IR 05000237/2020003

Integrated Inspection Report 05000237/2020003 and 05000249/2020003

ML20317A163
Person / Time
Site:	Dresden
Issue date:	11/10/2020
From:	Kenneth Riemer Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2020003
Download: ML20317A163 (19)

Text

November 10, 2020

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2020003 AND 05000249/2020003

Dear Mr. Hanson:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On October 14, 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.

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

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at 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/

Kenneth R. Riemer, 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: 05000237/2020003 and 05000249/2020003 Enterprise Identifier: I-2020-003-0026 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: G. Edwards, Health Physicist R. Elliott, Resident Inspector J. Havertape, Acting Sr. Resident Inspector A. Nguyen, Senior Resident Inspector C. Phillips, Project Engineer M. Porfirio, Illinois Emergency Management Agency J. Weigandt, Acting Resident Inspector Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

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 Enter a Condition Adverse to Quality into the Corrective Action Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71152 Systems NCV 05000237,05000249/2020003-01 Open/Closed The inspectors identified a green finding of very low safety significance and an associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," for the licensee's failure to enter a condition adverse to quality into the corrective action program. Specifically, the inspectors identified that during a monthly surveillance test of the common emergency diesel generator (EDG) on May 26, 2020, operators recorded high out of specification diesel cooling jacket water temperatures, a condition adverse to quality, and did not make an entry into the corrective action program.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. The unit operated at or near full rated thermal power for the entire inspection period.

Unit 3 began the inspection period at rated thermal power. On August 1, 2020, the unit was down powered to 80 percent power for a control rod sequence exchange. The unit returned to full rated thermal power on August 2, 2020. On August 11, 2020, the unit was shut down for maintenance outage, D3M20, to perform repairs to the 3B Reactor Recirculation pump 2 seal.

The unit returned to near full power on August 16, 2020. On August 18, 2020, the unit was down powered to 75 percent power for a control rod pattern adjustment. The unit was returned to full rated thermal power that same day. On September 6, 2020, Unit 3 entered coast down in preparation for refueling outage D3R26. The unit ended the inspection period at approximately 88 percent of rated thermal power.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 3 'B' train of the shutdown cooling system on August 13, 2020

(2) Unit 2 station blackout diesel on August 26, 2020

(3) Unit 3 station blackout diesel on August 26, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 core spray system on July 29, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)

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

(1) FZ 8.2.6.A, Unit 2 switchgear area elevation 534 on July 10, 2020

(2) FZ 1.1.2.2, Unit 2 reactor ground floor elevation 517' on July 16, 2020

(3) FZ 8.2.5.A, Unit 2 switchgear area elevation 517' on September 2, 2020

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 Unit 3 control room during the maintenance outage D3M20 shutdown on August 12, 2020, and startup on August 15, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated the performance and licensee evaluation of OBE 20-07A, Revision 0 on August 4, 2020

(2) The inspectors observed and evaluated the performance and licensee evaluation of OBE OPEX-AM, Revision 5 on August 24, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Unit 2 and Unit 3 high pressure core injection

(2) Failure of the Unit 3 'D' emergency relief valve to open during testing on August 12, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 3, C-5 rod drive accumulator charging on July 10, 2020

(2) Elevated risk associated with 2/3 fire pump maintenance outage on July 21, 2020

(3) Unit 3 elevated risk due to X-area flow reversal on July 22, 2020

(4) Protected paths for 2/3 diesel generator unavailability on August 25, 2020

(5) Risk mitigating actions associated with TR-2 transmission line repairs on August 26, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

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

(1) Action Request (AR) 04358674, NRC questions - Unit 2 and Unit 3 HPCI [high pressure coolant injection] rooms

(2) AR 4354939, Unit 2 anticipated transient without scram time delay relays K101A and K101B found out of tolerance during surveillance test

(3) AR 4362710, 3D ERV [emergency relief valve] stroking issues

(4) AR 4362001, 3B SDC HX outlet MOV 3-1001-4B difficult to operate

(5) AR 4364280, Unit 3 emergency diesel generator not loaded due to voltmeter issues

