IR 05000237/2023011

Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011

ML23242A188
Person / Time
Site:	Dresden
Issue date:	09/06/2023
From:	Jamie Benjamin NRC/RGN-III/DORS/EB1
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023011
Download: ML23242A188 (1)

Text

September 6, 2023

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 COMPREHENSIVE ENGINEERING TEAM INSPECTION REPORT 05000237/2023011 AND 05000249/2023011

Dear David Rhoades:

On August 4, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3 and discussed the results of this inspection with Pat Boyle and other members of your staff. The results of this inspection are documented in the enclosed report.

Three findings of very low safety significance (Green) are documented in this report. Three 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, Signed by Benjamin, Jamie on 09/06/23 Jamie C. Benjamin, Chief Engineering Branch 1 Division of Operating Reactor Safety 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: 05000237/2023011 and 05000249/2023011 Enterprise Identifier: I-2023-011-0033 Licensee: Constellation Energy Generation, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Inspection Dates: July 17, 2023 to August 04, 2023 Inspectors: C. Baron, Contractor J. Corujo-Sandin, Senior Reactor Inspector K. Fay, Reactor Inspector E. Fernandez, Senior Reactor Inspector M. Gangewere, Reactor Inspector J. Gilliam, Senior Reactor Inspector M. Siddiqui, Reactor Inspector Approved By: Jamie C. Benjamin, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Comprehensive Engineering Team 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 Correct Condition Adverse to Quality after HPCI Test Control Violation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21M Systems NCV 05000237,05000249/2023011-01 Conservative Open/Closed Bias The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to establish measures to assure a condition adverse to quality was corrected. Specifically, the licensee did not fully correct a violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, identified in an NRC 2020 Integrated Inspection report. As a result, the portion of the test control violation related to the failure to account for instrument uncertainty in the High Pressure Coolant Injection accident analysis or evaluation of surveillance test results remained uncorrected.

Failure to Identify HPCI Signal Converter Lockout Function Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.21M Systems NCV 05000237,05000249/2023011-02 Operating Open/Closed Experience The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI,

Corrective Action, due to the failure to identify a condition adverse to quality when information became available that the HPCI signal converter was installed with a lockout function that was not evaluated. Specifically, the licensee failed to identify the HPCI signal converter could lockout on different conditions (i.e., high temperature and high amperage).

This would result in the operators needing to take manual control of the system that is designed to operate automatically.

Failure to Translate HPCI Room Design Basis Temperature into Surveillance Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000237,05000249/2023011-03 Open/Closed The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, "Design Control," when the licensee failed to correctly translate high pressure coolant injection (HPCI) room design basis initial temperature into the unit daily surveillance log procedure. Specifically, the licensee failed to ensure normal HPCI room temperature would remain at or below 104 degrees Fahrenheit as assumed in HPCI room thermal response design calculation and Updated Final Safety Analysis Report (UFSAR) Environmental Zone 6 normal service temperature.

Additional Tracking Items

None.

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.

REACTOR SAFETY

===71111.21M - Comprehensive Engineering Team Inspection The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Structures, Systems, and Components (SSCs) (IP Section 03.01) ===

For each component sample, the inspectors reviewed the licensing and design bases including:

(1) the Updated Final Safety Analysis Report (UFSAR);

(2) the Technical Specifications (TS); and

(3) the Technical Requirements Manual (TRM). The inspectors reviewed a sample of operating procedures (including normal, abnormal and emergency procedures), overall system/component health (including condition reports and operability evaluations, if any) and associated maintenance effectiveness (e.g., Maintenance Rule, procedures). The inspectors performed visual inspections of the accessible components to identify potential hazards and/or signs of degradation. Additional component specific design attributes reviewed by the inspectors are listed below.

(1) Unit 3: 250 Volts Direct Current (VDC) Motor Control Center (MCC) #3 (3-83250-3)1. Protection against seismic events 2. Test/inspection procedures, acceptance criteria, and recent results:

a. Load testing b. TS surveillance c. Relay calibration d. Terminal corrosion resistance 3. Electrical design calculations and considerations:

a. Short circuit calculations b. MCC capacity c. Degraded voltage d. Overcurrent protection e. Direct Current (DC) voltage to MCC breakers

(2) Unit 3: 250 VDC MCC 3A and 3B (3-83250-3A and 3-83250-3B)1. Protection against seismic events 2. Test/inspection procedures, acceptance criteria, and recent results:

a. Load testing b. TS surveillance c. Relay calibration d. Terminal corrosion resistance 3. Electrical design calculations and considerations:

a. Short circuit calculations b. MCC capacity c. Degraded voltage d. Overcurrent protection e. DC Voltage to MCC breakers

(3) Unit 2/3: 250 VDC 2/3 Swing Battery Charger (2/3-83250)1. Translation of vendor specifications 2. Protection against seismic events 3. Test/inspection procedures, acceptance criteria, and recent results:

4. Electrical design calculations and considerations:

a. Duty cycle b. Sizing of protective fuses/breakers/relays c. Voltage drop calculation d. Configuration of electrical distribution e. Cable ampacity

(4) Unit 3: Electromatic Relief Valve (ERV) 3D and 3E (3-0203-3D and 3-0203-3E)1. Environmental qualification 2. Protection against High Energy Line Break (HELB)3. Mechanical design calculations and considerations: Relief capacity 4. Electrical design calculations and considerations:

a. Solenoid minimum voltage b. Control power c. Cable ampacity d. Voltage drop e. Degraded voltage effects f. Control logic instrumentation and setpoints

(5) Unit 2/3: Condensate Storage Tank (CST) 2/3 A and B (2/3-3303-A and 2/3-3303-B)1. Protection against external events:

a. Flooding b. Seismic c. HELB 2. Mechanical design calculations and considerations:

a. Available and required volume (Loss of Coolant Accident)b. Available and required volume (Station Blackout)c. Available and required volume (Feed and Bleed)d. Level setpoints e. Instrument uncertainty f. Design pressure g. Overpressure protection (e.g., relief valve or vent sizing)h. Temperature limits i. Post-accident leakage from Emergency Core Cooling Systems (ECCS) - impact to Main Control Room (MCR) dose analysis j. Heat tracing 3. Test/inspection procedures, acceptance criteria, and recent results:

a. Temperature b. Heat tracing c. Volume d. Instrument setpoints e. TS surveillances 4. Electrical design calculations and considerations:

a. Control logic for switchover to recirculation / make-up source 5. Ultrasonic Testing (UT) Examinations of Tank Bottom

(6) Unit 3: High Pressure Coolant Injection (HPCI) Pump, Booster Pump, and Turbine (3-2302, 3-2302-1 and 3-2301)1. Environmental qualification 2. Mechanical design calculations and considerations:

a. Flow capacity & balance b. Minimum flow c. Runout flow d. Required submergence: net positive suction head (NPSH) and vortexing prevention e. Tank level setpoints and instrument uncertainty f. CST vent and/or instrument line freeze protection g. Hydraulic transients (water hammer), including flashing in discharge piping due to reactor coolant system interface h. Gas intrusion & accumulation i. Room heat up calculations j. Room cooling 3. Test/inspection procedures, acceptance criteria, and recent results:

a. Pump comprehensive In Service Testing (IST) surveillances b. Pump quarterly IST surveillances c. TS instrument surveillances 4. Electrical design calculations and considerations:

a. Control instruments b. Set point calculations c. Control voltage 5. ASME Section XI a. Volumetric Examination of Pressure Retaining Bolts and Studs b. Surface examination of pump casing welds c. Surface examination of welded attachments

(7) Unit 3: HPCI Steam Supply Motor Operated Valve (MOV) (3-2301-3)1. Environmental qualification 2. Protection against external events:

a. Flooding, including sump pump b. Seismic c. HELB 3. Mechanical design a. Weak link analysis b. Required thrust (torque)c. Pressure locking and/or thermal binding d. Closure/Opening time e. Maximum allowed leakage f. Maximum differential pressure

4. Test/inspection procedures, acceptance criteria, and recent results:

a. Leakage b. IST c. Thermal overload testing d. TS required surveillance e. Leak Rate Testing (LRT)5. Motor power requirements:

a. Voltage drop b. Control logic c. Control voltage drop d. Load flow e. Thermal overload f. Required minimum voltage g. Degraded voltage effects h. Brake horsepower i. Motor thermal overload protection j. Cable ampacity k. Protective devices l. Emergency power (Emergency Diesel Generator and/or, battery)6. ASME Section XI: Surface exam of valve body welds

(8) Unit 3: HPCI Room Cooler (Heat Exchanger Coil and Fan) (3-5747)1. Environmental Qualification 2. Design calculations and considerations:

a. Minimum cooling water flowrate b. Maximum cooling water temperature c. Minimum working fluid flowrate d. Maximum working fluid temperature e. Tube plugging limit f. Fan motor minimum voltage g. Fan motor cable ampacity h. Control logic i. Control circuit voltage Fan motor protective device j. Heat transfer capacity 3. Test/inspection procedures, acceptance criteria, and recent results:

a. Generic Letter 89-13 visual inspections and cleanings b. Eddy current testing 4. ASME Section XI a. System pressure test b. Visual Testing (VT) examinations of welded attachments

Modifications (IP Section 03.02) (6 Samples)

(1) Engineering Change (EC) 632912, Revision 0 - HPCI Steam Rupture Disk - Allow Use of 140 PSIG Rated Set for 3-2301-68 and 3-2301-69

(2) EC 397957, Revision 7 - Replace HPCI Signal Converter and Flow Indicating Controller

