IR 05000237/2019004

Integrated Inspection Report 05000237/2019004 and 05000249/2019004

ML20030A139
Person / Time
Site:	Dresden
Issue date:	01/29/2020
From:	Dave Hills NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019004
Preceding documents:	ML19226A371 (14 August 2019)
Download: ML20030A139 (41)

Text

January 29, 2020

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2019004 AND 05000249/2019004

Dear Mr. Hanson:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On January 10, 2020, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

Five findings of very low safety significance (Green) are documented in this report. Five of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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 Dresden Nuclear Power Station, Units 2 and 3.

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 Dresden Nuclear Power Station, Units 2 and 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

David E. Hills, Chief Branch 1 Division of Reactor Projects

Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000237 and 05000249

License Numbers:

DPR-19 and DPR-25

Report Numbers:

05000237/2019004 and 05000249/2019004

Licensee:

Exelon Generation Company, LLC

Facility:

Dresden Nuclear Power Station, Units 2 and 3

Location:

Morris, IL

Inspection Dates:

October 01, 2019 to December 31, 2019

Inspectors:

J. Corujo-Sandin, Senior Resident Inspector

M. Domke, Reactor Inspector

G. Edwards, Health Physicist

R. Elliott, Resident Inspector

T. Go, Health Physicist

R. Murray, Senior Resident Inspector

A. Nguyen, Senior Resident Inspector n

C. Phillips, Project Engineer

M. Porfirio, Illinois Emergency Management Agency

A. Shaikh, Senior Reactor Inspector

P. Smagacz, Resident Inspector

C. St. Peters, Reactor Engineer

L. Torres, Illinois Emergency Management Agency

Approved By:

David E. Hills, Chief

Branch 1

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, 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 Identify and Control Hot Work Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000237/2019004-01 Open/Closed

[H.2] - Field Presence 71111.05Q The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.c, for the licensees failure to establish, implement, and maintain Fire Protection Program procedures which ensure fire prevention for hot work. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work," Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Inaccurate and Incomplete Post Maintenance Testing Documentation for Containment Isolation Valve 2-1301-2 Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000237/2019004-02 Open/Closed

[P.1] -

Identification 71111.19 On November 12, 2019, the inspectors identified a Green finding and associated non-cited violation when the licensee failed to have acceptance criteria for testing containment isolation valves per Technical Specification Surveillance Requirement 3.6.1.3.5, in accordance with 10 CFR 50, Appendix B, Criterion V, and identify and document the action taken in regard to a deficiency in a quality record in accordance with 10 CFR 50, Appendix B, Criterion XVII.

Failure to have Appropriate Installation Procedure for Relief Valve 2-4899-72 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237/2019004-03 Open/Closed

[H.9] - Training 71111.19 On November 14, 2019, a self-revealed Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings," was identified when the licensee failed to have an appropriate procedure for the installation of the Unit 2 containment cooling heat exchanger shell side relief valve.

Failure to Survey for Work Conducted in a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000249,05000237/2019004-04 Open/Closed

[H.14] -

Conservative Bias 71124.01 A self-revealed finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General was identified by inspectors when the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507' Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Failure to Positively Control a Door That Granted Access to a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000237/2019004-05 Open/Closed

[H.8] -

Procedure Adherence 71124.01 A self-revealed finding of very low safety significance (i.e. Green) and an associated NCV of 10 CFR 20.1601 (a)(3) was identified by inspectors when the licensee failed to lock and demonstrate positive control over a door that is the access point to an area having general area dose rates of approximately 3000 mrem/hour at 30 cm from the radiation source.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period in coast down to prepare for refueling outage D2R26.

The unit came offline on October 27, 2019, to commence D2R26. The refueling outage ended and the unit synchronized to the grid on November 15 and returning to full power on November 16, 2019. On December 9, 2019, the unit was down powered to 22 percent due to unidentified reactor coolant system leakage and returned to full rated thermal power on December 11, 2019. On December 14, 2019, power was reduced to 62 percent for a rod pattern adjustment and returned to full rated power the next day. On December 22, 2019, operators reduced electrical power to 65 percent for a complete rod pattern adjustment and returned to full power the same day. On December 28, 2019, the unit was down powered for a forced outage (D2F59) to repair a generator hydrogen leak and remained in that condition for the remainder of the inspection period.

Unit 3 began the inspection period at full power. On December 3, 2019, the unit was down powered to 82 percent for rod pattern adjustments and 3D3 feed water heater leak repair. The unit returned to full rated thermal power on December 7, 2019, and operated there for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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

Seasonal Extreme Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme cold temperatures and conditions that could adversely affect the ultimate heat sink such as ice blockages and frazil ice

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 2 shutdown cooling on October 28 - 30, 2019

(2) Unit 2 fuel pool cooling with alternate decay heat removal on November 5, 2019

(3) Unit 2 emergency diesel generator on November 5, 2019

(4) Unit 2 AC power while on 4kv cross ties during October 30 through November 5, 2019

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (4 Samples)

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

(1) Fire Zone (FZ) 1.2.2, U2 Drywell Primary Containment, elevation 517 on November 1, 2019

(2) FZ 8.2.5B, U2 Low Pressure Heater Bay, elevation 517 on October 31, 2019

(3) FZ 8.2.5A, U2 High Pressure Heater Bay, elevation 517 on November 7, 2019

(4) FZ 11.3, Unit 2/3 Circulating Water Pumps, elevation 490'; Unit 2/3 Service Water Pumps / Traveling Screens, elevation 509'; and Unit 2/3 Crib House Ground Floor, elevation 517' on December 30, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) 2/3 Cribhouse (Submersible Emergency Diesel Generator Cooling Water Pumps)

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 30, 2019 to November 6, 2019:

03.01.a - Nondestructive Examination and Welding Activities.

• Volumetric, manual ultrasonic examination of low pressure coolant injection system piping welds 2/1/1519-16/16-K5 and 2/1/1519-16/16-K6, ASME category R-A, items R1.11/R1.16 located in the drywell

• Volumetric, manual ultrasonic examination of reactor recirculation system welds 2/1/0201A-22/L1/L2 and 2/1/0201A-28/PD1A/L2 and 2/1/0201A-22/L2-D17 and 2/1/0201A-28/PD1A-D15, augmented IGSCC category D, located in the drywell

• Surface, magnetic particle examination of low pressure coolant injection heat exchanger support 2-1503-B located in the reactor building

• Pressure boundary weld review for jet pump instrumentation nozzle overlay weld for weld number 6 designated JP1A/N20A-6

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from April through May 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during Plant Shutdown for Refueling Outage, D2R26, on October 25 and October 27, 2019, and Plant Startup on November 14 - 15, 2019

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

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

(1) Fuel Pool Radiation Monitor (a)(1) AR4276469

(2) Control Rod Drive System WO 04768029-03

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 2 Yellow Risk for Lowered Inventory during outage on October 29, 2019 (2)4kv Crosstie after maintenance on October 30, 2019

(3) Plant Risk associated with performing Unit 2, Division 1 undervoltage test on November 5, 2019

(4) Fire Risk associated with removing the 2/3 service water pump from service on November 6, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (7 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) D2R26 Main Steam Isolation Valve Timing Issues

(2) D2R26 Local Leak Rate Test Local Leak Rate Test (LLRT) Feedwater 0220-62A failed LLRT as found conditions

(3) D2R26 Motor Operated Valve 2-1301-2 actuator degradation

(4) D2R26 Relief Valve 2-4899-72 post installation operability

(5) Historical Operability Review: Low Pressure Coolant Injection Loop Logic (DPIS 2-0261-35C)

(6) Part 21 Emergency Diesel Generator Seized Fuel Injector Plunger and Bushing

(7) High Pressure Coolant Injection and post-fire safe shutdown operation

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) U2 High Pressure Coolant Injection closure control MOV 2-2301-8

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Work Order (WO) 04590899, Unit 2 low pressure coolant injection valve on November 2, 2019

(2) Unit 2 Source Range Monitor 22 prior to fuel moves in SE quadrant on November 7 and 8, 2019

(3) WO 04771815, Unit 2 - 59 Main Steam Isolation Valve key interlock bypass test on November 9, 2019

(4) WO 04708044-01, Unit 2 Scram Dump Valves on November 11, 2019

(5) WO 01704408-01, Unit 2 2B Reactor Recirculating Pump Seal on November 11, 2019