(6) AR 4365128, Elevated temperatures on the 2/3 EDG cooling water system

(7) AR 4370960, Unit 3 standby liquid control clean demin water flow rate meter leak

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

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

(1) DOP 4700-08, 3C instrument air system operation after relief valve replacement and receiver inspection, work order (WO) 4692725

(2) DOP 0250-07, 3D ERV functional test after pilot replacement, WO 04885337

(3) DMP 0202-01, Recirculation pump seal replacement and pump leak test, WO 05003002

(4) DOS 6600-01, Diesel generator surveillance tests after trouble-shooting abnormal voltage indications on Unit 3 emergency diesel generator, WO 5063597

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated D3M20 forced outage for 3B reactor recirculation pump seal replacement activities from August 12, 2020 to August 16, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) DIS 1500-01, Division 2 quarterly TS reactor low pressure (350 PSIG) emergency core cooling system permissive calculation, WO 5026118

(2) DIS 1300-02, Unit 2 isolation condenser steam/condensate line high flow calibration, WO 5043705

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) Off-Year Exercise on September 23,

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (5 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Area Radiation Monitors (ARMs) on the refuel floor

(2) ARMs in the auxiliary building

(3) Portable ion chambers stored ready for use and/or during use in the refuel floor area

(4) Portable friskers used at the exit to the RCA on the refuel floor area

(5) ARMs located on the turbine floor Calibration and Testing Program (IP Section 03.02) (10 Samples 1 Partial)

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

(1) (Partial)

U2 and U3 Drywell High-Range Gamma Radiation Monitoring Systems (interim steps taken by the licensee to validate the periodic calibration/testing)

(2) Eberline RO20, SN# 78124

(3) Eberline RO20, SN #79222

(4) Eberline RO20, SN #76449

(5) Ludlum 177, SN# 16979

(6) Ludlum 177, SN# 16956

(7) Ludlum 177, SN# 19247

(8) Ludlum 3, SN# 14341

(9) Mirion AMP 100, SN# 20810

(10) Thermo AMS-4, SN #17476

(11) Canberra Argos, SN# 1011-285 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

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

(1) Unit 3 Service Water Radiation Monitor

(2) Unit 2/3 Vent System Particulate, Iodine and Noble Gas (SPING) and Unit 2/3 Chimney SPING monitors

71152 - Problem Identification and Resolution

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

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

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in issue identification during operator rounds that might be indicative of a more significant safety issue

INSPECTION RESULTS

Failure to Enter a Condition Adverse to Quality into the Corrective Action Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71152 Systems NCV 05000237,05000249/2020003-01 Open/Closed The inspectors identified a green finding of very low safety significance and an associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," for the licensee's failure to enter a condition adverse to quality into the corrective action program. Specifically, the inspectors identified that during a monthly surveillance test of the common emergency diesel generator (EDG) on May 26, 2020, operators recorded high out of specification diesel cooling jacket water temperatures, a condition adverse to quality, and did not make an entry into the corrective action program.

Description:

On May 26, 2020, the common EDG was started for routine monthly surveillance testing. As part of this testing, operator rounds were taken during the end of the one hour loaded portion of the run. The operators documented in WO 5036077 that TA 2/3-6641-12 and TA 2/3-6641-13, diesel generator jacket water temperature inlet and outlet, were 170 and 182 degrees [F] respectively. DOS 6600-01, Diesel Generator Surveillance Tests, Revision 144, required that TA 2/3-6641-12 and TA 2/3-6641-13 nominal range be 150 to 165 and 160 to 180 degrees [F] respectively.

On July 27, 2020, the common EDG was again run for the routine monthly surveillance testing. The operators documented in WO 5055405 that TA 2/3-6641-12 and TA 2/3-6641-13 were 171 and 183 degrees [F] respectively. Operators recorded this condition in the corrective action program as AR 4359125, 2/3 EDG cooling water inlet/outlet temperature high. On July 28, 2020, the station oversight committee reviewed the issue and implemented a procedure change request to increase the TA 2/3-6641-12 and TA 2/3-6641-13 nominal range to 150 to 180 and 160 to 190 degrees [F] respectively. The DG alarm and trip setpoints are 190 and 200 degrees [F] respectively. The diesel generator vendor estimated the maximum safe jacket water temperature to be 225 degrees [F].

