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05000346/FIN-2017003-0530 September 2017 23:59:59Davis BesseNRC identifiedUltrasonic Testing Records to Support Fuel Selection Were Not Being MaintainedA Severity Level IV NCV of 10 CFR 72.174, Quality Assurance Records, was identified by the NRC inspectors for the failure of the licensee as of June 22, 2017, to maintain sufficient records to furnish evidence of activities affecting quality. Specifically, the licensee failed to maintain ultrasonic testing (UT) records which were relied upon to demonstrate that the spent fuel selected for loading in calculation CNF062.02055, Revision 0, was correctly classified as intact. The licensee documented this issue in its CAP as CR201706976 and took timely corrective actions.The inspectors determined that the violation was of more than minor significance using IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Example 9a is applicable to this issue in that the licensee failed to maintain UT records for many fuel assemblies classified as intact for loading, and this failure to maintain records was not an isolated incident of one or two instances. The violation screened as a Severity Level IV NCV. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000346/FIN-2017003-0430 September 2017 23:59:59Davis BesseNRC identifiedFailure to Perform 10 CFR 50.59 EvaluationA finding of very low safety significance and an associated NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, was identified by the NRC inspectors for the licensees failure to maintain a record of a change from a method described in the USAR to another method. Specifically, the licensee failed to perform a written evaluation for the change to USAR defined load factors based on the design basis American Concrete Institute (ACI) 31863 Code to less conservative load factors based on the ACI 31871 Code. The licensee entered this issue into its CAP as CR201703025. Planned corrective action includes updating the USAR to reflect the changes to the Design Criteria Manual (DCM) for the load factors incorporated in the 1971 ACI 318 Code. 3 The inspectors determined that the licensees failure to perform a written evaluation for this change was a performance deficiency. The finding was determined to be more than minor because the inspectors could not conclude that the implemented change would not result in a departure from a method of evaluation described in the USAR) used in establishing the design bases and therefore not require a license amendment. Because the inspectors could conclude that the concrete structures designed using ACI 31871 load combinations would still have sufficient structural capacity to perform their design basis safety functions during a seismic event, the finding was determined to have very low safety significance corresponding to a Severity Level IV violation per Example 6.1.d.2 of the NRC Enforcement Policy. The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current licensee performance.
05000346/FIN-2011005-0431 December 2011 23:59:59Davis BesseNRC identifiedReactivity Manipulations Performed By Non-Licensed IndividuaLThe inspectors identified a SL IV NCV of 10 CFR 54(i) when a non-licensed member of the licensees engineering staff was observed operating switches that directly caused the insertion of various control rods that were being subjected to timing tests. Specifically, the inspectors observed that key switches used to interrupt power to the control rod drives and cause control rod insertion were manipulated by a member of the licensees engineering staff, and not a licensed individual. The issue was entered into the licensees CAP as CR 2011-06318. The issue was determined to be associated with the Mitigating Systems Cornerstone attribute of procedure quality. However, the inspectors subsequently determined that the issue had not adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because of several factors, the inspectors determined that the issue was of minor safety significance and, as such, did not constitute a finding. These factors included: All control rod group withdrawal activities were accomplished from the control room by an on-watch licensed reactor operator; All activities in the electrical penetration room were performed in accordance with an approved written test procedure, and under the direct supervision of a licensed Senior Reactor Operator; The operation of the local key switches in the electrical penetration room, albeit by a non-licensed individual, could only cause control rod insertion. There was no withdrawal capability; and. The individual operating the local key switches in the electrical penetration room was always in continuous communication with the on-watch licensed reactor operator in the control room. The inspectors determined that the issue was subject to the NRCs traditional enforcement process as an issue that had the potential to impact the agencys ability to perform its regulatory function. Specifically, the NRCs Reactor Oversight Process fundamentally assumes that only duly licensed individuals are allowed to manipulate reactor controls and alter core reactivity or make changes to reactor power, and that all licensed individuals perform their licensed duties in accordance with any restrictions associated with their individual licenses. The inspectors conferred with NRC Region III management and members of the enforcement staff and determined that, because of the factors noted above, the issue constituted a SL IV violation that resulted in no, or relatively inappreciable, safety consequences. Because this issue was dispositioned through the traditional enforcement process and had no Reactor Oversight Process aspects, there was no cross-cutting aspect associated with the violation.