(6) WO 04741694, 2A Reactor Recirculating pump on November 12, 2019

(7) Motor Operated Valve 2-1301-2 after control circuit work on November 12, 2019

(8) WO 04856283-01, 2B Control Rod Drive Pump on November 13, 2019

(9) WO 04797506-20, D2R26 PMTs [post maintenance tests] Required Prior to Entering Mode 2, relief valve 2-4899-72 post installation testing on November 19, 2019

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample 1 Partial)

(1) The inspectors evaluated Unit 2 refueling outage D2R26 activities from October 27 to November 14, 2019 (2)

(Partial)

The inspectors evaluated a forced outage, D2F59, due to Unit 2 Generator Hydrogen Leak which began December 28, 2019, and continued into the year 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Low Pressure Coolant Injection Logic System Functional Test (LSFT)on October 3, 2019, WO 04701722

(2) Unit 2 Reactor Cooldown Rate Monitoring on October 28, 2019

(3) Unit 2 Division 1 Under Voltage Test on November 4, 2019

(4) Unit 2 Anticipated Transient Without Scram LSFT per DIS 0263-08 (2 parts),

WO 04718556 on October 29 and November 6, 2019

Containment Isolation Valve Testing (IP Section 03.01) (2 Samples)

(1) Unit 2 Local Leak Rate Testing of Main Steam Isolation Valves (MSIV) 203-1A &

203-2A as per WO 04711481 on October 28, 2019

(2) Unit 2 Reactor Water Clean Up - Local Leak Rate Testing of Primary Containment Isolation Valve as per WO 04797506 on October 30,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 02.01) (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

(1) The inspectors reviewed the following:

Radiological Surveys

• Survey 2019-056853; Reactor Building Equipment Drain Tank Room

• Survey 2019-056188; 2/3 Radwaste 507' Barrel Area Basement

• Survey 2019-053762; 2/3 Radwaste 507' Barrel Area Basement

Risk Significant Radiological Work Activities

• Reactor Building Equipment Drain Tank Hydrolasing

• 2/3 Radwaste 507' Barrel Area Basement Hydrolasing

• D3R25 Drywell Control Rod Drive Exchange

Air Sample Survey Records

• Survey 2019-055827; Unit 2 Reactor Building Equipment Drain Tank Room

• Survey 2019-056853; Unit 2 Reactor Building Equipment Drain Tank Room

• Survey 2019-121830; Unit 2 Cavity N/E

Instructions to Workers (IP Section 02.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.

(1) The inspectors reviewed the following:

Radiation Work Packages

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1

• DR-2-19-00233; Radwaste Concentrator Maintenance; Revision 00

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs

Electronic Alarming Dosimeter Alarms

• Electronic Alarming Dosimeter Dose Rate Alarm on 2/3 Radwaste 507' Barrel Area Basement on 10/22/2019

Labeling of Containers

• Trash Container Located in Dresden Radwaste

• Trash Container Located in Dresden 2/3 Turbine Building

• Trash Container Located in Dresden 2/3 Reactor Building

Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) The inspectors verified the following sealed sources are accounted for and are intact:

• Small Plate Source; Cs137

• Small Plate Source; Cs137

Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

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

(1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1

High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

(1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.02 - Occupational ALARA Planning and Controls

Implementation of ALARA and Radiological Work Controls (IP Section 02.03) (1 Sample)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls.

(1) The inspectors reviewed the following activities:

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs; Revision 1

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:

• Advance Liquid Processing System (ALPS) Radwaste Area 517'

• Sea Vans Storage Yard located at Protected Area

• Radwaste Barreling Area 519'

• Unit-2/3 Radwaste 519' Stock Area and Truck-bay Area

The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:

• Turbine Equipment Sealand

• Reactor Building Equipment Sealand

• Torus Filters Sealand

• B-25 Box Containing Contaminated Hoses

• B-25 Box Containing Condensate Storage Tank Equipment

• Sealand for Shipment of Rolls-Royce Equipment DM-19-142

Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Advance Liquid Processing System (ALPS) Radwaste Area 517'

• Dry Active Waste (DAW) Processing at Radwaste Barreling Area 519'

Radioactive Waste Resin and/or Sludge Discharges Processes

• Sluicing of Resin Bed from ALPS Filter Tanks at 517' to a High Integrity Container (HIC) in the Radwaste Building 519'

Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

(1)

• 2019 DAW -10CFR61 Database Analysis

• 2019 Unit-2/3 Condensate Resin 10CFR61 Analysis

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated and observed the following radioactive material shipment preparation processes:

(1) DM-19-142; Rolls Royce Equipment to Roll-Royce Nuclear Field Service, UN3321, Low Specific Activity (LSA-II)

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)

• DM-19-142; UN3321, Radioactive Material, Low Specific Activity (LSA-II), 7; to Rolls Royce Nuclear Services

• DW-18-012; UN3321, Radioactive Material, LSA-II, 7; U-1 Dry Active Waste (DAW) to Energy Solution's Bear Creek Facility

• DW-19-019; UN3321, Radioactive Material, LSA-II, 7; Sludge from B-Max Waste to Energy Solution's Bear Creek Facility

• DW-19-030; UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to Energy Solution's Bear Creek Facility

• DM-19-021; UN2915, Radioactive Material, Type-A Package, 7; Shepherd Seal Source (A1 Special Form) in a Type-A Drum to J.L. Shepherd Facility

• DW-19-009; UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to Energy Solution's Bear Creek facility

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

(1) Unit 2, October 1, 2018 - September 30, 2019

(2) Unit 3, October 1, 2018 - September 30, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 2, October 1, 2018 - September 30, 2019

(2) Unit 3, October 1, 2018 - September 30, 2019

71152 - Problem Identification and Resolution

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

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the fire protection program implementation during the last year that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Non-Cited Violation for Security Equipment Loss of Power as documented in Inspection Report 05000237/2019411; 0500249/2019411 (ML19339D759 issued December 5, 2019)

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated 2D3 high pressure feedwater heater leak repair and licensees response on November 19 - 22, 2019

(2) The inspectors evaluated Unit 2 downpower and drywell entry for identifying/correcting increasing unidentified reactor coolant system leakage and licensees response on December 9,

INSPECTION RESULTS

Failure to Identify and Control Hot Work Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events

Green NCV 05000237/2019004-01 Open/Closed

[H.2] - Field Presence 71111.05Q The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.c, for the licensees failure to establish, implement, and maintain Fire Protection Program procedures which ensure fire prevention for hot work. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work," Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Description:

On November 6, 2019, during the Unit 2 refueling outage (Reactor in Mode 5), the inspectors observed contract pipe-fitters performing grinding work, using a flapper wheel, which resulted in visible sparks inside the drywell. The two workers were preparing to install small bore piping for the 2A Reactor Recirculating pump nozzles. The inspectors were unable to locate a hot work permit, fire watch, or fire extinguisher in the work area. The inspectors asked one of the workers if he was the fire watch and if there was a fire extinguisher available for the hot work. The worker replied he was not the fire watch and that hot work had not yet started.

The inspectors informed the workers that visible sparks are considered hot work. While one continued with the grinding, the other worker searched the work area for a fire extinguisher and then exited the drywell to continue searching for a fire extinguisher. After approximately 10 minutes, the inspectors exited the drywell and again informed the worker that grinding was still occurring without a hot work permit present, a fire watch, or a fire extinguisher. At this time, the worker returned to the work area and informed the other individual to stop the job.

The inspectors reviewed several of the licensees fire protection implementation procedures including OP-AA-201-004, Fire Prevention for Hot Work, Revision 16 and CC-AA-501-1027, Hot Work Precautions and Safety Practices, Revision 2. These procedures outline the site's policies regarding the proper control of hot work. Procedure OP-AA-201-004, Section 2.3 defined, in part, "Hot Work" as work activities that involve welding, cutting, grinding and open flame operations that are capable of initiating fires or explosions. Section 4.1.9 stated, in part, that "an operable Exelon fire extinguisher appropriate for the class of fire that could occur shall be available and conveniently located in the work area." Section 4.2.4 stated, a designated fire watch is required during the performance of all hot work operations governed by this procedure. Section 4.2.7 stated, The fire watch shall be aware of the location of fixed fire extinguisher(s) in the area and visually observe the fixed extinguisher to confirm that it appears to be in good condition prior to starting the hot work activityor have an additional Exelon fire extinguisher that is appropriate for the hazard readily available." Section 4.3.1 stated, An authorized hot work permit is required before any hot work operation is started within the protected area and the permit must be properly filled out and posted at the job site before the operation commences." In addition, procedure CC-AA-501-1027, Section 2.2 defines "Hot Work" as all processes that use or created an arc, flame, spark, or intense heat.