On August 24, 2020, the common DG was started for a 24-month endurance run. At 2:52 pm, the EDG was loaded to 2700 kW for a 2-hour 110 percent capacity test. At 3:04 pm, the main control room received an EDG trouble alarm and equipment operators noted jacket water outlet temperature to be 200 degrees [F]. At 3:25 pm, the EDG tripped on high cooling water temperature. The licensee documented this sequence of events in AR 4365128.

Troubleshooting determined heat exchanger fouling to be the cause of elevated jacket water temperatures and the eventual trip of the EDG. The fouling was cleared from the cooling water heat exchangers and the EDG was tested successfully on August 27, 2020. The licensee completed a causal evaluation and determined the cause of the fouling to be silt and clay.

Following the trip of the common EDG, the inspectors conducted a review of the issue.

During their review, the inspectors noted that on May 26th operators had circled the out of range temperature values for the jacket water cooler and made an annotation in the WO that the system engineer had been informed via email to evaluate the data. Additionally, the inspectors noted that no corresponding entry had been made into the corrective action program as required by PI-AA-125, Corrective Action Program, step 4.1.2. Step 4.1.2 states, If at any time a SCAQ, CAQ, or any question of either current or past operability arises, then initiate an IR in accordance with PI-AA-120. The inspectors questioned the licensee on why the issue wasn't documented into the CAP since it was out of specification data related to diesel generator operation that could potentially impact its ability to perform its safety function. The inspectors also identified that the issue in May would have provided valuable trend data for the licensee to evaluate the performance of the EDG and possible system degradation that was occurring. The inspectors determined that not entering the issue into the corrective action program was contrary to the licensee's CAP procedure and regulatory requirements and was a performance deficiency. The licensee captured the inspectors' concern in AR 4370364.

Corrective Actions: The licensee increased the common DG heat exchanger inspection/cleaning frequency from two years to annual, added instructions to all EDG surveillance procedures to clean the heat exchangers if a jacket water temperature of 180 [F]

is exceeded, and implemented a performance improvement action plan to improve issue identification and screening during operator rounds.

Corrective Action References: AR 4365128 and 4370364

Performance Assessment:

Performance Deficiency: Title 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, requires, in part, that the applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the activities, a Quality Assurance Program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. The Quality Assurance Program was described in NO-AA-10, "Quality Assurance Topical Report," Revision 95, and discussed that the CAP was used to identify and correct conditions adverse to quality in Sections 16.2.1 and 16.2.2. The inspectors determined that the failure to perform activities in accordance with procedure PI-AA-125, Corrective Action Program, Revision 7, which was a Quality Assurance Program implementing procedure, was a performance deficiency. Specifically, the inspectors identified that during WO 5036077 on May 26, 2020, operators recorded high out of specification diesel cooling jacket water temperatures, a condition adverse to quality, and did not make an entry into the corrective action program.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed the performance deficiency in accordance with the screening criteria contained in Inspection Manual Chapter 0609, Appendix A, for inspection findings at power. The inspectors determined that a detailed risk evaluation was required because they answered 'Yes' to the relevant portion of Question 3, "Does the finding represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time?" The technical specification allowed outage time for one diesel generator is 14 days. The inspectors determined that the common EDG had run for approximately 30 minutes under 110 percent load at the time of the trip. Further, the inspectors noted that in AR 4365128 operators stated that jacket water temperature had reached 225 [F] following the trip of the common EDG on August 24, 2020, and that the EDG vendor had stated 225 [F] to be the maximum safe operating temperature. Therefore, the inspectors concluded that the common EDG would have likely failed to run for its 24-hour mission time and that this condition likely existed since the EDG had last been run successfully on July 27, 2020.

