IR 05000346/2011008

IR 05000346-11-008; 02/14/2011 - 03/17/2011; Davis-Besse Nuclear Power Station; Routine Biennial Problem Identification and Resolution (Pi&R) Inspection

ML111091027
Person / Time
Site:	Davis Besse
Issue date:	04/19/2011
From:	Jamnes Cameron NRC/RGN-III/DRP/B6
To:	Allen B FirstEnergy Nuclear Operating Co
References
IR-11-008
Download: ML111091027 (24)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 April 19, 2011 Mr. Barry Allen FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2, Mail Stop A-DB-3080 Oak Harbor, OH 43449-9760 SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000 346/201 1 00 8

Dear Mr. Allen:

O n March 17 , 201 1 , the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) team inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the inspection findings, which were discussed on March 17 , 201 1 , with Mr. Brian Boles and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commission

's rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

The inspection team concluded that on the basis of the sample selected for review, in general, problems were properly identified, evaluated, and corrected. The team noted that the station staff reviewed operating experience for applicability to station activities. Audits and self-assessments were performed at an appropriate level to identify most deficiencies. Based on the independent assessment of safety culture results, interviews conducted during the inspection, and review of the employee concerns program, freedom to raise nuclear safety concerns was demonstrated.

Based on the results of this inspection, no findings were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room)

.

Sincerely,

/RA/ Jamnes L.

Cameron, Chief Branch 6 Division of Reactor Projects

Docket No. 50-346 License No. NPF-3

Enclosure:

Inspection Report 05000 346/201 1 00 8 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-346 License No:

NPF-3 Report No:

05000 346/201 1 00 8 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: February 14, 201 1, through March 17, 201 1 Inspectors:

A. Garmoe, Project Engineer, Team Lead J. Rutkowski , Senior Resident Inspector , Davis-Besse, Team Lead J. Bozga , Reactor Inspector, Mechanical C. Brown, Reactor Inspector, Electrical A. Wilson , Resident Inspector Approved by:

Jamnes L. Cameron

, Chief Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000 346/201 1 00 8; 02/14/201 1 - 0 3/17/201 1; Davis-Besse Nuclear

Power Station; Routine Biennial Problem Identification and Resolution (PI&R) Inspection This inspection was performed by three NRC regional inspectors, one Davis-Besse Nuclear Power Station senior resident inspector, and the Davis-Besse Nuclear Power Station resident inspector. No findings or violations of NRC requirements were identified during this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Davis-Besse Nuclear Power Station was generally effective. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify most deficiencies.

On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP.

Problem Identification and Resolution A. No findings were identified.

N RC-Identified and Self-Revealed Findings B. No violations of significance were identified.

=

Licensee-Identified Violations===

REPORT DETAILS

4OA2 Problem Identification and ResolutionThe activities documented in

Sections

.1 through .4 constitute

d one biennial sample of problem identification and resolution as defined in Inspection Procedure 71152. (71152B)

.1 a. Assessment of the Corrective Action

Program Effectiveness The inspector s reviewed the licensee's Corrective Action (CA) program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel.

Inspection Scope The inspectors reviewed risk and safety significant issues in the licensee's CA program since the last NRC Problem Identification and Resolution (PI&R) inspection in April 2009. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self assessment, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed Condition Reports (CRs) generated as a result of facility personnel's performance in daily plant activities. In addition, the inspectors reviewed CRs and a selection of completed investigations from the licensee's various investigation methods, which included root cause, full apparent cause, limited apparent cause, and common cause investigations.

The inspectors selected the control rod drive system to review in detail.

The inspectors' review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. A 5 year review on the control rod drive system was undertaken to assess the licensee's efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the auxiliary feedwater system and decay heat system.

A review of the use of the station maintenance rule program to help identify equipment issues was also conducted

. During the reviews, the inspectors determined whether the licensee staff

's actions were in compliance with the facility's corrective action program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined whether licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non

-cited violations.

b.

(1) Assessment Based on the information reviewed, including initiation rates of CRs and interviews, the inspectors concluded that the threshold for initiating condition reports was appropriate.

In addition, the inspectors noted that the licensee trends equipment and human performance on a regular basis.

Effectiveness of Problem Identification The inspectors identified one example of a weakness with regard to entering conditions into the corrective action program at a low threshold. The licensee initiated CR 11-89925 after I&C technicians inadvertently tripped the radwaste ventilation system while performing a surveillance to calibrate radwaste area exhaust process radiation monitor RE5405A. The licensee ha s been changing out radiation monitors from analog to digital, thus two active procedures were in place to perform the calibration. Prior to calibrating radiation monitor RE5405A, a digital radiation monitor, the technicians were incorrectly provided with the procedure used for calibrating an analog radiation monitor. The analog procedure performs steps in a slightly different order than the digital procedure, which caused the radwaste ventilation system to trip offline. One of the technicians involved had caught the mistake of being given the wrong procedure on several previous occasions, but did not catch the error in this instance. This event could have been prevented had a condition report been written for the previous instances of being given the wrong procedure.