05000346/FIN-2010003-0130 June 2010 23:59:59Davis BesseNRC identifiedFailure to Make a Required 8-Hour Event Report Per 10 CFR 50.72(b)(3)(ii)(B)The inspectors identified a Severity Level IV, non-cited violation (NCV) of 10 CFR 50.72(b)(3)(ii)(B), and an associated Green finding, for the licensees failure to recognize that, when in a shutdown condition, an 8-hour event notification to the NRC was required for the power plant being in an unanalyzed condition that significantly degrades plant safety. Specifically, during testing the Steam and Feedwater Rupture Control System (SFRCS) unexpectedly re-energized in a low steam line pressure blocked condition. This condition could cause an inappropriate SFRCS actuation and potentially result in auxiliary feedwater being supplied to a ruptured steam generator. Corrective actions included a change to the SFRCS logic to ensure that a power-on-reset occurs anytime 28 voltage direct current (VDC) power is lost. The inspectors determined that, per IMC 0612, Appendix B, Issue Screening, the failure to report the plant being in an unanalyzed condition that significantly degrades plant safety in accordance with 10 CFR 50.72(b)(3)(ii)(B) was a performance deficiency. Because the performance deficiency involved a violation that could have impacted the regulatory process, it is dispositioned using traditional enforcement. In accordance with Supplement I of the NRC Enforcement Policy, a failure to make a required report to the NRC is a Severity Level IV violation. The inspectors determined the performance deficiency was more than minor because the underlying technical issue affected the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This condition did not screen out in Phase 1 of the SDP because there was a potential loss of a safety function for greater than the technical specification allowed outage time. The significance of this condition was evaluated by the Region III Senior Reactor Analyst (SRA) and was determined to be of very low safety significance (Green). The inspectors determined that the primary cause of the performance deficiency affected the cross-cutting component of thorough evaluation of problems in the cross-cutting area of Problem Identification and Resolution. Specifically, the licensee did not properly evaluate a condition adverse to quality for reportability. (P.1(c)) (Section 1R15)
05000346/FIN-2008008-0130 September 2008 23:59:59Davis BesseNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for Service Water System ModificationThe inspectors identified a Severity Level IV NCV, having very low safety significance, of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to provide a documented basis for determining that changes to the service water system did not require prior NRC approval. Specifically, the licensee removed flow restricting piping orifices, which created an adverse change to the service water system, because the service water pumps could have insufficient net positive suction head during accident conditions. The licensee revised the service water system operating procedure to ensure that this change did not result in operation of the service water pumps with inadequate net positive suction head and entered this issue into the corrective action program. Because the issue affected the NRCs ability to perform its regulatory function, this issue was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the change would not have ultimately required NRC prior approval. The finding was determined to be of very low safety significance because the licensee had not aligned the service water system in a configuration that could have damaged the pumps
05000346/FIN-2005007-0230 June 2005 23:59:59Davis BesseNRC identifiedInaccurate/Incomplete Information (by Omission) in LER 05000346/1997-004A self-revealing issue was identified, during preparations for an NRC inspection, when the licensee discovered that Licensee Event Report (LER) 05000346/1997-004 was not complete and accurate in all material respects. Specifically, information had been removed from the LER prior to issuance. The deleted information was considered to be material by the NRC because if it had been complete and accurate, it would have resulted in additional inspection activities in the area of the completeness of corrective actions associated with this issue. Subsequent to the discovery of the deficiency, the licensee submitted Revision 01 to LER 05000346/1997-004, on March 26, 2004, which documented the originally omitted information Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated with the traditional enforcement process. Following a review of the additional information, inspectors determined that licensee corrective actions to address the material conditions documented in the original LER were sufficient. This issue was determined to be a Severity Level IV Non-Cited Violation, consistent with Section VI.A.1 of the NRC Enforcement Policy, of 10 CFR 50.9.