A detailed risk evaluation was performed to assess the significance of the finding. The finding was assumed to result in a degraded condition in which the common EDG would fail to run. The condition was assumed to exist for an exposure period of one month. A region III senior reactor analyst (SRA) used a recently modified Standardized Plant Analysis Risk (SPAR) model, revision 8.59, to analyze the finding. The model modification was necessary to properly incorporate FLEX strategies. FLEX equipment failure rates were estimated by using failure rates for similar permanently installed equipment multiplied by a factor of 3. The change in core damage frequency for the exposure period was estimated to be less than 1E-7/year. As a result, risk contributions for external events and large early release frequency were not evaluated. The dominant core damage sequence involved a weather-related loss of offsite power, failure of the emergency diesel generators, failure of the high-pressure coolant injection system, and the failure to recover offsite or onsite power within the battery depletion time.

Cross-Cutting Aspect: P.4 - Trending: The organization periodically analyzes information from the corrective action program and other assessments in the aggregate to identify programmatic and common cause issues. Specifically, the diesel generator jacket water temperature on the common EDG was relatively stable for a year prior to the elevated temperatures that were experienced during the May 2020 surveillance test. At this point, jacket water temperatures increased in a stepwise fashion initially and increased steadily during each monthly surveillance run until the eventual trip of the common EDG on August 24, 2020. The significance of the jacket water temperature trend change was not recognized by the licensee and no actions were implemented to correct or stop the trend.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, requires, in part, that the applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the activities, a Quality Assurance Program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. The Corrective Action Procedure, PI-AA-125, which implemented part of the Quality Assurance Topical Report, Step 4.1.2 states, If at any time a SCAQ, CAQ, or any question of either current or past operability/reportability arises, then initiate an IR in accordance with PI-AA-120.

Contrary to the above, on May 26, 2020 the licensee failed to carry out activities in accordance with a procedure established to implement the Quality Assurance Program.

Specifically, the licensee failed to generate an IR in accordance with PI-AA-125 for a condition adverse to quality.

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

Observation: Potential Adverse Trend Related to Issue Identification and 71152 Screening during Operator Rounds The inspectors reviewed Exelon's corrective action program (CAP) for trends that might be indicative of a more significant safety issue on September 21, 2020. The inspectors evaluated a sample of issues and events that occurred over the course of the second and third quarters of 2020 to determine whether issues were appropriately considered as emerging or adverse trends. The evaluation revealed a number of NRC and IEMA identified issues relating to equipment parameters found out of their specified operator rounds ranges:

• AR 4338023, IEMA U3 EDG walkdown items

• AR 4355291, NRC question on 3A CRD pump

• AR 4356740, IEMA walkdown items

• AR 4358676, WR needed to lower oil level in U2 HPCI booster pump

• AR 4370364, NRC question related to work order All of the issues reviewed pertained to parameters covered on routine equipment operator rounds and were found by either NRC or IEMA during system walkdowns or document reviews to be outside the expected nominal range. The inspectors noted the number of NRC and IEMA-identified issues relating to operator rounds in the second and third quarters represented an increase in relation to previous quarters and was therefore a potentially adverse trend. The inspectors determined that the issues identified in AR 4338023, 4355291, 4356740, and 4358676, did not impact system operability or functionality and were, therefore, minor. However, upon an in-depth review the inspectors determined that the issue documented in AR 4370364 adversely affected the equipment performance attribute of the mitigating systems cornerstone and was dispositioned separately in this report as a green finding and associated non-cited violation titled "Failure to Enter a Condition Adverse to Quality into the Corrective Action Program."

The inspectors raised the concern of a potentially adverse trend associated with issue identification and screening during operator rounds with the licensee. The licensee was receptive to the inspectors' feedback and responded that there was a plan to improve performance during operator rounds with an emphasis on entering issues into the corrective action program. Specific actions in the licensee's plan included one-on-one discussions between equipment operators and operations management on expectations, paired observations during operator rounds, and removal of unnecessary items from equipment operator rounds packages.

EXIT MEETINGS AND DEBRIEFS

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

• On October 14, 2020, the inspectors presented the integrated inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.