Observations No findings were identified.

Findings

(2) The inspectors reviewed the classification of CRs for resolution and determined that, in general, CRs were assigned appropriate prioritization and evaluation levels and evaluations in apparent cause and root cause reports that were reviewed were adequate. Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed CR 10

-75350, "Turbine Building HELB Concerns in CCW Pump Room." The inspectors noted that the immediate operability determination was based on engineering judgment that was not numerically or analytically based. Upon further discussion with the Engineering Department, the operability determination was updated to include numerically and analytically based information. The inspectors concluded that the Shift Manager accepted engineering judgment as a basis for operability and did not sufficiently challenge the information provided by Engineering to ensure an adequate basis for operability was provided.

Observations The inspectors also reviewed CR 10

-87473, "Pipe Stress Calculations for Temporary Shielding." Pipe stress analysis and pipe support calculations were verified to be in conformance with design and licensing basis requirements for decay heat piping systems. However, the inspectors did identify three design control violations of minor significance involving the placement of lead shielding on piping systems. The minor violations were entered into the CA program as CR 11-90280, CR 11

-90326, and CR 11-90347. No findings were identified.

Findings

(3) In general, the inspectors noted that the corrective actions addressed the cause of the identified problem, and appeared to have been effective in the majority of samples reviewed. The inspectors noted that at least in one department there were some inconsistencies in closing out corrective actions and that those closeouts were not in accordance with station expectations.

Effectiveness of Corrective Actions The inspectors identified several examples where licensee personnel appeared to demonstrate a lack of rigor in complying with stated requirements of the CA program. Observations Procedure NOP-LP-2001, "Corrective Action Program,"

Section 4.17, states that all approved CAs shall be tracked in the condition report database from initiation until implementation. Additionally, a licensee-generated memorandum sent to Davis-Besse managers on March 10, 2010, re

-iterated that CAs identifying that something "will" be done should not be closed until the action is done. The inspectors review ed CR 09-55141, "Chemistry Plant Status Control Standing Order Noncompliance,"

and observed that CA #9 was closed on August 26, 2009 , with work order system notifications to track remaining open items. Two of the notifications (600566034 and 600566035) were still open as of February 17, 2011. Licensee personnel stated that the CAs were complete d but the notifications had not been updated in a timely manner. Additionally

, it was identified tha t CAs #5 and #9 had not been accomplished as written

, even though the CAs were closed in the CA program electronic database. As a result of the inspectors' observations, the licensee initiated CR 11-89901 and CR 11-89748. The inspectors reviewed CR 09

-67079, "Weaknesses in the Boron

-10 Correction Factor Program ," which was written in response to licensee identified ineffective and incomplete CA from CR 06

-06669, "Boron 10 Isotopic Composition Not Accounted for in BWST, BAATS, CFTS." Corrective action

1. 3 of CR 09-67079 called for a full review of all Chemistry full and limit ed apparent causes, dating to 2006, to ensure that all CAs generated as a result of those evaluations were tracked to completion. The results of that review were documented in CR 10

-72273, "Incomplete Documentation of Corrective Actions," which included several example s of documentation issues or closure issues.

The inspectors noted that the review did not identify that CA #9 from CR 09-55141 had remaining open items

. It was also determined that CA #4 of CR 09

-67079 was closed on April 27, 2010

, to an action plan that listed actions to be tracked using work order notification s 600612198, 600612199, and 600612200. The action plan stated that the due date for completion of the actions was November 1, 2010. As of February 16, 2011, those notifications were still open even though the licensee stated that the actions had been completed. The licensee documented this issue in CR 11-89741. The inspectors reviewed CR 10

-73290, "Unattended Vehicle in the 75 Foot Exclusion Zone near the Dry Fuel Storage Pad

," which was written on March 12, 2010, to document a finding issued by the NRC. A ll CAs and the limited apparent cause analysis were documented as completed as of April 9, 2010. The CR was scheduled to be reviewed by the Corrective Action Review Board (CARB) on November 1, 201

0. However, the sponsoring

manager withdrew the document until there was a revised analysis of condition applicability to similar circumstances. As of February 15, 2011, the CR had not been reviewed by the CARB, which is inconsistent with the CARB review time frame requirements of NOP