05000346/FIN-2004015-0131 December 2004 23:59:59Davis BesseNRC identifiedFailure to Perform Appropriate 50.59 Screening Concerning ECCS Sump Pump Affect on ECCS Component OperabilityA failure to perform an adequate safety evaluation review as required by 10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report (USAR) was self-revealed. In June 2003, the licensee changed the limit and precautions sections of several procedures to specify that emergency core cooling system (ECCS) room sump pumps were not required to be in service for ECCS and containment spray equipment operability. However, the USAR credits the ECCS sump pumps and their running lights for providing indication of the need for operator action in response to a passive failure in the ECCS system. The procedure changes were inappropriately categorized as being exempt from the 50.59 process because the changes involved "Managerial or Administrative Procedures." Because the issue affected the NRC's ability to perform its regulatory function, this finding was evaluated with the traditional enforcement process. The finding was determined to be of very low safety significance because, although the procedure changes could have resulted in the operation outside the requirements of technical specification action statements, no loss of function occurred. This was determined to be a Severity Level IV NCV of 10 CFR 50.59.
05000346/FIN-2004009-0130 September 2004 23:59:59Davis BesseNRC identifiedIncomplete Information Provided to NRC in Licensing SubmittalThe team identified that the licensee failed to provide complete information to the NRC in a licensing submittal. Specifically, the licensee did not identify that previously submitted licensing correspondence regarding the basis for not protecting ventilation system cables was no longer accurate.
05000346/FIN-2004010-0230 September 2004 23:59:59Davis BesseNRC identifiedInadequate 10 CFR 50.59 Evaluation Regarding Tornado Missile Protection for EDG Exhaust StacksThe inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.59, "Changes, Tests, and Experiments," based on the licensee performing an inadequate evaluation of a proposed change to the plant, regarding tornado missile protection of the diesel generator exhaust stacks and plant doors. Specifically, the licensee's response to the question posed in 10 CFR 50.59(c)(2)(vi) did not demonstrate that the proposed change did not create the possibility of a malfunction of equipment important to safety with a different result than any previously evaluated in the Final Safety Analysis Report (as updated) Because the Significance Determination Process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of the violation, that is, the failure to demonstrate that the proposed change did not create the possibility of a malfunction of equipment important to safety with a different result, were assessed using the Significance Determination Process This finding was determined to be more than minor because the inspectors could not determine reasonably that the change would not ultimately require NRC approval. The finding was determined to be of very low safety significance based on a significance determination process analysis of a loss of offsite power concurrent with loss of one emergency diesel generator and the violation was classified as a Severity Level IV Violation. (Section 1R02)
05000346/FIN-2004010-1030 September 2004 23:59:59Davis BesseNRC identifiedInadequate Safety Evaluation for Changes to the Plant made as Described in the USAR Concerning the low-low pressure interlock for the AFW PumpsThe inspectors identified a Severity Level IV Non-Cited Violation associated with the failure to perform an adequate safety evaluation review as required by 10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report. Specifically, the licensee failed to perform a safety evaluation in accordance with 10 CFR 50.59 for changes made to Section 9.2.7.3.c of the Updated Safety Analysis Report concerning the low-low pressure interlock for the auxiliary feedwater pumps. The changes made by the licensee adversely affected an Updated Safety Analysis Report-described function in that a previously described automatic feature of the steam inlet valve to the auxiliary feedwater pump was changed to clarify that this automatic feature was not available under certain conditions Because the Significance Determination Process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of the violation, that is, the failure to evaluate the changes made to Section 9.2.7.3.c of the USAR, were assessed using the Significance Determination Process This finding was determined to be more than minor because the inspectors could not determine reasonably that the change would not ultimately require NRC approval. The inspectors determined that this issue was of very low safety significance, because the design basis safety-related function of the auxiliary feedwater system, to remove reactor decay heat following a loss of normal feedwater, was not adversely affected, and because the team determined from the mitigating systems evaluation in the Phase 1 Screening Worksheet that all the questions were answered "No." Therefore, the results of the violation were determined to be of very low safety significance and the violation was classified as a Severity Level IV Violation. (Section 1R02)