• On September 4, 2020, the inspectors presented the Radiation Protection inspection results to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings M-363 Diagram of Shutdown Reactor Cooling Piping BG

Procedures DOP 1400-E1 Unit 2 Core Spray System Electrical Checklist 4

DOP 1400-M1 Unit 2 Core Spray System 24

DOP 6620-16 SBO D/G 2(3) Preparation for Standby Readiness 17

71111.05 Corrective Action 1417050 Fire Panel 2202-56A in Trouble 09/23/2012

Documents 4095329 Relay K6 De-Energized in Panel 2202-56A 02/18/2018

Corrective Action 4357245 NRC Question Regarding Cables Along FP Piping on RB 07/16/2020

Documents 517'

Resulting from

Inspection

Fire Plans 105 U2RB-5 105 U2RB-5Unit 2 RX Ground Floor Elev. 517' FZ 1.1.2.2 5

146 U2TB-49A Unit 2 CREVS 5

149 U2TB-51 Unit 2 Switchgear Area Elev. 534 6

Miscellaneous TRM 3.7.1 Fire Hose Stations 30

Procedures MA-AA-716-026 Station Housekeeping/Material Condition Program 18

Work Orders 1589710 Fire Panel 2202-56A In Trouble - Bad Tamper Switch 05/15/2018

4772846 Relay K6 De-Energized in Panel 2202-56A 04/14/2018

71111.12 Drawings 12E-3462, sheet Electromatic Relief Valve 203-3D Control AG

Engineering Function 30-3 Maintenance Rule System Basis Document for Main Steam 09/03/2020

Evaluations Function 30-3, Prevent Over Pressure of the Reactor Vessel

During Transients

Miscellaneous Relays - Control / Preventative Maintenance Template 2

Timing

Procedures DEOP 0400-2 Emergency Depressurization 9

ER-AA-200-1001 Equipment Classification 5

71111.13 Corrective Action 4355950 Fire Pumps Auto-Started from Unexpected Pre-Action 07/10/2020

Documents 4356022 Unexpected Alarm 901-2 C-8 Central File Fire w/Halon 07/10/2020

Discharge

Procedures DFPP 4123-15 Returning 2-3 Diesel Fire Pump to Standby Following Start 3

71111.15 Corrective Action 4359125 2/3 EDG Cooling Water Inlet/Outlet Temperature High 07/27/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 4362001 3B SDC HX Outlet MOV 3-1001-4B Difficult to Operate 08/09/2020

4364280 Unit 3 Emergency Diesel Generator Not Loaded due to 08/20/2020

Voltmeter Issues

4370960 U3 SBLC Clean Demin Water Flow Rate Meter Leak 09/21/2020

4392001 3B SDC HX Outlet MOV 3-1001-4B Difficult to Operate 08/09/2020

Corrective Action 4368224 NRC Question on DOS 6600-01 09/09/2020

Documents

Resulting from

Inspection

Drawings 12E-3334 Relaying and Metering Diagram 4160 V Switchgear 34-1 and W

33-1

2E-3336 Relay, Metering and Excitation Diagram Standby Diesel Y

Generator 3

20306 Vickers Schematic Diagram Voltage Regulator Model 1

35D533-2

M-364 Diagram of Standby Liquid Control Piping AS

Engineering 4362710 3D ERV Stroking Issues - Complex Troubleshooting 0

Evaluations Package

Miscellaneous EPRI 1011111 EMD Mag Amp Voltage Regulators for Emergency Diesel 11/01/2004