These includes welding, cutting, gouging, grinding, and open flame operations."

Based on their review, the inspectors determined the work performed met the definition of "hot work" and needed to be controlled under the site's requirements for such work.

Specifically, the licensee did not have a hot work permit posted at the job site, no designated fire watch, and no fire extinguisher readily available.

Corrective Actions: In response to the inspectors observation, the workers stopped the grinding activities and licensee managers met with the crew. Licensee managers informed the workers they should have stopped when they started producing sparks, acquired a fire extinguisher, established a fire watch, signed into their hot work permit, and then continued work. In addition, the licensee performed a Work Group Evaluation.

Corrective Action References: AR 4295218, Visible Sparks During 2A RR Pump Bowl Piping."

Performance Assessment:

Performance Deficiency: The inspectors determined the licensees failure to follow fire protection program implementing procedures regarding fire prevention for hot work was contrary to Technical Specification 5.4.1.c, which required that written procedures covering Fire Protection Program implementation, be established, implemented, and maintained and was a performance deficiency. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work, Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, failing to comply with fire protection procedure requirements while performing hot work (e.g.

without a designated fire watch and fire extinguisher) increases the fire hazards to the plant by delaying the time it would take to identify and mitigate a potential fire resulting from the hot work.

Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. Specifically, the inspectors determined this finding was of very low safety significance (Green) because the performance deficiency was not expected to increase the likelihood of a fire that would cause a Shutdown Initiating Event, as defined in IMC 0609 Appendix G. This was determined based on the specific work being performed and the very limited combustibles observed in the work area.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the licensee's lack of field presence during the contractors grinding prevented them from promptly correcting the expectations for hot work.

Enforcement:

Violation: Technical Specification 5.4.1.c, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the following activities: Fire Protection Program Implementation.

Procedure CC-CC-211, "Fire Protection Program," Revision 8, described the site's Fire Protection Program. Section 4.8.1 designated procedure OP-AA-201-004 as the administrative positive control process over hot work (via a permit system).

Procedure OP-AA-201-004, "Fire Prevention for Hot Work," Revision 17:

Section 2.3 defined, in part, "Hot Work" as work activities that involve welding, cutting, grinding and open flame operations that are capable of initiating fires or explosions.

Section 4.1.9 required, in part, that an operable Exelon fire extinguisher appropriate for the class of fire that could occur shall be available and conveniently located in the work area.

Section 4.2.4 stated, in part, that a designated Fire Watch is required during the performance of all hot work operations governed by this procedure.

Section 4.3.1 stated, an authorized Hot Work Permit is required before any hot work operation is started within the protected area and inside any building located outside the protected area unless the location is a Designated Hot Work Area. The permit must be properly filled out and posted at the job site before the operation commences.

Contrary to the above, on November 6, 2019, the licensee failed to implement procedures covering activities regarding the Fire Protection Program implementation. Specifically, the licensee failed to follow the requirements of procedure OP-AA-201-004. The licensee failed to:

(1) realize the grinding work being performed was considered hot work;

(2) obtain an appropriate fire extinguisher;

(3) designate a fire watch during the performance of the hot work; and

(4) fill and post the Hot Work Permit.

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

Inaccurate and Incomplete Post Maintenance Testing Documentation for Containment Isolation Valve 2-1301-2 Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity

Green NCV 05000237/2019004-02 Open/Closed

[P.1] -

Identification 71111.19 On November 12, 2019, the inspectors identified a Green finding and associated NCV when the licensee failed to have acceptance criteria for testing containment isolation valves per Technical Specification Surveillance Requirement 3.6.1.3.5, in accordance with 10 CFR 50, Appendix B, Criterion V, and identify and document the action taken in regard to a deficiency in a quality record in accordance with 10 CFR 50, Appendix B, Criterion XVII.

Description:

On October 28, 2019, per the licensee's motor operated valve test program, an as-found diagnostic test was perfomed (Work Order 01693537-01, D2 3RFL Com MOV Elect Insp &

Diagnostic Testing 2-1301-2) on an isolation condenser containment isolation valve 2-1301-2 and the work order documentation stated that the valve passed the test. The licensee was also required to do an internal inspection of the valve actuator and found some degradation.

The licensee repaired the degradation and performed another as left diagnostic test (WO 01742662-09, MOV 2-1301-2 Stem Scoring Nut Rust) on November 9, 2018, which the work order documentation stated was acceptable. However, the valve failed to operate from the control room and additional maintenance was performed. The licensee performed post-maintenance testing on the 2-1301-2 on November 12, 2019, which consisted of closing the valve from the control room.

On November 12, 2019, the inspectors observed the post-maintenance testing of primary containment isolation valve 2-1301-2. During the test the licensee timed the valve closure in accordance with DOS 1300-02, Isolation Condenser Valve Operability Check, Revision 21, Step I.5, which was labeled as acceptance criteria within the procedure. The inspectors questioned against what criteria the closure time of the valve was to be compared against to determine operability. The licensee responded that the station was no longer required to time motor operated valves and that valve closure was sufficient to determine operability. The inspectors questioned how the licensee met Technical Specification Surveillance Requirement 3.6.1.3.5, which required the verification that the isolation time of each primary containment isolation valve was within limits. The licensee responded that the Technical Specification Surveillance Requirement was met when the valves were timed during diagnostic testing required by the motor operated valve test program requirements. The inspectors reviewed the as-found diagnostic testing work order performed on October 28, 2019, and the as left diagnostic testing work order performed on November 9, 2019, for the 2-1301-2 valve. The valve was timed during the diagnostic test but the inspectors thought there was no quantitative or qualitative acceptance criteria in the work order documentation.

The inspectors met with members of the licensee's engineering staff on November 21, 2019.

The licensee's staff pointed out there was a line in the as-found work order documentation that stated that the maximum valve closure time was 22.84 seconds and that this was the acceptance criteria. The inspectors pointed out that the actual valve closure time was 28.6 seconds and that the work order documentation stated that the valve passed the test even though the test documentation showed otherwise. The licensee stated that they were aware of this discrepancy at the time of the as-found test and had evaluated the results and later determined the test result was satisfactory. The licensee stated that the 22.84 second acceptance criteria was incorrect and should have been much closer to the actual 28 second closure time. The inspectors asked if this evaluation was documented in a corrective action document or in the work order documentation that the inspectors were not aware of. The licensee stated that the evaluation determination was not documented in the work orders.

The inspectors pointed out the as-found test was performed 12 days before the as-left test and the discrepancy with incorrect acceptance criteria still existed in the as-left test documentation and had not been corrected. Quantitative acceptance criteria for timing of primary containment isolation valves was located in Appendix A of the Technical Requirements Manual which was not referenced in the work order. However, since the valve closure limit time was 45 seconds as listed in Appendix A of the Technical Requirements Manual and the valve closed in about 28 seconds the inspectors had no concern with the operability of the valve.

Corrective Actions: The licensee planned to ensure actions were in place to revise the MOV work orders instructions to document results, ensure accurate acceptance criteria, require written resolution or create a corrective action document for deficiences, and reference Technical Specification and Technical Requirements Manual requirements. An extent of condition review for similar deficiences was planned.

Corrective Action References: AR 4299125, MOV Stroke Time Documentation Issue AR 4300288, NRC Quality Assurance of MOV Work Oders AR 4301626, MOV 2-1301-2 Documentation Inquiry AR 4299431, MOV Program Improvements Resulting from IR 4299125

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's work orders that covered the testing of valve 2-1301-2 required by Technical Specification Surveillance Requirement 3.6.1.3.5 to verify that the closure time of primary containment isolation valves were within limits did not have appropriate acceptance criteria. Procedures that affect quality were required to contain appropriate acceptance criteria in accordance with 10 CFR 50, Appendix B, Criterion V. Valve 2-1301-2 was a safety-related valve and Technical Specification Surveillance Requirement 3.6.1.3.5 was an activity that affected quality. The valve was returned to service and both the work orders were closed without any documentation of the action taken in connection with the deficiency associated with the acceptance criteria as required by 10 CFR 50, Appendix B, Criterion XVII. This was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to have appropriate acceptance criteria in technical specification surveillance test procedures impacted the procedure quality attribute to ensure the valve worked properly in service.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding did not constitute an actual open pathway in the physical integrity of the reactor containment and and there are no hydrogen ignitors at Dresden so therefore the finding screened as Green.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, had the workers identified that the incorrect acceptance criteria was a problem and addressed the issue in the work order documentation this violation would not have occurred.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, required that 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.