(3) EC 629898, Revision 1 - Install HPCI AOP Jumper in 902-3 Panel 2-2302-AOP

(4) EC 625763, Revision 0 - 3-2301-3 Pressure Locking / Thermal Binding Susceptibility Remediation

(5) EC 638016, Revision 1 - Containment Cooling Service Water (CCSW) Line 3-1510-16" / Code Repair of Through Wall Leak

(6) NED-I-EIC-0111, Revision 6 - High Pressure Coolant Injection Steam Line High Flow Isolation Setpoint Error Analysis 10 CFR 50.59 Evaluations/Screening (IP Section 03.03) (13 Samples)

(1) Evaluation 2023-01-001 - Replace HPCI Signal Converter and Flow Indicating Controller

(2) Screening 2019-099 - Loss of Feedwater Heaters

(3) Screening 2019-028 - Provide Temporary Cooling to U2 HPCI Room Due to High Vibes in 2-5747 HPCI Room Cooler

(4) Screening 2019-036 - Feedwater Regulating Valve (FWRV) Operation

(5) Screening 2019-039 - Replace CCSW Vault Cooler Cooling Coils U2 Div I (Coolers A & B)

(6) Screening 2019-047 - Loss of Heating Boilers

(7) Screening 2020-014 - High Pressure Coolant Injection System Standby Operation

(8) Screening 2020-016 - Diesel Generator Cooling Water Pump Quarterly and Comprehensive/Preservice Test for Operational

(9) Screening 2021-005 - Unit 2(3) Monthly Station Battery Inspection

(10) Screening 2022-007 - CCSW Vault Coolers 2C/2D Replacement

(11) Screening 2022-009 - Calibrate Venturi Feedwater Flow Rate for Unit 2

(12) Screening 2023-007 - HPCI Signal Converter and Flow Indicating Controller

(13) Screening 2020-104 - Procedure Enhancement to Take Actions to Secure HPCI to Prevent Spurious Injection to Ensure Functionality of the Isolation Condenser

===System.

Operating Experience Samples (IP Section 03.04) (2 Samples)===

(1) Generic Letter 2008-01 - Managing Gas Accumulation in ECCS, Decay Heat Removal and Containment Spray Systems

(2) Information Notice 2009-09 - Improper Flow Controller Settings

INSPECTION RESULTS

Failure to Correct Condition Adverse to Quality after HPCI Test Control Violation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21M Systems NCV 05000237,05000249/2023011-01 Conservative Open/Closed Bias The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to establish measures to assure a condition adverse to quality was corrected. Specifically, the licensee did not fully correct a violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, identified in an NRC 2020 Integrated Inspection report. As a result, the portion of the test control violation related to the failure to account for instrument uncertainty in the High Pressure Coolant Injection accident analysis or evaluation of surveillance test results remained uncorrected.

Description:

The NRC first quarter Integrated Inspection Report issued on May 11, 2020, (Inspection Report 05000237/2020001; 05000249/2020001, ML20133J811) identified a 10 CFR 50, Appendix B, Criterion XI, Test Control, violation, in part, for the licensees failure to account for instrument uncertainty when establishing acceptance criteria in the High Pressure Coolant Injection (HPCI) surveillance procedure, DOS 2300-03 High Pressure Coolant Injection System Operability and Quarterly IST Verification Test, Revision 117. Technical Specification (TS) Surveillance Requirement (SR) 3.5.1.6 required the licensee to verify the HPCI pump can develop a flow rate greater than or equal to 5,000 gpm against a system head corresponding to reactor pressure. Procedure DOS 2300-03 step H.5.a and Data Sheet 2 implemented this TS SR and established acceptance criteria for HPCI flow equal to or greater than 5,000 gpm. Flow was measured by Flow Controller FIC 2(3)-2340-1.

Calculation NED-I-EIC-0109, Revision 6, Section 15, Conclusions determined average instrument uncertainty associated with Unit 3 FIC was +/- 254 gpm under normal plant conditions and +/- 848 gpm under accident conditions.

In response to the test control violation, the licensee entered this issue into their Corrective Action Program (CAP) as Action Request (AR) 04331189. AR assignments completed a generic BWR fleet and Dresden specific sensitivity study to approximate built in conservatisms to Dresdens current licensing basis ECCS evaluation model utilizing Appendix K to Part 50 ECCS Evaluation Models methodology. These assignments studied the impact reduced ECCS flow rates had on peak cladding temperature. This AR was closed on December 16, 2022.