Generators

MI 4520 EMD Maintenance Instruction; Voltage Regulator - Magnetic 08/01/1961

Amplifier Type

MI 4523 EMD Maintenance Instruction; Magnetic Amplifier Controlled 03/01/1970

Voltage Regulator

Work Orders 1828114 D2/3 2 Y PM Standby Diesel Generator Inspection 07/18/2017

4664268-15 D2/3 2 Y PM Standby Diesel Generator Inspection 03/25/2019

5036077 D2/3 1M TS Unit Diesel Generator Operability 05/20/2020

5044726 D2/3 1M TS Unit Diesel Generator Operability 06/20/2020

5055405 D2/3 1M TS Unit Diesel Generator Operability 07/25/2020

71111.19 Procedures DOP 4700-08 3C Instrument Air System Operation 37

DOS 6600-01 Diesel Generator Surveillance Tests 144

Work Orders 4692725 D3 3Y COM 3C IA REC IDNS INSP/LFT CK RV (ILL 08/06/2020

1. U0232183)

4885337 D3 RFL PM Electromatic Relief - D - Replace Pilot 10/26/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

4885337 Functional Test D ERV per DOS 0250-07 08/14/2020

5003002 MM Replace 3B RR Seal and OP Post Maintenance Test of 08/07/2020

3B RR Pump Following Seal Replacement

5063597 D3 1M TS (IST) Unit Diesel Generator Operability 08/17/2020

71111.20 Corrective Action 4362352 Unit 3 IRM 18 Does Not Pass Range 6-7 Overlap Check 08/12/2020

Documents 4362710 3D ERV Stroking Issues 08/12/2020

4362717 CRD L-13 Green Double Dashes on Full Core Display 08/12/2020

4363390 Unit 3 RWCU Auxiliary Pump Trip during Reactor Startup - 08/15/2020

D3M20

4363512 IRM 18 Went Downscale When Ranging from 6 to 7 08/16/2020

4363514 Control Rod N9 - RPIS Issue Caused Rod Drift Alarm - 08/16/2020

D3M20

Corrective Action 4362731 NRC Identified Potential Issue Rigging for Recirculation Seal 08/12/2020

Documents 4363331 NRC - 3B Drywell Cooler Access Hatch Latch - D3M20 08/15/2020

Resulting from

Inspection

Engineering D3M20 Shutdown Safety Management Plan 08/10/2020

Evaluations

71111.22 Corrective Action 04357223 Found PS 2-0263-52A Circuit 1 and Circuit 2 Reset O.O.T 07/16/2020

Documents 4351938 Unit 2 DEHC Fluctuations in Throttle Mode 06/23/2020

4355936 Unit 2 DEHC Fluctuations in Throttle Mode 07/10/2020

Corrective Action 4358189 Hose Used for Calibrations During DIS 1500-01 Questioned 07/22/2020

Documents

Resulting from

Inspection

Engineering 447233 Evaluate the Effect of Hose Length on IMD Calibrations for 07/23/2020

Changes ECCS Pressure Switches

Procedures DIS 1300-02 Unit 2 Isolation Condenser Steam/Condensate Line High 32

Flow Calibration

DIS 1500-01 Unit 2 Reactor Low Pressure (350 PSIG) ECCS Permissive 41

Work Orders 05036080-01 Quarterly TS CS Pump Test 07/31/2020

05065409-05 Core Spray Flow Indicator Needs Calibration 07/31/2020

26118 D2 Quarter TS Reactor Low Pressure (350 PSIG) ECCS 07/16/2020

Permissive Calculation

Inspection Type Designation Description or Title Revision or

Procedure Date

5043705 D2 Quarter TS ISO Cond Steam AND Cond Line HI Flow 08/20/2020

CAL

71124.05 Calibration DMC-3000 Calibration Summary Report 06/26/2020

Records Calibration of the Accuscan II WBC System at Exelon 07/13/2020

Dresden Generating Station

Calibration of the Fastscan WBC System at Exelon Dresden 07/15/2020

Generating Station

Drywell High Radiation Monitor RIS 2(3)-2419A Channel 10/29/2019

Calibration

Corrective Action 04280769 2/3 Refueling Floor CAM Long Term Out of Service 07/25/2018

Documents 04297049 Liquid Scintillation Calibration Procedure Lack Guidance 11/12/2019

04301949 903-3 C-9 2/3 Reactor Building Vent Stack Monitor Flow Low 12/06/2019

Miscellaneous General Atomics High-Range Gamma Radiation Monitoring 3

System

Self-Assessments AR 04322022 02 RP SRPT for NRC SA IP 71124.05 - Instrumentation 08/04/2020

Work Orders 0196847401 Unit 3 Drywell High Range Gamma Radiation Monitoring 10/30/2018

System Calibration

71152 Corrective Action 4361303 Follow-Up Discussions with the NRC (re. Oil Level Readings) 08/05/2020

Documents

Resulting from

Inspection

16