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVII, Quality Assurance Records, required, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include the action taken in connection with any deficiencies noted.

The licensee established Work Orders 01693537-01 and 01742662-09 as the implementing procedures for verifying the closing time of containment isolation valve 2-1301-2 in accordance with Technical Specification Surveillance Requirement 3.6.1.3.5, an activity affecting quality.

Contrary to the above,

A. On October 28, and November 9, 2019, the licensee conducted motor operated valve diagnostic testing on safety-related valve 2-1301-2, an isolation condenser primary containment isolation valve, an activity affecting quality, with Work Orders 01693537-01 and 01742662-09 that did not include appropriate acceptance criteria. The acceptance criteria listed in the Work Orders was inaccurate, causing the documentation to show that the valve failed the timing test.

B. On November 12, 2019, both work orders 01693537-01 and 01742662-09 contained information indicating the tests performed were unsatisfactory in that the time required for the valve to close was deficient in that it did not meet the acceptance criteria given. The valve was returned to service and both the work orders were closed without any documentation of the action taken in connection with the deficiency associated with the acceptance criteria still in the work order.

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

Failure to have Appropriate Installation Procedure for Relief Valve 2-4899-72 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000237/2019004-03 Open/Closed

[H.9] - Training 71111.19 On November 14, 2019, a self-revealed Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings," was identified when the licensee failed to have an appropriate procedure for the installation of the Unit 2 containment cooling heat exchanger shell side relief valve.

Description:

On November 13, 2019, while Unit 2 was in Mode 2, torus level lowered to -6.16" resulting in the licensee entering T.S. 3.6.2.2, Condition A on Suppression Pool Water Level not within limits per DOS 1600-16, Suppression Chamber Water Level Correction. The licensee also entered DEOP 200-01, Primary Containment Control, per DOP 1600-02, Torus Water Level Control, limitations. The operators filled the torus using high pressure coolant injection (HPCI) per DOP 1600-02.

On November 14, 2019, the licensee was troubleshooting the emergency core cooling system (ECCS) keep fill system as part of the torus level lowering, and identified the 2A Containment Cooling Heat Exchanger Shell Side Relief Valve (2-4899-72) was open.

The licensee reset the valve to the closed position. The relief valve had been replaced in refueling outage D2R26 per Work Order 04709186-01 on November 6, 2019. The inspectors questioned if the relief valve had undergone post-maintenance testing. The licensee responded the valve had been tested on November 11, 2019, and that the testing was considered satisfactory. The inspectors questioned how the relief valve was not reset after the post-maintenance testing. The licensee stated the relief valve has a mechanical gag that can be operated from a lever installed at the top of the valve. Determining whether the valve was open or closed was not part of the post-maintenance testing.

The inspectors met with the licensee staff on November 19, 2019. The inspectors asked the licensee if the control room received an alarm for low torus level. The licensee stated the alarm was already lit for other work being done. The inspectors asked the licensee if any of the pumps aligned to the torus would have a potential to vortex. The licensee pointed out based on the recorded level, the vortex limit was not expected to occur. The inspectors also asked about the operability of the ECCS systems. The licensee stated there were no loss of safety function due to the HPCI turbine exhaust remaining covered as well as the relief valve quenchers remaining covered. The licensee also pointed out that HPCI was not required to be operable until reactor pressure reaches 150 psig and the reactor had been at 0 psig so based on this information as well, the licensee observed that all safety functions had been met for the ECCS systems.

Corrective Actions: The licensee closed relief valve 2-4899-72. The licensee planned to perform a Corrective Action Program Evaluation (CAPE) and generate corrective actions from the results.

Corrective Action References: AR 4297084, DEOP 200-01 Entry for Low Torus Water Level AR 4297420, Relief Valve 2-4899-72 Identified to be Lifted AR 4303551, 4.0 Critique - Unplanned Entry into TS 3.6.2.2 & DEOP 200-1

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's work order for installation of relief valve 2-4899-72, a safety-related component, did not contain appropriate instructions for installation. The licensee's failure to have appropriate work instructions for verifying the relief valve was installed in the correct position was contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings."

Specifically, the work order failed to have instructions to verify the relief valve was closed after its installation. This was a performance deficiency.

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. Specifically, this condition resulted in the inoperability of the suppression pool which is the safety source of water for ECCS systems.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding did not constitute an actual loss of probable risk assessment functionality for the suppression pool and ECCS systems, and therefore screens to Green.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the workers installing relief valve 2-4899-72 did not have the knowledge to recognize the valve was open, and that the relief valve was installed in the incorrect configuration.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.

The licensee established Work Order 04709186-01 as the implementing procedure for installing relief valve 2-4899-72, an activity affecting quality.

Contrary to the above, from November 6 to November 14, 2019, the licensee failed to have a procedure appropriate for the circumstances for the installation of relief valve 2-4899-72, a safety-related component. Specifically, the work order did not have a step to verify relief valve 2-4899-72 was installed in the correct position.

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

Failure to Survey for Work Conducted in a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety

Green NCV 05000249,05000237/2019004-04 Open/Closed

[H.14] -

Conservative Bias 71124.01 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General was identified by inspectors when the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Description:

On October 21, 2019, three individuals accompanied by a Radiation Protection Technician (RPT) entered the Unit 2/3 Radwaste Basement Barreling Area to complete hydrolasing work that was being conducted in support of the installation of the new Advanced Liquid Processing Station at Dresden Station. During the initial attempt to complete the task, the individuals involved with the work experienced issues with the hydrolasing equipment which caused the individuals and the RPT to exit the Unit 2/3 Radwaste Basement Barreling Area to troubleshoot the issue. During the troubleshooting session, it was decided that the individuals would use a drain port that was in a back corridor of the Radwaste Barreling Area to drain excess water from the hydrolasing equipment that was causing the issues with the task. Access to that area was not included in the original scope of the work activity. The troubleshooting session also involved discussions around how transient conditions existed in the back corridor due to a previous resin transfer that had occurred in the area.

The individuals returned to the Radwaste Barreling Area with a different RPT than who initially covered the job. Before the work resumed, the RPT surveyed the area of the back corridor that contained the drain port only. This survey revealed conditions that were less than 20 mrem/hour general area. When the work was resumed, the individuals began taking turns proceeding to the back corridor to place the excess water into the drain port. While traveling to the back corridor to empty the water in the drain port, one of the individuals heard a loud sound in the opposite direction of the drain port when they entered the corridor. The individual felt that this sound may be result of the issues that the work crew had been experiencing with the hydrolasing equipment and took 2 steps in this direction (to the left) to investigate this noise. The individual then received an electronic dosimeter dose rate alarm of 567 mrem/hour. When RP became aware of elevated dose rates, an RPT measured dose rates that ranged from 400 mrem/hour to 2500 mrem/hour at 30 centimeters from the source of radiation (resin transfer piping) that was unknown yet accessible to workers in the area without barricades to prevent authorized access.

Corrective Actions: When the licensee became aware of elevated dose rates due to the electronic dose rate alarm that was received by an individual conducting work in the area, an RPT was sent to the Unit 2/3 Radwaste Barreling Area to perform follow-up surveys. The survey results revealed dose rates that ranged from 400 mrem/hour to 2500 mrem/hour at 30 centimeters from the source of radiation (resin transfer piping). The licensee also conducted interviews with all involved parties to gain further insights into the cause of the event and to aide in creating an operating experience tool for future reference. Supervisors were also required to observe high radiation area briefings and to periodically shadow technicians in the field while taking radiation surveys.

Corrective Action References: AR 4290588, "Dose Rate Alarm While Working in the Radwaste Basement"

Performance Assessment:

Performance Deficiency: The licensee did not make surveys (as required by 10 CFR 20.1501 (a)(1)) to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the licensee did not make surveys (as required by 10 CFR 20.1501 (a)(1)) to assure compliance with 10 CFR 20.1601 (a)(3) which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. The licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (i.e., Green) because:

(1) it did not involve as-low-as reasonably-achievable planning or work controls,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee determined that the RP staff knew that a resin transfer had occurred within the area in question and failed to perform a radiation survey. The decision to not survey the area after a resin transfer had occurred was deemed to be non-conservative. Consequently, this led to individuals entering an area where dose rates were not known and/or established.