05000346/FIN-2004002-0231 March 2004 23:59:59Davis BesseNRC identifiedChange to Emergency Plan Without Prior NRC ApprovalThe inspectors identified that the licensee had changed its standard emergency action level (EAL) scheme by revising one EAL's criteria for a Unusual Event declaration due to the initiation of the Steam and Feedwater Rupture Control System as a result of a rapid depressurization o the secondary side. The inspectors determined that this EAL change decreased the effectiveness of the emergency plan, and that the license did not obtain prior NRC approval for this change, contrary to the requirements of 10 CFR 50.54(q). Because the issue affected the NRC' ability to perform its regulatory function, it was evaluated with the traditional enforcement process as specified in Section IV.A.3 of the Enforcement Policy. According to Supplement VIII of the Enforcement Policy, this finding was determined to be a Severity Level IV becaus it involved a failure to meet a requirement not directly related to assessment and notification. Further, this problem was isolated to one EA and was not indicative of a functional problem with the EAL scheme. Additionally, because the licensee entered this issue into its correctiv action program and completed adequate corrective actions, this finding is being treated as a Severity Level IV Non-Cited Violation of 10 CF 50.54(q).
05000346/FIN-2003010-2331 March 2004 23:59:59Davis BesseNRC identifiedInappropriate Application of 10 CFR 50.59The team identified a Non-Cited Violation of 10 CFR 50.59, \"Changes, Tests and Experiments.\" Specifically, the license failed to preform an adequate evaluation of a defacto modification to the plant where the underlying change may have required NRC approva prior to implementation. The design change involved degraded or missing physical barriers that could result in one or more of the diese generators failing to fulfill their design function during a tornado. Following discovery, the licensee entered the issue into the corrective actio program and re-performed the analysis. The licensee also repaired those barriers which were physically degraded. The primary cause of thi violation was related to the cross-cutting area of human performance as the licensee appeared to selectively choose information from th guidance document in order to achieve the desired outcome Because this issue affected the NRC's ability to perform its regulatory function, this finding was evaluated with the traditional enforcemen process. The finding was determined to be of very low safety significance based on a significance determination process analysis of a loss o offsite power concurrent with loss of one emergency diesel generator. (Section 4OA3(3)b.23)
05000346/FIN-2003019-0131 December 2003 23:59:59Davis BesseNRC identifiedInaccurate or Incomplete Information in Response to G/L 88-14(INSTRUMENT Air Supply System Problems Affecting SAFETY-RELATED EquipmentThe inspectors identified a Non-Cited Violation of 10 CFR 50.9(a) regarding the licensee's February 22, 1989, reply to NRC Generic Letter 88-14, "Instrument Air Supply System Problems Affecting Safety-related Equipment." Specifically, the licensee's response stated that the dewpoint of Davis-Besse's Instrument Air System is checked three times weekly. However, the inspectors determined at the time the licensee's response to this Generic Letter was being prepared and issued, the dewpoint was checked significantly less than three times weekly. This was identified in the licensee's corrective action program as CR 03-08959. This finding is of very low safety significance because of the age of the issue and because substantial upgrades have been performed on the Instrument Air System. This finding potentially impacted the NRC's ability to perform its regulatory function. This type of finding cannot be processed through the Significance Determination Process. Consequently, the violation was processed using the traditional enforcement process.
05000346/FIN-2001015-0131 December 2001 23:59:59Davis BesseNRC identifiedSL Iv Violation of 10 CFR 50.7The NRC concluded that a security officer was discriminated against for engaging in protected activities within the scope of 10 CFR 50.7, "Employee Protection." A security supervisor subjected the officer to a fact-finding meeting on January 12, 2001, and placed a copy of the documentation from the meeting in the security officer's personnel file. The NRC determined that these actions were taken, at least in part, as a result of the security officer engaging in protected activity when he identified and documented in the condition report the potential security department training deficiency. The NRC issued a Notice of Violation by letter dated December 20, 2001, requiring a response by the licensee (VIO 50-346/01-15-01).