The inspectors reviewed UFSAR Table 6.3-20b for HPCI LOCA (loss of coolant accident)analysis minimum flow rate and the current accident analysis, ANP-3749P, Dresden Units 2 and 3 Atrium 10 XM LOCA Break Spectrum Analysis with Increase ADS Flow, Revision 0. The inspectors noted the HPCI assumed flowrates were both 5,000 gpm and remained unchanged since the 2020 test control violation was identified. Since the accident analysis did not account for instrument uncertainty, the inspector verified if TS SR 3.5.1.6 implementing procedure, DOS 2300-03, Revision 119, was revised to evaluate the test results to ensure HPCI accident analysis flowrate of 5,000 gpm could be achieved. The inspectors concluded instrument uncertainty was neither accounted for in the design analysis nor the TS SR implementing procedure and therefore, AR 04331189 corrective actions did not correct the 2020 test control violation.

The inspectors noted under Work Order 05271158 on September 15, 2022, and Work Order 05096718 on November 18, 2022, the recorded HPCI flow rate for the TS SR test were 5,225 and 5,220 gpm respectively. These were below the required flow rate if instrument uncertainty was included in the acceptance criteria. The inspector verified Work Order 05128666 on March 3, 2023, achieved a HPCI flow rate greater than the acceptance criteria plus instrument uncertainty.

Corrective Actions: The licensee entered this issue into their CAP and planned for engineering to evaluate, determine extent of condition with any additional actions to address, and communicate any corrective actions applicable to fleet plants. The licensee reviewed recently performed IST tests which established a flow range acceptance criteria greater than the TS SR instrument uncertainty and verified IST as-found flow values remained above the TS SR plus instrument uncertainty value and therefore, Unit 2 and 3 HPCI remained operable.

Corrective Action References: AR 04695296, 2023 CETI-NRC ID: Issue with uncertainty not in ECCS testing.

Performance Assessment:

Performance Deficiency: The licensee's failure to correct a condition adverse to quality was contrary to 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and was a performance deficiency. Specifically, when corrective actions to the 2020 test control violation were closed on December 16, 2022 (under AR 04331189), the licensee failed to account for instrument uncertainty in the accident analysis or TS SR implementing procedure, to ensure the analyzed HPCI required flowrate of 5,000 gpm could be achieved.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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. Specifically, the current accident analysis, ANP-3749P, Revision 0, design did not account for instrument uncertainty in the assumed HPCI flowrate, and the analysis flowrate of 5,000 gpm was directly translated into the TS SR implementing procedure, DOS 2300-03, Revision 119, without accounting for the instrument uncertainty calculated in design calculation NED-I-EIC-0109, Revision 6. HPCI surveillance test completions under Work Order 05271158 and 05096718 both failed to stay within the bounds of the accident analysis design flowrate of 5,000 gpm if instrument uncertainty was accounted for in the procedure.

Therefore, absent TS SR procedural controls, the design margins to ensure the capability of the HPCI system to mitigate a small break loss of coolant accident, as analyzed in the current accident analysis, remain vulnerable. This is a concern since Dresdens accident analysis has transitioned through different nuclear fuel vendors (GE, Westinghouse, and Areva), and currently no design control measures have ensured the HPCI system would remain within the bounds of the analysis of record.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the inspectors determined that this finding is of very low safety significance (Green) because: the performance deficiency was not a design or qualification issue; it did not represent a loss of the system function; the associated trains were neither inoperable for greater than its allowed outage time nor was it inoperable for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and were not part of an external event mitigating system. Specifically, although the inspectors identified completed surveillance tests outside the bounds of the current accident analysis design if instrument uncertainty was accounted for, review of additional surveillance tests ensured the HPCI pump could meet the accident analysis design flow rate if the design margins were more closely guarded.

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. As a result of the test control violation, corrective actions under AR 04331189 completed a sensitivity study to measure the impact of ECCS reduced flow rate on peak cladding temperature. However, the corrective actions did not establish measures to account for instrument uncertainty in the HPCI accident analysis design nor the TS SR implementing procedure to ensure the assumed design flowrate of 5,000 gpm could be achieved.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as deficiencies, deviations and nonconformances are corrected.

Contrary to the above, as of December 16, 2022, the licensee failed to establish measures to assure conditions adverse to quality were corrected. Specifically, a non-cited violation of Appendix B, Criterion XI, Test Control, was identified in a 2020 NRC Integrated Inspection Report, in part, for the failure to account for instrument uncertainty in the acceptance criteria of HPCI surveillance procedure DOS 2300-03, High Pressure Coolant Injection System Operability and Quarterly IST Verification Test, Revision 117. The licensee documented this violation in their CAP as AR 04331189. This was closed on December 16, 2022, and failed to establish measures that assured the HPCI system would remain within the bounds of the analyzed design such that the HPCI flowrate of 5,000 gpm would be achieved if instrument uncertainty was accounted for in the accident analysis or TS SR implementing procedure.

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

Failure to Identify HPCI Signal Converter Lockout Function Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.21M Systems NCV 05000237,05000249/2023011-02 Operating Open/Closed Experience The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, due to the failure to identify a condition adverse to quality when information became available that the HPCI signal converter was installed with a lockout function that was not evaluated. Specifically, the licensee failed to identify the HPCI signal converter could lockout on different conditions (i.e., high temperature and high amperage).