Enforcement:

Violation: Title 10 CFR 20.1501 (a)(1) requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Contrary to the above, on October 21 2019, the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Barrel Area Basement and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

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

Failure to Positively Control a Door That Granted Access to a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety

Green NCV 05000237/2019004-05 Open/Closed

[H.8] -

Procedure Adherence 71124.01 A self-revealed finding of very low safety significance (i.e. Green) and an associated non-cited violation (NCV) of 10 CFR 20.1601 (a)(3) was identified by inspectors when the licensee failed to lock and demonstrate positive control over a door that is the access point to an area having general area dose rates of approximately 3000 mrem/hour at 30 cm from the radiation source.

Description:

On October 29, 2019, the licensee continued to conduct piping modification work in the Unit 2 Reactor Building Equipment Drain Tank Room (RBEDT Room). At the end of the shift, the workers and the RP technician responsible for covering the job exited the area, but the RP Technician failed to have another technician verify that the door leading into the Unit 2 RBEDT Room had been locked and secured. The RP Technician then performed shift turnover with the new RP Technician that would be covering the job on the next shift. When the new RP Technician approached the door with the new work crew, a member of the work crew pointed out to the RP Technician that the door did not appear to be locked. The RP Technician verified this claim, and the door was unlocked. The RP Technician immediately entered the area to verify that no individuals were currently in the room and to perform follow up surveys to verify if conditions in the room had changed. Conditions in the room were unchanged and were consistent with the initial survey data that showed the Tank in the Unit 2 RBEDT Room having dose rates of 5000 mrem/hour on contact, and 3000 mrem/hour at 30 centimeters from the radiation source. After the survey, the RP Technician did not allow the new shift work in the room to begin. The RP Technician immediately reported the event to their supervisor, and the Radiation Protection Manager was also notified. The site performed a stand down of work activities in the area until the prompt investigation of the event was completed. The investigation revealed that the failure to verify that the door had been locked at the end of the previous shift was the primary cause for this event.

Corrective Actions: The licensee initiated a high radiation area (HRA) door verification practice that involved supervisors verifying that HRA doors were secured and locked after technicians had verified that the doors were secured and locked also. The licensee also verified that all HRA doors at the facility were secured and locked regardless of if the room had been accessed during this time frame. The licensee also placed door guards at the Unit 2 RBEDT Room until the job was completed, and also notified the NRC Resident Inspection staff and Regional Inspector.

Corrective Action References: AR 4292469, "U2 REBT Room Door Left Unsecured"

Performance Assessment:

Performance Deficiency: The licensee failed to lock and demonstrate positive control over a door that is the access point to an area where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. The area had been posted as an HRA and controlled by a locked door in accordance with 10 CFR 20.1601 (a)(3). General Area dose rates were measured up to 3 Rem/hour.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to lock and demonstrate positive control over a door that is the access point to an HRA could have led to an individual being exposed to dose rates that were greater than or equal to 3 Rem (30 mSv) at 30 centimeters from the radiation source.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (i.e., Green) because:

(1) it did not involve as-low-as reasonably-achievable planning or work controls,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the licensee determined that the RP Technician's failure to verify that the Unit 2 RBEDT Room was locked and secured which is required by procedure was the cause of the event.

Enforcement:

Violation: Title 10 CFR 20.1601(a) requires, with exceptions not applicable here, that the licensee ensure that each entrance to a high radiation area has one or more of the following features:

(1) a control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep-dose equivalent of 0.1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates;

(2) a control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or

(3) entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.

Title 10 CFR 20.1601(b) provides that, in place of the controls required by 10 CFR 20.1601(a)for a high radiation area, a licensee may substitute continuous direct or electronic surveillance that is capable of preventing unauthorized entry.

Contrary to the above, as of October 29, 2019, the entrance to the Unit 2 Reactor Building Equipment Drain Tank Room, a high radiation area with a radiation dose rate of approximately 3000 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source, was not controlled by any methods described in 10 CFR 20.1601

(a) or (b).

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

Observation: Semiannual Trend Review 71152 The NRC and Illinois Emergency Management Agency (IEMA) inspector have noticed what appears to be an adverse trend in the area of fire protection program implementation during the last year (calendar year 2019). There were various issue reports (IRs) documented in the corrective action program system addressing fire protection related deficiencies. In addition, there appeared to be an increasing number of these items being identified by external parties (NRC, IEMA and Exelon corporate Nuclear Oversight). For the purposes of a simple comparison, a comparable time frame was searched in the CAP. The search focused on items related to inoperable or degraded fire equipment or program implementation issues (e.g. fire doors, fire risk assessment, transient combustibles, and intervening combustibles).

This cursory search found the following:

From 6/1/18 to 12/31/18 Two NRC/IEMA-identified issues (IRs 4167042 and 4206398)

Four licensee-identified issues (IRs 4156094, 4188719, 4188731 and 4200212)

From 6/1/19 to 12/19/19 Nine NRC/IEMA-identified issues (IRs 4259040, 4260129, 4271776, 4273498, 4274824, 4291271, 4292782, 4295069 and 4295218)

Nine licensee-identified issues (IRs 4268037, 4269072, 4281360, 4290524, 4290768, 4294704, 4295095, 4295198 and 4299099)

Inspectors noted, not only the increasing number of identified items, but also the increase in number and percentage of items identified by NRC and IEMA. In addition, the inspectors noted the majority of the items identified by NRC and IEMA were in areas typically traversed by plant personnel.

An additional search of the CAP over the last year (keywords "fire"; "TRM 3.7.n"; "hotwork";

"transient combustibles") noted the following number of IRs documenting issues related to:

16 - Fire Door Deficiencies 28 - Fire protection pipping/component leaks, degradation or issues 2 - Transient combustibles 14 - Fire Protection Procedures or fire report deficiencies 14 - Fire Alarm Issues (not counting valid actuation)8 - Fire Extinguisher / Fire Hoses deficiencies 5 - Fire Wraps or Barriers deficiencies (other than doors)4 - Hot Work issues

It was important to note these searches were not meant to be exhaustive, but done for the purpose of highlighting what appeared to be an emerging adverse trend. The reasons for this trend have not been determined, however, over the last year the NRC and licensee have identified adverse trends regarding procedure use/adherence and human performance in other areas. It is worth mentioning that the licensee's corporate office noticed a trend in the last few weeks of 2019 regarding support workers performance and fire protection across multiple sites, including Dresden Station. This was documented in corporate IR 04304700.

Based on a review of the available information, and in accordance with our inspection and documentation procedures, the inspectors did not identify any findings or violations of more than minor significance, except for one example. The issue of concern described under IR 4295218, "NRC Id'd - Visible Sparks During 2A RR Pump Bowl Piping," was evaluated by the resident inspectors and determined to result in a Green finding with an associated non-cited violation. The details of this finding are documented in this report under Section 71111.05Q, "Failure to Identify and Control How Work."

EXIT MEETINGS AND DEBRIEFS

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

• On January 10, 2020, the inspectors presented the integrated inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

• On November 6, 2019, the inspectors presented the D2R26 ISI exit meeting inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

• On November 22, 2019, the inspectors presented the Radiation Protection Inspection Results inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