-LP-2001, "Corrective Action Program." The licensee initiated CR 11

-89733 to document this issue. The inspectors reviewed CR 09

-63254, "Finding MS

-C-09-08-22: Ineffective Corrective Action Implementation for HSM." The CR discussed a CA from a full apparent cause evaluation (ACE) that had not been effectively implemented. The licensee performed a limited ACE to determine why the CA from the full ACE had not been effectively implemented. The limited ACE identified the cause as a failure to fully follow the CR process; however the inspectors identified that no CA was assigned to address the cause. The inspectors noted that the underlying technical issue, combustible materials within 75 feet of the horizontal storage modules (dry cask spent fuel storage), is an issue that the licensee has not been able to effectively correct for several years. Dating back to 2006, the licensee received two non

-cited violations from the NRC and performed numerous apparent cause evaluations. The inspectors view the lack of a CA to address the most recent identified cause, particularly when considered as part of a long

-standing issue, as a weakness in the ability to promptly take effective corrective actions.

No findings were identified.

Findings

.2 a. Assessment of the Use of Operating Experience

The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing operating experience program procedures, completed evaluations of OE issues and events, monthly assessments of the OE composite performance indicators, and attended CA program meetings to observe the use of OE information. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed whether corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

Inspection Scope b. The inspectors determined that the overall performance of the operating experience program was adequate.

Assessment The inspectors reviewed the licensee's dispositioning of Information Notice (IN) 2008

-02, "Findings Identified During Component Design Basis Inspections (CDBI)," which communicated issues identified during recent CDBI inspections.

The inspectors noted that the licensee's review of IN 2008

-02 was closed to existing procedures and practices, such as the OE Program, Latent Issues Review Process, and the Engineering Design Process. There was very little, if any, applicability review performed by the licensee. Observations No findings were identified.

Findings

.3 a. Assessment of Self

-Assessments and Audits The inspectors assessed the licensee staff's ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective CAs, through efforts from departmental assessments and audits.

Inspection Scope b. The inspectors concluded that self

-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold level. However, the inspectors noted at least one assessment that did not identify issues subsequently identified by the NRC. The inspectors concluded that these audits and self

-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self

-assessments and audits had identified issues that were not previously recognized by the station.

Assessment Observations The inspectors reviewed licensee self-assessment SN

-SA-255, "Pre-NRC IP 95001 Inspection Assessment (Davis

-Besse EP)," for adequacy.

The self-assessment was prepared in August 2010, prior to the NRC 95001 supplemental inspection that was conducted in September 2010. The supplemental inspection was conducted in response to a finding of low to moderate (White)safety significance identified in 2009 for the failure to recognize an event in the electrical switchyard that met the emergency action level conditions for declaring an Alert. Self

-assessment SN

-SA-255 states that the assessment verified that "actions taken have been largely effective in correcting the root and contributing causes of the failure to classify."

However, the NRC 95001 inspection revealed weaknesses with the adequacy of the licensee's extent of cause evaluation and concerns about whether th e corrective actions would prevent recurrence. Site Self Assessment s

The NRC kept the White finding open until the corrective actions and extent of cause evaluation were expanded. A follow-up NRC 95001 inspection reviewed the updated information and closed the White finding in December 2010. Based on the NRC

's concerns during the initial 95001 inspection, the inspectors questioned the adequacy of self-assessment SN

-SA-255. The inspectors identified weaknesses in the corrective actions and extent of cause review s performed by the self-assessment. The licensee initiated CR 11-90395 in response to the inspector's observations.

The inspectors also reviewed self

-assessment IP

-SA-11-113, "Integrated Performance Assessment and Trending for Operations, Second 6 months of 2010

." The inspectors identified that the self

-assessment failed to identify a trend that was identified by NRC inspectors during the fourth quarter of 2010. Specifically, the NRC integrated fourth quarter Inspection Report 05000356/2010005 identified an adverse trend related to the licensee's management of Technical Specifications and Limiting Conditions for Operations, with several examples identified during the third and fourth quarter s of 2010. The inspectors noted a weakness in that self

-assessments, including IP-SA-11-113, review NRC inspection report s for findings and violations, but do not review the semi-annual trend review section of the report. A review of the semi

-annual trend section could have led the self

-assessment to document a potential adverse trend in Operations that was relevant to the second half of 2010

. Self Assessment SN

-SA-10-352, "Work Order Package Completeness and Associated Impact on the Maintenance Shops," was also reviewed by the inspectors.