This would result in the operators needing to take manual control of the system that is designed to operate automatically.

Description:

The inspectors reviewed the modification package, 50.59 evaluation, and screening associated with the licensees replacement of HPCI signal converter which the licensee installed in March of 2023 on Unit 1 and 2. The purpose of the HPCI signal converter is to provide positioning signals to the motor gear unit (MGU). When the HPCI system sends a flow demand change through the flow indicating controller (FIC), the signal converter sends a signal to the MGU which results in the MGU changing positions and the system flow equaling to the FIC flow demand. These actions are designed to happen automatically. HPCI is a safety-related system.

In April 2023, via operating experience from another site, the licensee learned that the HPCI signal converter was installed with a lockout feature that was not expected. This feature allows the HPCI signal converter to trip on different conditions (i.e., high temperature and high amperage). If the HPCI signal converter locks out, the operators would have to take manual actions to operate the system. Based on the inspectors review it was identified that the licensee had not entered this condition adverse to quality in their corrective action program to evaluate the impact to their site and implement corrective actions.

After further inspector questions the licensee determined that while they had not experienced issues with the signal converters lockout feature, their installed design was susceptible to the failure mode. The inspectors subsequently reviewed licensee provided documentation, such as training materials, procedures, and the corrective action document written after inspector identification. Based on the completed review, the inspectors did not identify any concerns with operability.

Corrective Actions: The licensees current corrective actions are to contact the vendor to remove the lockout function of the HPCI signal converter and reinstall.

Corrective Action References: AR 04694214, "HPCI Signal Converter Servo Amp Hardening Opportunity"

Performance Assessment:

Performance Deficiency: The licensee failed to identify a condition adverse to quality when information became available that the HPCI signal converter was installed with a lockout function that was not evaluated. This was contrary to 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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. Specifically, lockout of the HPCI signal converter would result in the operators having to take manual action to control HPCI flow which is designed to be an automatic function and it was not evaluated.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the finding screened as having very low safety significance (green) because they answered 'yes' to the questions: If the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality.

The inspectors determined the finding did not cause a loss of PRA functionality.

Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, the licensee became aware of Operating Experience associated with their HPCI signal converter modification in April 2023 and did not enter the condition adverse to quality in the corrective action program.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, from April 15, 2023 to August 2, 2023, the licensee failed to identify a condition adverse to quality. Specifically, the licensee became aware of a previously unevaluated installed lockout feature associated with the HPCI signal converter, a deficiency, and did not enter the condition adverse to quality into the corrective actions program.

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

Failure to Translate HPCI Room Design Basis Temperature into Surveillance Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000237,05000249/2023011-03 Open/Closed The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, "Design Control," when the licensee failed to correctly translate high pressure coolant injection (HPCI) room design basis initial temperature into the unit daily surveillance log procedure. Specifically, the licensee failed to ensure normal HPCI room temperature would remain at or below 104 degrees Fahrenheit as assumed in HPCI room thermal response design calculation and UFSAR Environmental Zone 6 normal service temperature.

Description:

Dresden Power Station had a safety-related High Pressure Coolant Injection (HPCI) system to provide core cooling under loss-of-coolant-accident (LOCA) conditions which do not result in rapid depressurization of the reactor pressure vessel. The HPCI system consisted of steam driven pumps, piping, and valves to transfer water from the suction source to the reactor core.

The HPCI room was equipped with a room cooler and fan to maintain HPCI room temperature at acceptable levels during prolonged operation. During normal operation, the room cooler was cooled by non-safety service water (SW). The Containment Cooling Service Water (CCSW) system provided a safety-related back up source of cooling water to the room cooler to keep the HPCI room from reaching the automatic isolation temperature setpoint of 173 +/- 5 degrees Fahrenheit and to maintain its Environmental Qualification (EQ)temperature requirements.

The inspectors reviewed HPCI EQ requirements and associated exemptions. UFSAR Section 3.11.1.4.1 Harsh Post-Accident Areas stated, exception to above 120 degrees Fahrenheit definition is taken for the HPCI Rooms where the peak temperature resulting from a LOCA is 127 degrees Fahrenheit with room coolers and 134 degrees Fahrenheit without room coolers and the environment is considered mild. UFSAR Table 3.11-1 Environmental Zone Parameters for Normal Service Conditions established the temperature for Zone 6, including HPCI rooms, as 104 degrees Fahrenheit. The inspectors reviewed design calculation DRE98-0077, Dresden HPCI Room Thermal Response with Reduced Room Cooler Capability Essential Calc, major revision 001 issued June 18, 2004. This is the current design bases calculation of record. The calculation concluded peak room temperatures during continuous operation of HPCI turbine was 127 degrees Fahrenheit when CCSW flow to the room cooler was initiated after 600 seconds and 134 degrees Fahrenheit after four hours without the room cooler or fan operating. These temperatures agreed with the UFSAR credited EQ temperature exemptions.

