

SF-003E SH 2 SFRCS Power Distribution Relay Cabinet 1

SF-006A SH 1 SFRCS Logic Module Logic Channel 1 4

Procedures DB-MI-03211 Channel Functional Test of SFRCS Actuation Channel 1 20

Logic For Mode 1

DB-SS-04201 Emergency Feedwater Pump Quarterly Test 4

Work Orders 200725747 MI3211-001 08.000 SFRCS ACH1 Functional SFRCS ACH 07/22/2019

Logic Functional FA Normal

71124.06 Corrective Action CR-2019-02900 Liquid Scintillation Detector (LI.0.11.32) Daily QC Source 03/28/2019

Documents Check Adverse Trend

CR-2019-04592 Series 28 Dosimeter Calibrator Fails Standardization 05/22/2019

Corrective Action CR-2019-07027 Mobile Shielded Particulate Iodine Samplers for Station Vent 08/21/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Accident Range Monitors are Currently Bolted Down to

Resulting from Structure

Inspection

Miscellaneous Offsite Dose Calculation Manual 36

Davis-Besse Nuclear Power Station Meteorological and 11/06/2017

Atmospheric Dispersion Report

Combined Annual Radiological Environmental Operating 05/10/2018

Report and Radiological Effluent Release Report for the

Davis-Besse Nuclear Power Station - 2017

Combined Annual Radiological Environmental Operating 05/14/2019

Report and Radiological Effluent Release Report for the

Davis-Besse Nuclear Power Station - 2018

DB-CN-04060 2017 Effluent MDAs 1

DB-CN-04060 2018 Effluent MDAs 1

Procedures DB-CN-04060 A Priori Minimum Detectable Activity for HPGe Gamma 1

Spectrometers

DB-HP-10000 Radiation Monitor Setpoint Control 09

NOP-OP-3202 FENOC Radiochemistry Quality Control Program 06

Self-Assessments MS-C-18-08-02 Multi-Site Chemistry and Environmental Fleet Oversight 10/12/2018

Report

Work Orders 200683191 CN3001-001 04.000 Liquid/Gaseous Radioactive Release 03/18/2018

Dose Commitment

200685288 CN3001-001 04.000 Liquid/Gaseous Radioactive Release 04/20/2018

Dose Commitment

200731127 CN3011-002 04.200 Station Vent Quarterly Radiolgical 08/22/2019

Monitoring Analysis

200731130 CN3011-002 04.200 Liquid Quarterly Radiolgical Monitoring 08/22/2019

Analysis

200731635 CN3001-001 04.000 Liquid/Gaseous Radioactive Release 07/25/2019

Dose Commitment

200765692 Station Vent Releases, Weekly Radiological Monitoring 08/20/2019

Sampling and Analysis

Inspection Type Designation Description or Title Revision or

Procedure Date

200765692 Station Vent Releases, Weekly Radiological Monitoring 08/20/2019

Sampling and Analysis

200765739 Station Vent Releases, Weekly Radiological Monitoring 06/04/2019

Sampling and Analysis

71124.07 Corrective Action CR-2018-06245 REMP Air Monitor at Location T-11 Timer Discrepancy 07/12/2018

Documents CR-2019-01163 REMP Air Monitor Failure Trend 02/07/2019

Corrective Action CR-2019-07022 2019 NRC REMP Inspection 08/21/2019

Documents CR-2019-07038 Nuclear Regulatory Commission Observation Concern of 08/22/2019

Resulting from Meteorologic Tower Equipment Obsolescence

Inspection

Miscellaneous 10 CFR 50.75(g) Contaminated Soil History at Davis Besse Nuclear Power 08/17/2019

Plant Pursuant to 10 CFR 50.75(g)

Annual REMP 2018 Annual Radiological Environmental Operating Report 05/15/2019

Report

Procedures DB-CN-03023 Annual Land Use Census 4

DB-MI-04060 Met Towers Calibrations 1

NOBP-OP-2012 System/Work Practice Prioritization for NEI 07-07; Buried 1

Piping Integrity Program

71151 Miscellaneous Selected Unit Log Entries - July 1, 2018 through

June 30, 2019

MSPI Mitigating System Performance Index Basis Document 7

NOBP-LP-4012- Reactor Coolant System Specific Activity 11/4/2018

though

07/01/2019

NOBP-LP-4012- RETS/ODCM Radiological Effluent Occurrence 11/04/2018

through

07/01/2019

71152 Corrective Action CR 2019-00691 Missing Weld Location on Drawing M-0246B 01/23/2019

Documents CR 2019-03884 NRC 1Q2019 - Minor Violation of 10 CFR 50 App B Criterion 04/26/2019

III, Design Control

CR 2019-04156 Nitrogen Supply Piping Drawing Dispcrepancies 05/06/2019

CR 2019-06190 Unlabeled Support Near CD162 Discovered 08/22/2019

CR 2019-06635 Clearance Level 4 due to Drawing Dependency 09/06/2019

CR 2019-06788 Replacement Valve for CD5367 will not Fit 07/22/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

CR 2019-06832 Incorrect Quality Classification in SAP for PCV2398 08/14/2019

Miscellaneous DUN Status Monthly - New as-Built-vs-Incorporated DUN's for 2019 09/03/2019

August 2019

Procedures DBBP-DBDE- Design Engineering Human Performance Practices 0

0004

NOP-CC-1002 Drawing Control 4

NOP-CC-2003 Engineering Changes 24

71153 Corrective Action CR 2019-00296 MFPT 2 Failed to Trip in Response to a Manual Trip Initiated 01/12/2019

Documents from the Control Room

CR 2019-05397 Failed MPFT 1 HP Stop Valve Test 06/23/2019

CR 2019-07441 ARTS Failed to Receive Trip Input from MFPT #2 Following 09/08/2019

Reactor Trip

CR 2019-07832 MFPT #2 Trip Relay Valve As-Found Condition 09/24/2019

Miscellaneous Outage Control Center Shift Turnover Report 09/08/2019

Outage Control Center Shift Turnover Report 09/09/2019

EN 54263 Automatic Reactor Trip During Main Turbine Valve Testing 09/07/2019

LER 2018-001-00 Borated Water Storage Tank Level Transmitter Out of 02/14/2019

Tolerance Due to Reaching End of Expected Life

2