The licensee conducted this assessment to review why 64 work orders had been placed in "Additional Planning" status between July 26 and October 4, 2010. The assessment conclusion did not identify any negative trends attributable to a particular department or process but included the statement, "Work Planning needs to continue to strive for increased quality in the work orders." Procedure NOBP

-LP-2001, "FENOC Self

-Assessment/Benchmarking," states that assessment results should be grouped as strengths, recommendations, and deficiencies. Deficiencies and recommendations are required by procedure to have corrective action or notification assignments. The statement referenced was not listed as a deficiency or recommendation and, therefore, had no associated corrective action or notification action that could communicate the insight to plant staff. Discussion with licensee personnel revealed that the need to strive for increased Work Order quality was being reinforced by a corrective action from the Root Cause Evaluation in CR 10-86565, which is not related to SN

-SA-10-352. While the concern over work order quality in assessment SN

-SA-10-352 was being addressed by a separate unrelated action, the inspectors concluded that, absent the unrelated Root Cause Evaluation, this meaningful observation would have likely not been communicated to plant staff. Such communication could have been accomplished through an assigned corrective action or notification from the self

-assessment.

The inspectors reviewed assessments and audits conducted by Fleet Oversight , including the quarterly assessment report from the fourth quarter of 2010. Ratings of the performance of station organizations are assigned by Fleet Oversight in accordance with

procedure NOBP-LP-2023, "Nuclear Operating Business Practice, Performance Assessment." That procedure specifie s four levels of effectiveness using a color scheme of green, white, yellow, and red. In the fourth quarter of 2010, all departments Fleet Oversight Assessments were rated as "effective" (White), with steady, improved, or improving trends. The inspectors noted several departments were rated as "effective" for all quarters in 2010. This included the Chemistry department which, in the fourth quarter of 2010, was rated as "marginally effective

" (Yellow) in a separate assessment, MS-C-10-08-02, a multi

-site audit of chemistry and environmental areas. That audit identified recurring significant issues in the laboratory quality control program, failure to satisfy Technical Specification requirements for changes to the Offsite Dose Control Manual, and issues related to chemistry sampling and analysis.

The inspectors, while not having a general concern with the overall effectiveness of the assessment and audit program, did question the rating of effective for all station departments.

The inspectors also reviewed Fleet Oversight quarterly assessments for the Site Protection department for the fourth quarter 2009 and all four quarters of 2010, based on review of Condition Report 10

-70483, "Site Protection Rated Marginally Effective for Fourth Quarter 2009."

The assessments show the Site Protection department transitioning from "marginally effective

" (Yellow) to "effective" (White). The inspectors' review of the assessments identified that, when taken as stand

-alone documents, it was difficult to verify the conclusions that were reached. The main reason for this appears to be that the assessments focus on different items each quarter, thereby making it more difficult to trend performance. The inspectors did, ultimately, determine that the assessment conclusions were appropriate using information from other performance reports in addition to information included in the quarterly assessments.

The inspectors noted that the licensee-provided listing of assessments did not indicate any assessment of the licensee's overall assessment program. The inspectors were advised that such an assessment was scheduled for the second quarter of 2011.

No findings were identified.

Findings

.4 a. Assessment of Safety Conscious Work Environment

The inspectors assessed the licensee's safety

-conscious work environment (SCWE) through the reviews of the facility's employee concern s program (ECP) implementing procedures, discussions with the ECP coordinator, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 20 10 Safety Culture Survey.

Inspection Scope The inspectors interviewed approximately 30 individuals from various departments to assess their willingness to raise nuclear safety issues.

The individuals were selected to provide a distribution across the various departments at the site and included lo ng-term contractors. The sample was of individuals predominantly at first-line supervision and below first

-line supervision. In addition to assessing individuals' willingness to raise nuclear safety issues, the interviews also addressed changes in the CA program and plant environment over the past 2 years. Other items discussed included:

knowledge and understanding of the CA program; effectiveness and efficiency of the CA program; willingness to use the CA program; management's support of the CA program; feedback on issues raised; and ease of input to the CA database system. b. Interviews indicated that the licensee has an environment where people are free to raise issues without fear of retaliation. Documents provided to the inspectors regarding the 2010 safety culture assessment stated that Davis

-Besse Nuclear Power Station maintained a healthy safety culture.

Based on a review of the survey data , the inspectors concluded that the data supported that conclusion

. Assessment All interviewees indicated that station personnel would raise safety issues and were comfortable doing so. All individuals knew that, in addition to the CA program, they could raise issues to their management, the ECP, or the NRC. None of the individuals interviewed indicated they had been retaliated against for raising issues nor were they aware of anyone who had been retaliated against.

Several interviewees indicated that they believe writing a condition report will result in more work for them and others indicated that condition reports can be perceived negatively by individuals involved in the documented activity. However, all individuals indicated that they would nevertheless raise safety issues through condition reports.

No findings were identified.

Findings

4OA6

.1 Management Meetings On March 17, 2011, the inspectors presented the inspection results to Mr. B. Boles, and other members of the licensee staff.