The inspectors reviewed DRE98-0077 minor revision 001C issued February 28, 2018, and noted changes that decreased available design margins. For example:

Minor revision 001C concluded total tube plugging limit for HPCI room cooler was 14 tubes based on 20 GPM CCSW flow to maintain the EQ basis for equipment in the HPCI Room. Eddy Current Testing under Work Order 05142242 on March 2, 2023, determined 39 tubes exceeded the predetermined tube plugging criteria of 70%. The 14 tubes that exceeded 90% tube plugging criteria were plugged and the inspection interval was shortened from 2 years to 1 year. Increased tube erosion was attributed to running non-safety SW at double the heat exchanger design flowrate.

Superseded calculation, RSA-D-92-06 HPCI Room Thermal Response with Loss of HPCI Room Cooler at Dresden Station revision 0 assumed a fan flow rate of 4750 cfm. In contrast, DRE98-0077 used the fan name plate rating of 4950 cfm. No surveillances to verify the rated flow were performed.

Relative humidity from DRE98-0077 revision 001 to 001C changed from 95% to 0%.

AR 04518422 U3 HPCI Room Coolers was reviewed which noted potential steam leaks in the U3 HPCI room.

Based on the above, the inspectors were concerned that decreased margins in HPCI room thermal response could impact conclusions in calculation DRE98-0077 and therefore, HPCI room EQ requirements. Specifically, a DRE98-0077 assumption stated, in part, initial room temperature is at 104 degrees Fahrenheit. This assumption was first established in revision 0 of the calculation issued on April 10, 1998. To validate this assumption, the inspectors reviewed Unit 2

(3) Appendix A, Unit Daily Surveillance Log, Revision 146. The surveillance procedure directed operators to maintain HPCI room temperature less than 100 degrees Fahrenheit however, it directed operators to operate the HPCI room cooler as necessary to reduce the temperature to less than or equal to 120 degrees Fahrenheit and then HPCI may be declared operable with no additional testing. This would invalidate the calculation design initial temperature assumption and Environmental Zone 6 normal service temperature. During an event requiring prolonged HPCI operation, exceeding the initial room temperature of 104 degrees Fahrenheit would cause higher than the peak 127 and 134 degree temperatures that current design bases calculation analyzes for, and exceed the temperatures that exempt the HPCI room from EQ harsh temperature requirements. Failure to translate the HPCI design basis initial temperature into the surveillance log procedure was determined to affect both Unit 2 and 3.

Inspectors also noted operators would not receive a control room alarm until HPCI room temperature reached 110 degrees Fahrenheit. The inspectors reviewed past condition reports and confirmed the HPCI room temperature had exceeded the design basis initial temperature of 104 degrees Fahrenheit as documented in AR 01245549.

Corrective Actions: The licensee entered this issue into their Corrective Action Program and planned to review HPCI room temperature design basis and evaluate appropriate recommendations to review HPCI room cooler calculations and/or operations procedure. The licensee determined no compensatory actions were currently needed based on shiftily monitoring of room temperature, and available historical calculation information to support continued HPCI operability.

Corrective Action References: AR 04694742, "2023 CETI - HPCI Room Temp Calc and Procedure Discrepancies.

Performance Assessment:

Performance Deficiency: The licensee's failure to correctly translate HPCI room design basis initial temperature assumptions into the Operations daily surveillance log procedure acceptance criteria was contrary to 10 CFR 50 Appendix B, Criterion III, "Design Control,"

and 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 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. Specifically, failure to translate HPCI room design basis temperature into the surveillance log procedure failed to ensure design assumptions would remain valid. The Unit Daily Surveillance Log Unit 2

(3) Appendix A would allow the HPCI room temperature to reach 120 degrees Fahrenheit. This would invalidate an initial assumed HPCI room temperature of 104 degrees Fahrenheit in the design calculation and UFSAR Environmental Zone 6 normal service temperature which would prevent exceeding peak room temperatures of 127 and 134 degrees Fahrenheit to protect HPCI from reaching the automatic isolation setpoint temperature, and to exempt the HPCI room from EQ harsh environment requirements.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the finding screened to Green (very low safety significance) because it did not result in the loss of operability or functionality. This was based on shiftily monitoring of room temperature, and available historical calculation information to support continued HPCI operability.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR 50 Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions.

Calculation DRE98-0077, Dresden HPCI Room Thermal Response with Reduced Room Cooler Capability Essential Calc, Revision 001 establishes the HPCI room design basis temperature response and assumes an initial HPCI room temperature of 104 degrees Fahrenheit.