290477

Heating Boiler Schedule Gaps

10/23/2019

298569

Ops Crew 1 Clock Reset - Heating Steam Leaks

11/18/2019

299671

DOA 5700-01 Entry

11/25/2019

299678

2/3A Heating Boiler Local Low Level Alarm Will Not Clear

11/25/2019

Corrective Action

Documents

Resulting from

Inspection

4301697

NRC Requests 12/04/19 Shift 2

2/04/2019

4303211

NRC Request 2/3 Cribhouse Windows DOA 5700-01

2/04/2019

Procedures

DOA 5700-01

Loss of Heating Boilers

DOS 0010-19

Preparation for Cold Weather Operations for Unit 1 & Out

Buildings

DOS 0010-19

Checklist 1 Preparation for Cold Weather

DOS 0010-22

Preparation for Cold Weather Operations for Unit 2

DOS 0010-25

Preparation for Cold Weather Operations for Unit 3

DOS 0010-31

Preparation for Cold Weather Operations at the Lift Station,

Goose Lake Pump Station, Security Diesel Building, and

Cooling Towers

Work Orders

04883155-01

Preparation for Cold Weather for Unit 2

10/25/2019

04883211-01

Prepare for Cold Weather Unit 1

10/25/2019

04883215-01

Preparation for Cold Weather Chges For R/W

10/25/2019

048833219-01

Preparation for Cold Weather for Unit 3

10/25/2019

04891989-01

Prepare Out Bldgs for Cold Weather for Lift Attion

10/24/2019

71111.04Q Corrective Action

Documents

297625

3D3 Heater Steam Leak

11/15/2019

Drawings

205LN001-001

Shutdown Cooling System

233LN001-001

Fuel Pool Cooling (FPC) System

M-31

Diagram of Fuel Pool Cooling Piping

BT

Procedures

DOP 1000-M1

Unit 2 Shutdown Cooling System Checklist

DOP 10000-03

Shutdown Cooling Mode of Operation

DOP 1900-E1

Fuel Pool Cooling Electrical

DOP 1900-M1

Unit 2 Fuel Pool Cooling System Checklist

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DOP 6400-10

Removing/Restoring Transformer 22(32) For Outage

Maintenance

DOP 6400-14

TR 86 Load Tap Changer Operation

DOP 6400-15

TR 32 Load Tap Changer Operation

DOP 6500-08

Bus 24-1 to Bus 34-1 Tie Breaker Operation

DOP 6500-30

Bus 23-1 to Bus 33-1 Tie Breaker Operation

DOS 1000-02

Alternate Decay Heat Removal Using Shutdown Cooling and

Fuel Pool Cooling

71111.05Q Corrective Action

Documents

4035503

2/3 Diesel Fir Pump Local Tachometer Failed PMT

07/26/2017

4159567

2/3 DFP Tachometer Not Accurate

07/27/2018

Corrective Action

Documents

Resulting from

Inspection

4301893

2/3 - 3903 DGCWP / NRC Request for Info

2/05/2019

4304481

NRC ID: Fire Protection Report Requires Clarification

2/16/2019

Drawings

2E-2096C

Electrical Installation Cribhouse Partial Plans and Sections,

Elevation 490'8"

G

F-220, Sht 4

Fire Wrap - Cribhouse - Partial Plan & Sections, Elev. 490'8"

E

Fire Plans

FZ 1.2.2

Unit 2 Drywell Primary Containment, Elev. 517'

FZ 8.2.5A

Unit 2 H. P. Heaters/Steam Lines Elevation 517'

FZ 8.2.5B

Unit 2 Low Pressure Heater Bays, Elevation 517'

Procedures

DAN 923-1 G-4

U2/3 Diesel Fire PP Running

DFPS 4123-05

2/3 Diesel Fire Pump Operability

DFPS 4123-15

Returning 2/3 Diesel Fire Pump to Standby Following Start

71111.06

Corrective Action

Documents

20311

Unit 2 & 3 EDGCW Pump Submersibility Qualification

08/22/2002

Corrective Action

Documents

Resulting from

Inspection

4301697

NRC Requests 12/04/19 Shift 2

2/04/2019

4301893

2/3 - 3903 DGCWP / NRC Request for Info

2/05/2019

4302085

NRC Questions Consistency of Harsh Environment

Definition

2/06/2019

Engineering

Changes

338567

Install Water Tight Seals Around Power Cables for the

2-3903 DGCW Pump

338568

Install Water Tight Seals Around Power Cables for the

2-3903 DGCW Pump

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

338569

Install Water Tight Seals Around Power Cables For the

3-3903 DGCW Pump

23268

Revise Flood Elevation Action Level in UFSAR, TRM and

DOA 0010-04

000

Miscellaneous

Binder #: D1528

Crane-Chempump Diesel Generator Cooling Water Pump

004

Crane

Chempump

Series G

Instruction Manual

n/a

Procedures

CC-AA-203

Environmental Qualification Program

DES 6600-08

Diesel Generator Electrical Maintenance Surveillance

Inspection

71111.08G Corrective Action

Documents

2017-6960

Dresden U2 Weld Overlay Drawing

11/12/2017

4070767

Indications Found in Reactor Head Flange Weld

11/03/2017

4071740

D2R25 -UT Indication -N20A Nozzle Weld 6

11/07/2017

4074270

Nozzle N20A Repair Plan Requires Revision

11/13/2017

4075547

NRC Relief Request for U2 Weld Overlay

11/16/2017

NDE Reports

D2R25-APR-05

UT Examination Summary Sheet

11/12/2017

D2R25-UT-030

UT Calibration/Examination

11/06/2017

D2R25-UT-034

UT Calibration/Examination

11/06/2017

D2R26-UT-005

UT Calibration/Examination

10/30/2019

D2R26-UT-006

UT Calibration/Examination

10/30/2019

D2R26-UT-008

UT Calibration/Examination

11/01/2019

D2R26-UT-009

UT Calibration/Examination

11/01/2019

D2R26-UT-010

UT Calibration/Examination

11/01/2019

Procedures

ER-AA-335-003

Magnetic Particle Examination

GEH-PDI-UT-2

PDI Generic Procedure for the Ultrasonic Examination of

Austenitic Pipe Welds

GEH-PDI-UT-3

PDI Generic Procedure for Ultrasonic Through Wall Sizing in

Piping Welds

GEH-UT-717

Procedure for the Examination of Reactor Pressure Vessel

Welds from the Inside Surface with MICROTOMO in

Accordance with Appendix VIII

GEH-UT-737

Procedure for the Examination of Reactor Pressure Vessel

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Welds from the Inside Surface with the Z-Scan UT System in