The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

Exit Meeting Summary

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Attachment

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC

T

B. Allen, Site Vice President

Licensee

P. Boissoneault; Manager, Chemistry

B. Boles, Director, Site Operations

K. Byrd, Director, Site Performance Improvement

J. Cuff, Manager, Site Maintenance (Acting)

J. Dominy, Director, Site Maintenance

G. Hayes, Supervisor, Reactor Engineering

J. Hook, Manager, Design Engineering

V. Kaminskas, Director, Site Engineering

G. Kendrick, Manager, Site Outage Management

P. McCloskey, Manager, Site Regulatory Compliance

D. Noble, Manager, Radiation Protection

M. Parker, Manager, Site Protection

R. Patrick, Manager, Site Work Management

A. Percival, Sr. Chemistry Technologist (Liquid Radwaste and Effluent Analysis)

S. Plymale, Manager, Site Operations

J. Sturdavant, Regulatory Compliance

T. Summers, Manager, Plant Engineering

J. Vetter, Manager, Emergency Response

A. Wise, Manager, Technical Services

D. Kimble, Senior Resident Inspector

Nuclear Regulatory Commission

LIST OF ITEMS OPENED, CLOSED AND DISCUSS

ED None. Opened None. Closed

Attachment

LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

PLANT PROCEDURES

Number Description or Title

DB-HP-04027 Date or Revision

Installed Shielding Inspection and Engineering Evaluation

Rev. 5 DB-ME-09101 Reactor Trip Breaker Maintenance and Testing Rev. 3 DB-MI-04503 Channel Calibration of Process Radiation Monitors Rev. 8 DB-OP-02522 Small RCS Leaks

Rev. 10 DB-PF-00004 Equipment Failure Trending

Rev. 0 NOBP-ER-3916 Component Health & Trending

Rev. 9 NOBP-LP-2001 FENOC Self

-Assessment/Benchmarking

Rev. 15 NOBP-LP-2010 CREST Trending Codes

Rev. 9 NOBP-LP-2011 FENOC Cause Analysis

Rev. 12 NOBP-LP-2018 Integrated Performance Assessment and Trending Rev. 7 NOPL-LP-2003 Policy - SCWE Rev. 2 NOP-LP-2001 Corrective Action program

Rev. 26 NOP-LP-2100 Operating Experience Program

Rev. 4 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

N/A Date or Revision

Corrective Action Review

Board Minutes

11/1/2011 N/A Corrective Action Review Board Minutes

2/28/20 11 06-01753 Station not in Compliance With DB

-FP-0007 4/10/2006 06-02340 Potential Violation of 10 CFR 72.122C

5/19/2006 07-15336 Combustible Material Found in Sealand Containers on Dry Fuel Storage Pad

2/28/2007 07-32112 Pressurizer Level Decrease While Placing DH Train 1 in Standby

2/30/2007 08-46365 Repeat of Transient Combustible Material Located Near Horizontal Storage Modules

9/16/2008 08-46188 Violation of

DB-FP-0007, Control of Transient Combustibles

9/12/2008 08-44622 Nuclear Fuel Assessment Report

-2nd Quarter 2008 Fme Program Is Rated Red

8/12/2008 09-54570 Initiation of CRs For 10CFR21 Notifications

3/3/2009 09-55141 Chemistry Plant Status Control Standing Order Noncompliance

3/11/2009

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

09-56755 Date or Revision

NRC PI&R: DB

-ME-09114 Does Not Implement Recommended Torque Values

4/06/2009 09-57013 NRC PI&R 2009: CR 04

-04561, Westinghouse TB

-04-13 Circuit Brkr Eval & Actions 4/8/2009 09-57272 MS100 Main Steam Line 2

Isolation Valve Failed to Fully Open

4/15/2009 09-57849 Procedure Non

-Compliance during #1 Purification Demineralizer Outlet

Sampling 4/24/2009 09-60012 Use of Written Instructions

6/08/2009 09-61025 Loss of J Bus, Catastrophic Failure of J Bus B Phase Potential Device

6/25/2009 09-61198-02 DB-SA-09-047: Ineffective Corrective Actions 6/27/20 09 09-63254 Finding MS

-C-09-08-22: Ineffective Corrective Action Implementation for HSM

8/14/2009 09-67480 2009 CDBI: Inadequate Equivalency Justification Provided in ERR 90

-0003-070 11/9/2009 09-67489 NRC Concern

- Submerged Cables in Electrical Manhole MH3045

11/9/2009 10-70583 DB-PA-09-04: Site Protection Rated Marginally Effective for Fourth Quarter 2009

1/25/2010 09-68029 CDBI 2009:

Potential Violation of

CFR 50.71 11/19/2009

09-65084 NRC Question with the Motor Operated Valve PM and Testing Program

10/28/2009 09-65326 NRC P I For Drill/Exercise Performance In Action Region

10/1/2009 09-66474 2009 CDBI: Procedures For LOCA Outside CTMT 10/22/20 09 09-66487 Insulation Removed from Steam Piping at AFPT But Not Evaluated; IR 2009005