UFSAR Table 3.11-1, Environmental Zone Parameters for Normal Service Conditions, establishes Zone 6 temperature as 104 degrees Fahrenheit, which includes the HPCI rooms.

Procedure Appendix A, Unit Daily Surveillance Log Unit 2 (3), Revision 146, include HPCI room temperature acceptance criteria which state, in part, operate HPCI room cooler as necessary to reduce the temperature to less than or equal to 120 degrees Fahrenheit. When the temperature is less than or equal to 120 degrees Fahrenheit, then HPCI may be declared operable with no additional testing required.

Contrary to the above, as of April 10, 1998, the licensee failed to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, acceptance criteria in Operations procedure Appendix A failed to ensure the HPCI room would be maintained at or below the assumed initial design basis temperature of 104 degrees Fahrenheit established in calculation DRE98-0077 and UFSAR Table 3.11-1.

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

EXIT MEETINGS AND DEBRIEFS

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

On August 4, 2023, the inspectors presented the Comprehensive Engineering Team Inspection results to Pat Boyle and other members of the licensee staff.

On August 3, 2023, the inspectors presented the Technical Debrief inspection results to Jason Biegelson and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21M Calculations 7927-52-19-2 Calculation for 250VDC Circuit Coordination Interaction for B

Appendix R

ANP-3749P Dresden Units 2 and 3 Atrium 10XM LOCA Break Spectrum 0

Analysis with Increased ADS Flow

CE-DR-011 Weak Link Analysis for Crane 10 Gate Valve 2(3)-2301-3 5

DR-721-M-003 The Emergency Air Cooler Coil Performance Evaluation for 0

the HPCI Turbine/Pump Rooms

DR-CID-52 Accuracy of the Contaminated Condensate Storage Tank 1

(CST) Level Indication Loops

DRE-0124 Dresden HPCI NPSH Temperature Limits 1

DRE-3-2301-3 DC Motor Operated GL96-05 Gate Valve 7

DRE-3-2302-1 Rising Stem Motor Operated Valve Data Sheet 7

DRE00-0054 HPCI Condensate Storage Tank Level Error Analysis 0

DRE01-0041 Updated EQ Zone Parameter Tables Following 3

Implementation of Extended Power Uprate

DRE01-0070 Seismic and Environmental Qualification of the 250VDC 0

MCC Components

DRE03-0015 HPCI MOV Design Basis Document and Differential 0A, 0C

Pressure Calculation

DRE18-0010 Dresden Unit 2 and 3, 250 VDC System Analysis 2

DRE96-0206 HPCI Pump Discharge Pressure for 5000 GPM Flow to 1

Reactor Vessel

DRE96-0215 Pressure Drop Analysis for HPCI Exhaust Steam Piping 1

DRE97-0063 HPCI Turbine Pump Room Cooling Load Calculation 1A

DRE97-0145 Maximum Flow Through the LPCI and HPCI Pump Minimum 2A

Flow Lines

DRE97-0170 Dresden HPCI Room Thermal Analysis Loss of Room 0

Cooler

71111.21M Calculations DRE98-0030 Determination of Setpoint of CST LOW-LOW Level Switches 0A, 0B, 0C