Accordance with Appendix VIII

Work Orders

4709411

Perform Weld Overlay on Unit 2 N20A Nozzle Weld Joint

N20A-6

11/17/2017

71111.11Q Corrective Action

Documents

292191

4.0 Critique - U2 Shutdown for D2R26

10/28/2019

292642

RTD Thermal Couple and Shackle Became Dislodged in

RPV

10/30/2019

293035

Fuel Moves Stopped / RFB Comes in Contact with Camera

Cable

10/30/2019

Procedures

DGP 01-01

Unit Startup

197

DGP 01-S1

Start-up Checklist

2

DGP 01-S5

Mode 3 to Mode 2 Restart Checklist

DGP 02-01

Unit Shutdown

171

DGP 03-04 Control Rod Movements

DOP 0500-06

Planned Movement of the Reactor Mode Switch

DOP 10000-03

Shutdown Cooling Mode of Operation

DOP 1900-03

Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool

Level Control

71111.12

Corrective Action

Documents

269595

Unexpected Alarm - U2 Fuel Pool CH B Rad Hi

08/05/2019

269595

Unexpected Alarm - U2 Fuel Pool CH B RAD Hi

08/05/2019

269595-10

Review GE Reuter Stokes Failure Analysis Results

09/30/2019

269595-11

Revise WGE Based on the GE Reuter Stokes Failure

10/23/2019

273817

SPC4246346-19: 3-1705-16B Failure Analysis Results

08/22/2019

276469

Unexpected Alarm - U3 Fuel Pool CH A Rad Hi

09/03/2019

4300107

Unexpected Alarm: 902-3 B-1 Refuel Floor RAD-Hi

11/26/2019

4300120

Unexpected Alarm, Area Rad Monitor Downscale

11/26/2019

Procedures

ER-AA-310-1002

Maintenance Rule Function Safety Significance

Determination

Work Orders

04768029-03

Perform Vibration Analysis on 2-0302-3B CRD Pump

11/15/2019

71111.13

Corrective Action

Documents

Resulting from

Inspection

295069

NRC ID'D Procedure Revision Required For Fire Risk

Procedure

11/06/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Miscellaneous

Protected Equipment Lists for Unit 2 and Unit 3 Risk

Significant Systems

Procedures

DOP 6500-08

Bus 24-1 to Bus 34-1 Tie Breaker Operation

DOP 6500-14

Returning 4KV Bus 24-1 to Operation After

Maintenance/Testing

DOP 6500-15

Removing 4KV Buss 33-1 From operation for

Maintenance/Testing

DOP 6500-16

Returning 4KV Buss 33-1 to Operation After Maintenance

DOP 6500-30

Bus 23-1 to Bus 33-1 Tie Breaker Operation

DOS 6600-06

Bus Undervoltage and ECCS [emergency core cooling

system] Integrated Functional Test For Unit 2/3 Diesel

Generator to Unit 2

OP-AA-108-117

Protected Equipment Program

OP-DR-201-012-

1001

Dresden On-Line Fire Risk Management

71111.15

Corrective Action

Documents

270543

Dresden OPEX Review for QDC IR 4266776

08/08/2019

270543

Dresden OPEX Review for QDC IR 4266776

08/08/2019

280928

DPIS will not Trip

09/20/2019

280928

DPIC will not Trip

09/20/2019

282612

Enhance DSSPs to Prevent Potential Spurious HPCI

Actuation

09/26/2019

282612

Enhance DSSPs to Prevent Potential Spurious HPCI

Actuation

09/26/2019

290427

Historical Operability Review for DPIS 3-0261-35C

10/23/2019

291863

MSIV 2-203-1A Needs Timing Adjustment

10/28/2019

291864

MSIV 2-203-1C Needs Timing Adjustment

10/28/2019

291865

MSIV 2-203-1D Needs Timing Adjustment

10/28/2019

291868

MSIV 2-203-2B Needs Timing Adjustment

10/28/2019

291993

Part 21 EMD Fuel Injector - Seized Plunger and Bushing

10/28/2019

292440

D2R26 LLRT FW 0220-62A Failed, Added Scope

10/29/2019

292595

D2R26 2C MSIV - Water Intrusion Misc EOC

10/29/2019

292986

DR26 2-0261-35B DPIS Not Zeroed Out

10/30/2019

293026

1C MSIV Actuator is Leaking By Internally

10/31/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

293026

1C MSIV Actuator Is Leaking By Internally

10/31/2019

294831

D2R26 Scope Addition 2-1201-2 Actuator Needs to be

Rebuilt

11/05/2019

QDC IR 4266776

HPCI not Disabled for Fire Areas TB-III and TB-1

09/26/2019

Drawings

ISI-105

Inservice Inspection Class 1 Isolation Condenser Piping

H

ISI-111

Inservice Inspection Class 1 High Pressure Coolant Injection

Piping

F

ISI-122

Inservice Inspection Class 1 High Pressure Coolant Injection

Piping

G

M-310

Instrument Installation Details Unit 2

05/25/1968

Miscellaneous

OPXR 4259869-

(QDC)

QDC IR 4266776 - HPCI not Disabled for Fire Areas

09/26/2019

Procedures

DSSP 0100-A1

Hot Shutdown Procedure - Path A1

DSSP 0100-

A2/B2

Hot Shutdown Procedure - Path A2/B2

DSSP 0100-B1

Hot Shutdown Procedure - Path B1

DSSP 0100-CR

Hot Shutdown Procedure - Control Room Evacuation

DSSP 0100-E/F

Hot Shutdown Procedure - Path E/F

Work Orders

00457621

Perform Testing Following DPIS 3-0261-35C Replacement

09/21/2019

71111.18

Engineering

Changes

20175

HPCI Injection MOV 2-2301-8 Closure Control Modification

From Torque Switch Close to Limit Switch Close

001

Work Orders

01693630-01

D2 5RFL Com MOV Elect Insp & Diagnostic Testing

2-2301-8

11/03/2019

04726346-01

24M/RFL TS HPCI Motor Operated Valve Operability Surv

11/13/2019

04797506-18

HPCI PMTS Prior to Startup

11/13/2019

71111.19

Corrective Action

Documents

296162

Cannot Full Stroke The 2-1301-2 Valve From the MCR

11/10/2019

297084

DEOP 200-01 Entry for Low Torus Water Level

11/13/2019

297420

Relief Valve 2-4899-72 Identified to be Lifted

11/14/2019

4303551

4.0 Critique - Unplanned Entry into TS 3.6.2.2 & DEOP

200-1

2/13/2019

Miscellaneous

White Paper to Answer NRC Questions

11/19/2019

193133013202

U2 ISO COND RX OUTLET ISO (MOV Diagnostic Test

Data)

11/09/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

DMP 0202-01

Recirculation Pump Seal Replacement and Pump Leak Test

DOS 0700-03

SRM Detector Position Rod Block Functional Test

DOS 0700-12

Determining Source Range Monitor Signal to Noise Ratio

and Minimum SRM Count Rate

DOS 1300-02

Isolation Condenser Valve Operability Check

DOS 1600-18

Cold Shutdown Valve Testing

Work Orders

286811-01

D2 5RFL Solenoid Valve 2-302-20A

11/01/2019

01310540-01

D2 5RFL PM Repl Solenoid Valve 2-302-20B

11/01/2019

01487915-01

4RFL PM COM MOV Elec Insp & Diagnostic Test 2-1501-

2A

10/31/2019

01704408-01

2B Replace 2B RR Pump Mech Seal with New N-7500 STY

11/12/2019

04590899-01

RFL Com MOV Electrical Insp & Diagnostic Test 2-1501-

21A

11/02/2019

04708044-01

D2 24M/RFL TS Mode Switch in S/D Scram Func Test

11/11/2019

04709186-01

CM to Replace LPCI/CCSW Heat Exchanger Relief Valve

11/06/2019

04709880-01

D2 rFL PM CRD 2B Gear Unit Change Oil/Take Oil Sample

11/07/2019

04741694-03

U2 Hydrostatic Leak Test - 2RC01 Class 1 W/D

11/14/2019

04768029-01

Replace 2B CRD Pump Motor (2-0302-3B)

11/11/2019

04771815

59" MSIV Key Interlock Bypass Test

11/09/2019

04797506-18

HPCI PMTS Required for Mode 2

11/15/2019

04797506-20

LPCI Div 1 PMTs Required for Mode 2

11/11/2019

04797506-28

Reactor Recirc PMTS Required for Mode 2

11/14/2019

04856283-01

D2R26 CRD System

11/14/2019

71111.20

Corrective Action

Documents

289667

Apparent EMD WHR Violations

10/18/2019

292191

4.0-Critique - U2 Shutdown for D2R26

10/28/2019

292538

SRM 22 Has Increasing Count Rate Trend

10/29/2019

292561

FME on U2 RPV Steam Dryer

10/30/2019

292594

SRM Bypassed and INOP

10/30/2019

293016

Historical FME Discovered on Jet Pump 18-Vessel Side

10/31/2019

293614

D2R26 Feed Water Check Valve 2-0220-62A Failed LLRT

11/01/2019

293954

Unit 2 HPCI AOP Failed to Stay Running

11/02/2019

294290

D2R26 AF LLRT 1601-23 & 62 Test Volume Over Warning

Limit

11/04/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

294413

D2R26 Torus and Centipede Coating Inspection Results

11/01/2019

294422

D2R26 Drywell Protective Coating Inspection Results

10/30/2019

295192

Fatigue Assessment

11/06/2019

295435

Snubber 2-0201B-17 Failed Operational Test D2R26

11/07/2019

295529

Whole Body Counts for Potential Internal Contamination

11/07/2019

295928

SRM 22 Identified to be Leaking

11/08/20219

296041

D2R26 Full Core Sipping Results

11/09/2019

297084

DEOP 200-01 Entry for Low Torus Water Level

11/13/2019

Drawings

27100LN001-

001a

Off Gas

Miscellaneous

0710-80-0033

Flowserve Technical Notes, N-Seal Operation at Low

System Pressures

December

2007

Tagout Walkdown

2-02-ERVS-001

Tagout Walkdown

2-54-TRAPSV-001

Tagout Walkdown

2-54-OFFGAS-001

Tagout Walkdown

2-23-HPICISTM-001

Tagout Walkdown

2-32-2ARFPMN-001

Procedures

DFP 0800-01

Master Refueling Procedure

DFP 0800-07

Fuel Movements During Refueling Operations

DGP 02-02

Reactor Vessel Slow Fill

DGP 04-01

Fuel Moves and Refueling

DMP 5800-18

Load Handling of Heavy Loads and Lifting Devices

DOP 1600-22

Drywell Entry (Initial, Following Closeout, or At Power

DOP 1900-03

Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool

Level Control

LS-AA-119

Fatigue Management and Work Hour Limits

MA-AA-716-008

Foreign Material Exclusion Program

MA-AA-716-008-

1008

Reactor Services, Refuel Floor FME Plan

Work Orders

04713223-02

RFL Reactor Vessel and Cavity Level Instrumentation

10/21/2019

71111.22

Corrective Action

Documents

284229

Delayed Alarm During DIS 1500-05

10/01/2019

Drawings

239LN001-001

Main Steam System

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DRE204LN001-

001

Reactor Water Clean-Up System and Instrumentation

M-12

Diagram of Main Steam Piping

ABT

Procedures

DAN 902(3)-5 H-8 Panel 2202-70A(B) Trouble

DGP 02-03

Reactor Scram

115

DIS 0263-08

Unit 2 ATWS RPT/ARI Logic System Functional Test

DIS 1500-05

Division I & II Low Pressure Coolant Injection ECCS

Initiation Circuitry Logic Functional Test

DOS 7000-01

Local Leak Rate Testing of Main Steam Isolation Valves

(Dry Tests)