-02 10/19/2009

09-68328 Accidental Discharge Of Security Officers Weapon 11/27/2009

09-68498 Chemistry Parameters Trending Deficiencies

2/2/2009 10-69971 CDBI 2009: Inadequate Corrective Action Taken for Potential Tornado Missiles

1/12/2010 10-70666 Electrical Manhole MH3045

- Cables Submerged 1/27/2010 10-72207 CV5005 Closed Light Did Not Illuminate During S troke Time Test

2/28/2010 10-73290 Unattended Vehicle In The 75 Foot Exclusion Zone Near The Dry Fuel Storage

Pad 3/12/2010

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

10-74253 Date or Revision

DB-PA-10-01: Finding: ISI Program Plan Not Updated to Meet 10 CFR 50.55A Rqmt

3/25/2010 10-75350 Turbine Building HELB Analysis Deficiency

4/14/2010 10-75790-07 Red Cross-Cutting Aspect PI For H.2.(c) - Resources / Documentation

4/22/2010 10-76811 Compliance With NOBP

-LP4014, Managing Regulatory Interface

5/13/20 10 10-79786 SN-SA-10-227 - Snapshot Self

-Assessment Quality Issues

7/16/2010 10-82117 NRC 95001 Inspection Of The June 2009 Switchyard Event/White Finding Follow

-up 9/2/20 10 10-81867 IP-SA-10-244, Site Trend With Oversight of Supplemental and FENOC Personnel

8/27/2010 10-82447 Incorrect Simulator Eal Declarations

9/9/2010 10-83637 August 2010 SCWE Survey Results Indicate 3 Red Pillars For Chemistry

10/4/2010 10-83723 August 2010 SCWE Survey Results Indicate One Red Pillar For Security

10/5/2010 10-83779 NRC Finding:

Submerged Cables in Electrical Manhole MH3045

10/6/2010 10-84979 Potential Compliance Issue with NRC RIS 2010-06 and Davis Besse TRM 8.7.3

10/27/2010

10-85247 Containment Normal Range Radiation Monitor 11/02/2010

10-85453 Safety Control Rod 3

-4 Ratcheted IN from

100 percent to 72 percent Withdrawn 11/05/2010

10-87256 Transfer Switch for Rod 3

-4 may have Degraded Set Contacts

2/17/2010

10-87348 Area For Improvement In Extent Of Cause Determination

2/20/20 10 10-87473 Pipe Stress Calculations for Temporary Shielding 12/23/2010 11-89925 Misposition Radwaste Ventilation Inadvertently Tripped During RE5405A Calibration

2/22/2011 AUDITS, ASSESSMENTS AND SELF

-ASSESSMENTS

Number Description or Title

CYCLE 16 Date or Revision

Periodic Maintenance Effectiveness Assessment Report

5/21/20 10 DB-PA-09-04 Fleet Oversight Fourth Quarter 2009 Report for Site Protection

DB-PA-10-01 Fleet Oversight First Quarter 2010 Report for Site Protection

DB-PA-10-02 Fleet Oversight Second Quarter 2010

Attachment

AUDITS, ASSESSMENTS AND SELF

-ASSESSMENTS

Number Description or Title

Report for Site Protection

Date or Revision

DB-PA-10-03 Fleet Oversight Third Quarter Report

11/11/2010

DB-PA-10-04 Fleet Oversight Fourth Quarter 2010 Report for Site Protection

DB-SA-10-009 Implementation of Corrective Action Program 12/29/2010

DB-SA-09-042 Security Equipment Maintenance and Testing 6/9/2009 DB-SA-09-048 Site Access Controls

9/10/2009 DB-SA-09-052 EPRI PWR Secondary Water Chemistry

Guidelines

7/27/20 09 DB-SA-09-053 Operator Response to Stator Cooling Turbine Runback July 2009

7/27/20 09 DB-SA-09-070 Chemistry Parameters Trending

2/14/2009

DB-SA-10-007 Work Group Clearance

8/30/20 10 DB-SA-10-009 Implementation of Corrective Action Program 12/29/2010

IP-SA-10-157 2010 Chemistry Integrated Performance Assessment and Trending

st Quarter, 2010

IP-SA-10-251 Training Integrated Performance Assessment and Trending 10/4/2010 IP-SA-10-238 IPAT/Self-Assessment: Operations First 6 months, 2010

7/29/20 10 IP-SA-10-312 Chemistry Integrated Performance Assessment and Trending

10/21/2010

IP-SA-11-113 IPAT/Self-Assessment:

Operations Second 6 months, 2010

2/16/20 11 MS-C-09-08-22 Corrective Action Program Multi

-Site Audit

9/30/20 09 MS-C-10-08-02 Fleet Oversight Multi

-Site Audit of Chemistry and Environmental

10/14/2010 SN-IP-10-311 IPAT/Self-Assessment: Operations third quarter, 2010

11/16/20 10 SN-IP-10-322 IPAT/Self-Assessment: Emergency Preparedness third quarter, 2010

11/17/20 10 SN-IP-10-323 Training Integrated Performance Assessment and Trending

10/26/2010

SN-SA-10-255 Pre-NRC IP 59001 Inspection Assessment (Davis-Besse EP) 8/9/20 10 SN-SA-10-176 Maintenance place keeping within procedures and work orders and work order quality 7/19/20 10 SN-SA-10-352 Work Order Package Completeness and Associated Impact on the Maintenance Shops 11/2/2010 SN-SA-10-368 Cross-Cutting Aspects of NRC Inspection Report Findings for the Period October 1,2009 - September 30, 2 010 11/19/20 10

Attachment

CONDITION REPORTS GENERATED DURING INSPECTION

Number Description or Title

11-89733 Date or Revision

NRC PI&R 2011: CR Not Placed in Reject Status 2/16/2011 11-89741 Notifications not Closed by Section Plan Due Dates 2/17/2011 11-89901 Untimely Completion of Notifications Associated With CA Closure

2/21/2011 11-90280 Friction Load Not Included in Analysis of Pipe Support 33B

-GCB-2-H3 3/1/2011 11-90326 NRC PI&R 2011:

Incomplete Evaluation of Supports 33B

-GCB-2-H3 and 33B

-GCB-1-H8 3/2/2011 11-90347 NRC PI&R 2011:

Incomplete Evaluation of Supports 33B

-GCB-2-H1 and 31-HCC-5-H1 3/2/2011 11-90395 NRC PI&R 2011:

Adequacy of Self-Assessment SN

-SA-255 3/3/2011 11-91081 NRC PI&R 2011:

CR Corrective Actions did not Address Cause

3/14/2011 WORK CONTROL DOCUMENTS

Number Description or Title

200288536 Date or Revision

DB-SUB055-01 Control Rod Drive System Primary Trip Breaker

4/7/2008 200333222 DB-Spares-Breakers Unit 1 Spare Breakers

10/17/2008

600547136 Tighten Mortise Cylinder

6/9/2009 600565341 Security Vehicle Barrier

8/20/2009 600566038 DB-CH-01395; Incorporate SO 09

-011 8/25/2009 600566137 Repair wheel mounts on Mobile Platform

8/26/2009 EFFECTIVENESS REVIEWS

Number Description or Title

CR 09-51887-6 Date or Revision

SW 4691B Found Out of Position

1/12/20 09 09-60012, CA10

Maintenance and Work Order Place Keeping

7/26/2010 DB-PA-10-04 Fleet Oversight Fourth Quarter 2010

2/25/20 11 CALCULATIONS

Number Description or Title

31-HCC-5-H1 Date or Revision

Pipe Support 31

-HCC-5-H1 for Makeup and Purification System

Rev. 0 33B-GCB-1-H8 Pipe Support 33B

-GCB-1-H8 for Low Pressure Injection System

Rev. 0 33B-GCB-2-H1 Pipe Support 33B

-GCB-2-H1 for Low Pressure Injection System

Rev. 0 33B-GCB-2-H3 Pipe Support 33B

-GCB-2-H3 for Low Rev. 1

Attachment

CALCULATIONS

Number Description or Title

Pressure Injection System

Date or Revision

MISCELLANEOUS

Number Description or Title

Cycle 16 Date or Revision

Periodic Maintenance Effectiveness Assessment Report

08/26/2010

D-RPO-12 Performance Indicator

- Corrective Maintenance Backlog

Jan. 2011 D-RPO-13 Performance Indicator

- Deficient Maintenance Backlog

Jan. 2011 D-SPO-05 Performance Indicator

- Condition Report Process Health Indicator

Dec. 2010 D-SPO-05B Performance Indicator

- Open CRs >

180 Days Oct. 2010 D-SPO-05C Performance Indicator

- Open Condition Reports 2009-2010 D-SPO-05D Performance Indicator

- Condition Reports Open > 180 Days

2009-2010 D-SPO-05E Performance

Indicator

- Open Long Term Condition Reports

2009-2010 D-SPO-05C Performance Indicator

- Condition Reports Initiated 2009-2010 IN 2008-02 Findings Identified During Component Design Bases Inspections

03/19/20 08 MS-C-10-08-02 Fleet Oversight Multi

-Site Audit of Chemistry and Environmental

10/14/20 10 MRPM 29 Maintenance Rule Program Manual

Rev. 29 NOBP-OP-4111 5-Year Exposure Reduction Plan

Rev. 1 SD-049 Control Rod Drive System

Rev. 5 System-55-01-CRD System Health Report 2010

-4 02/03/20 11 ROOT AND APPARENT CAUSE EVALUATIONS

Number Description or Title

09-51887 Date or Revision

SW 4691B Found Out of Position

1/12/20 09 09-52766 Nuclear Fuel: Reactor Core Axial Power Imbalance Predicted Versus Measured

1/29/2009 09-57272 MS100 Main Steam Line 2 Isolation Valve Failed to Fully Open

6/19/2009 09-57013 NRC PI&R 2009: CR 04

-04561, Westinghouse TB

-04-13 Circuit Brkr Eval & Actions 6/1/2009 09-57849 Procedure Non

-Compliance during #1 Purification Demineralizer Outlet

4/24/2009

Attachment

ROOT AND APPARENT CAUSE EVALUATIONS

Number Description or Title

Sampling Date or Revision

09-60017 AFI PI.2-1, Causal Analysis and Precursor Problems 6/8/20 09 09-60019 Industry Feedback on High Standards and Expectations

6/8/2009 09-61025 Loss of J Bus, Catastrophic Failure of J Bus B Phase Potential Device

8/30/2009 09-65778 Misapplication of Potter & Brumfield MDR Rotary Relays

10/12/20 09 09-65837 Potter & Brumfield MDR Rotary Relay Issue For CAC's 10/13/2009

09-67079 WEAKNESSES IN THE BORON

-10 CORRECTION FACTOR PROGRAM

10/30/2009

09-68328 ACCIDENTAL DISCHARGE OF SECURITY OFFICERS WEAPON

11/27/2009

09-69162 Apparent Heat Balance Input Error (T476, TE-SP15A) 12/16/2009

09-69475 White Finding Identified For Inadequate Emergency Classification Of Event

2/30/2009

10-70583 DB-PA-09-04: Site Protection Rated Marginally Effective for Fourth Quarter 2009

1/25/2010 10-74253 DB-PA-10-01: Finding:

ISI Program Plan Not Updated to meet 10CFR50.55A Rqmt

9/7/2010 10-78632 DB-PA-10-02 - Declining Trend in Human Performance

6/22/20 10 10-79651 Failure To Notify NRC Of Unanalyzed Condition In 8 Hours 7/14/20 10 10-81852 CNRB - Improving Implementation of the Corrective Action Program

8/27/20 10 10-81863 CNRB - Potential Decline In Emergency Preparedness

8/27/20 10 10-82447 INCORRECT SIMULATOR EAL DECLARATIONS

9/9/2010 10-82780 MS-C-10-08-02 FINDING CHEMISTRY LAB QC PROGRAM IMPLEMENTATION

9/17/2010 10-85144 NRC-NCV: Inadequate Procedure For a Loss Of Coolant Accident Outside Containment

10/30/20 10 10-85453 Safety Control Rod 3

-4 Ratcheted In from

100 percent to 72 percent

11/05/2010

11-87721 SFRCS ACH 2 Output Logic LED Failed To Illuminate

1/4/20 11 11-88100 PRZR Code Safety Valves Setpoint Failure Reporting 1/12/20 11 RCAR, 10-85453 Safety Control Rod 3

-4 Ratcheted In from

100 percent to 72 percent Withdrawn 2/05/20 11

Attachment

LIST OF ACRONYMS USED

ACE Apparent Cause Evaluation CA Corrective

Action CAP Corrective

Action Program

CARB Corrective Action Review Board

CDBI Component Design Basis Inspection

CR Condition Report ECP Employee Concern s Program IMC Inspection Manual Chapter

IN Information Notice

OE Operating Experience PI&R Problem Identification and Resolution

SCWE Safety-Conscious Work Environment

B. Allen -2- In accordance with

CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading

-rm/adams.html

(the Public Electronic Reading Room)

. Sincerely, /RA/ Jamnes

L. Cameron, Chief Branch 6 Division of Reactor Projects

Docket No. 50

-346 License No. NPF-3 Enclosure:

Inspection Report 05000

346/2011008 w/Attachment: Supplemental Information

cc w/encl:

Distribution via ListServe

DOCUMENT NAME:

G:\DRPIII\DAVI\Davi 2011 008.docx

Publicly Available

Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII NAME PSmagacz:dtp JLC for JCameron DATE 04/19/11 04/19/11 OFFICIAL RECORD COPY

Letter to B. Allen from J. Cameron dated

April 19, 2011.

SUBJECT: DAVIS-BESSE NUCLEAR POWER

STATION - NRC PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION 05000 346/2011008