DOS 7000-02

Local Leak Rate Testing of Main Steam Isolation Valves

(Wet Tests)

DOS 7000-08

Local Leak Rate Testing of Primary Containment Isolation

Valves

DOS 7000-18

Local Leak Rate Testing of Unit 2(3) Reactor Water Cleanup

(RWCU) System Valves

Work Orders

01906071-01

D2 48M/2RFL TS Bus 23-1 UV and ECCS Integrated Func

Tests

11/06/2019

04701722

D2 24M TS Division I & II LPCI Injection ECCS Initiation

Circuitry LSFT

10/02/2019

04710348

Clean Up MO Valve Operability and IST Timing

11/13/2019

04711479

D2 TS LLRT MSIV 203-1C & 203-2C Dry Test

10/28/2019

04711480

D2 TS LLRT MSIV 203-1D & 203-2D Dry Test

10/28/2019

04711481

D2 TS LLRT MSIV 203-1A & 203-2A Dry Test

10/28/2019

04716605-01

As Found LLRT per RWCU MOVs per DOS 7000-18

10/30/2019

04718556

D2 24M/RFL TS ATWS RPT/ARI Logic System Functional

Test

11/06/2019

04797506-29

RWCU PMTS Required for Mode 2

11/09/2019

71124.01

Corrective Action

Documents

2019-056888

B SJAE Room

10/28/2019

294554

AR 04294554

11/03/2019

295116

Dose Alarm Received Providing Oversite in the 2B SJAE

11/06/2019

299113

Radiation Protection Improvement Plan

11/21/2019

Corrective Action

298840

NRC ID: NISP-RP-003 Paperwork not Found or

11/20/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Resulting from

Inspection

Documented

299123

NRC ID-Inconsistency in Use of RP-AA-460-002

11/21/2019

299139

NRC ID - Documentation Discrepancy During Review

11/21/2019

Procedures

NISP-RP-005

Access Controls for High Radiation Areas

Radiation

Surveys

2019-053762

2/3 Radiation 507' Barrel Area Basement

09/27/2019

2019-056188

2/3 Radwaste 507' Barrel Area Basement

10/22/2019

2019-056853

Reactor Building Equipment Drain Tank Room

10/28/2019

2019-056862

U2 Drywell 515' General Area

10/28/2019

2019-057152

2/3 Radwaste 507' Barrel Area Basement

10/30/2019

2019-057198

Reactor Equipment Drain Tank Room

10/30/2019

Radiation Work

Permits (RWPs)

DR-0-19-00233

2019 Radwaste Concentrator Maintenance

DR-2-19-00333

2019 Unit 2 Floor Drain System Activities REBT

71124.02

Radiation Work

Permits (RWPs)

DR-2-19-00333

2019 Unit 2 Floor Drain System Activities

DR-2-19-00548

D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve

Repairs

71124.08

Engineering

Evaluations14-210 and 14-

215H Cask

Conformance of Energy Solutions 14-215H Cask with

Specifications for DOT 7A, Type A Packaging

Miscellaneous14-210 and 14-

215H

Safety Analysis Report for 14-210 and 14-215 Packaging

2019 Unit-2/3

Condensate

Resin

2019 Unit-2/3 Condensate Resin Sample Validation

11/05/2019

DAW D2R26-

2019

2019 DAW-10CFR61 Database Analysis -2019 DAW

Average Ave in Radman WMG Program

11/08/2019

FO-OP-023-

161024

Dewatering Completion Record on Liner PL8-120FR Liner

Serial Number 689557-19

10/18/2019

Procedures

CS-OP-PR-104

Energy Solutions; Operation of the Energy Solutions

Demand Advance Liquid Processing System (ALPS)

FO-OP-023-

161024

Energy Solutions: Waste Transfer and Bead Resin/Activated

Carbon Dewatering Procedure for Energy Solutions14-215

or Smaller Liners at Dresden Station

RP-AA-602

Packaging of Radioactive Material Shipments

Shipping Records DM-19-021

UN2915, Radioactive Material, Type-A Package, 7;

Shepherd Seal Source (A1 Special Form) in a Type-A Drum

08/20/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

to J.L. Shepherd Facility

DM-19-142

UN3321, Radioactive Material, Low Specific Activity

(LSA-II), 7; to Rolls Royce Nuclear Services

11/15/2019

DW-18-012

UN3321, Radioactive material, LSA-II, 7; U-1 Dry Active

Waste (DAW) to Energy Solution's Bear Creek Facility, TN

07/25/2018

DW-19-009

UN3321, Radioactive Material, LSA-II, 7; Unit-2/3 DAW to

Energy Solution's Bear Creek Facility, TN

03/27/2019

DW-19-019

UN3321, Radioactive Material, LSA-II, 7; Sludge from B-Max

Waste to Energy Solution's Bear Creek Facility, TN

09/06/2019

DW-19-030

UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to

Energy Solution's Bear Creek Facility, TN

10/24/2019

71151

Corrective Action

Documents

4304564

Incorrect Calculation of Unidentified and Total Leakage Rate

2/17/2019

Corrective Action

Documents

Resulting from

Inspection

4303649

NRC Asked Question Regarding Leakrate Reporting

2/13/2019

Miscellaneous

LS-AA-2090

Monthly Data Elements for NRC Reactor Coolant System

(RCS) Specific Activity (10/01/2018 - 09/30/2019)

Procedures

DOP 2000-24,

Appendix A

Unit Daily Surveillance Log, Attachment A

2

71152

Corrective Action

Documents

4156094

RB 545 Centerline Fire Door Inop

07/16/2018

206398

U3 EDG Room Door Will Not Close and Latch on Its Own

2/28/2018

236627

ESOMS Hot Work Permit Does Not Match Att. 2 of OP-AA-

201-004

04/05/2019

258569

Declining Trend in Procedure Use & Adherence

06/21/2019

259040

Fire Door 67 Inop - Not Consistently Latching

06/24/2019

271776

Contingency Fire Hoses Staged for CO Were Out of Date

08/09/2019

273498

Trans. Combustibles Below U3 W LPCI Stairs - IEMA

Identified

08/20/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

274824

IEMA ID: Issues During Walkdown in Turbine Building

08/27/2019

284652

Consider Cleaning Dirty Smoke Detectors

10/03/2019

284987

NOS ID ESOMS Hot Work Permit Does Not match

10/04/2019

284991

Independent Critique Report Not Retained

10/03/2019

292782

IEMA Questions 4kv X-tie

10/30/2019

4304700

Corp Ops ID's Adverse Trend Supp Worker Perf Fire

Protection

2/17/2019

Corrective Action

Documents

Resulting from

Inspection

295069

NRC ID'd Procedure Revision Required for Fire Risk

Procedure

11/05/2019

295218

NRC ID'd - Visible Sparks During 2A RR Pump Bowl Piping

11/06/2019

4309162

IR Miscoded as NCAP for Potential Regulatory Impact

01/09/2020

71153

Corrective Action

Documents

298330

High Pressure Feedwater Heater Extent of Condition

11/19/2019

298508

IEMA Questions on 2D3 & 3D3 FWH Leak Repairs

11/18/2019

298831

NRC Request for Information

11/20/2019

298915

2D3 FWH Extraction MOV Leakby

11/21/2019

4301802

NDE-UT Results for HP FW Htr. Extent of Condition

2/05/2019

4301894

4.0 Critique for 2D3 FW Heater Restoration

11/30/2019

4302516

Leakage From Pipe Cap Downstream of 2-0220-63B/64B

2/09/2019

4304585

4.0 Critique U2 Downpower Performed 12/09/19 - 12/10/19

2/09/2019

Corrective Action

Documents

Resulting from

Inspection

4302546

NRC - Question Regarding Visitor Control

2/09/2019

Drawings

260000-001

Feedwater Heating Flow Paths

Procedures

SY-AA-101-117

Processing and Escorting of Personnel and Vehicles

31