to Prevent Potential Air Entrainment from Vortexing During

HPCI Operation

DRE98-0033 Unit 3 Reactor Building MCCS Thermal Overload Heater 2

Sizing

DRE98-0077 Dresden HPCI Room Thermal Response with Reduced 1, 1C

Room Cooler Capability

DRE98-0200 Qualification of Support for CST Pressure Switches 0

DRE99-0013 Hydraulic Performance of the HPCI System 2, 2D

NED-I-EIC-0109 High Pressure Coolant Injection (HPCI) Pump Discharge 6, 6A

Flow Loop Accuracy and Minimum Flow Set Points

NED-I-EIC-0111 High Pressure Coolant Injection (HPCI) Steam Line High 6

Flow Isolation Setpoint Error Analysis

NF-BEX-13-68-P LOCA Analysis for SVEA-96 OPTIMA2 Fuel 0

RSA-D-92-06 HPCI Room Thermal Response with Loss of HPCI Room 0

Cooler at Dresden Station

Corrective Action 1245549 U3 HPCI Room Temperature 07/29/2011

Documents 3988159 2-2301-3 U2 HPCI Turb Stm Supply MOV Did Not Open 03/22/2017

4109028 HPCI Room Cooler Tube Plugging 02/27/2018

4159025 Verification of HPCI Room Cooler Airflow Needed 07/26/2018

21994 Step Increase in Vibration Levels on U2 HPCI Room Cooler 02/20/2019

272562 OP-DR-102-106 Requires Revision 07/03/2019

293954 Unit 2 HPCI AOP Failed to Stay Running 11/02/2019

4315614 NRC Question on DOS 2300-03 Acceptance Criteria 02/05/2020

29276 3D ERV Tailpipe Temp Rise 03/24/2020

4331189 NRC: Procedures and Instrument Uncertainty 03/31/2020

4332151 Strengthen Procedures Involving Torquing 04/02/2020

4348755 U3 HPCI Bearing #2 Vibes Greater than 3 mils 06/11/2020

4360154 Corporate Torque HIT Actions 07/31/2020

4362710 3D ERV Stroking Issues 08/12/2020

4382882 D3R26 - Steam Leak from HPCI Rupture Disc 11/07/2020

4450012 Contingency WO for Timer Relay Replacement for 2/3 10/01/2021

250VDC Battery Charger

4518422 U3 HPCI Room Concerns 08/23/2022

4541698 U1 HPCI MGU Abnormal Indications During Signal 12/09/2022

Converter Cal

4542053 HPCI Signal Converter Servo Amplifier Fault Light Lit 12/11/2022

803865 Dresden Actions in Response to NRC GL 2008-01 08/05/2008

Corrective Action 4691022 50.59 Screening Paperwork Supplemental Record Needed 07/17/2023

Documents 4691172 CETI 2023 - UFSAR 8.1.2 Requires Revision 07/18/2023

Resulting from 4691637 2023 CETI: ASME Code Related Component ISI/ANI 07/20/2023

Inspection Documentation

4691644 Missing Screws on Junction Box 3RB-53 07/20/2023

4691683 CETI 2023: FG 3-2301-70 07/20/2023

4691903 2023 CETI - EC404291 and 50.59 Documents Require 07/21/2023

Revisions

4691908 2023 CETI EC 404290 IP-ENG-001 Form 2 has Typo Error 07/21/2023

4694214 HPCI Signal Converter Servo Amp Hardening Opportunity 08/02/2023

4694498 Conflict Between ISI and IST Documents 08/03/2023

4694742 2023 CETI - HPCI Room Temp Calc and Procedure 08/04/2023

Discrepancies

4695296 2023 CETI-NRC ID: Issue with Uncertainty Not in ECCS 08/08/2023

Testing

Drawings 12E-3462 Sheet 1 Schematic Diagram Auto Blowdown Part 2 AH

2E-3462 Sheet 3 Schematic Diagram Auto Blowdown Electromatic Relief AG

Valve 203-3E and 203-3D

21800-001 Unit 2 ADS Initiation Logic 1

DRE206LN001 Circuits Initiation Trip Reset 6

Fig 10

M-310 Sh 62 Instrument Installation Details - Condensate System 4

M-35 Sh 1 Diagram of Demineralized Water System Piping ER

M-374 Diagram of High Pressure Coolant Injection Piping CZ

M-4456 HPCI Room Cooler Drip Pan & Support Structure A

M-51 Diagram of High Pressure Coolant Injection Piping CX

Engineering 2019-014 Loss of Heating Boilers 0

Changes 2019-036 Feedwater Regulating Valve (FWRV) Operation 0

2019-039 Replace CCSW Vault Cooler Cooling Coils-U2 DIV 1 0

(Coolers A&B)/EC 404290

20-016 Diesel Generator Cooling Water Pump Quarterly Test 0

21-005 Unit2(3) Monthly Station Battery Inspection 0

22-009 Calibrate Venturi Feedwater low Rate for Unit 2 0

357611 HPCI Inputs Validated for LOCA Analysis 11/16/2006

360968 Evaluation of Potential Secondary Containment Bypass 05/12/2006

During HPCI Pipe Breach

371153 NRC GL 2008-01 HPCI System Evaluation 11/24/2012

397957 Replace U3 HPCI Signal Converter and Flow Indicating 7

Controller

404291 Replace CCSW Vault Cooler Cooling Coils - U2 - Division 2 0

448508 Provide Torque Value for HPCI Rupture Discs (2(3)-2301-68 11/02/2020

& -69) with Fully Lubricated Flange Bolts

27314 Provide Temporary Supplemental Cooling to U2 HPCI Room 0

Due to 2-5747 U2 HPCI Room Cooler High Vibes

29898 Install HPCI AOP Jumper in 902-3 Panel 2-2302-AOP 1

2912 HPCI Steam Rupture Disk - Allow Use of 140 PSIG Rated 0

Set.

638016 CCSW Line 3-1510-16"/Code Repair of Through Wall Leak 1

Engineering 2023-01-001 Modification to Install Alternate HPCI Signal Converter to 0

Evaluations Replace Functions of 2(3)- 2386 with 2(3)-2386A

386611 Evaluation of HPCI Room Cooler (2-5747) Safety-Related 11/09/2011

Cooling Water Requirements

216498 Dresden Unit 2 HPCI Room Cooler Operability 07/07/2000

633963 Evaluation of ECCS Instrument Uncertainties Impact on 06/23/2021

ECCS-LOCA Analysis

6N3917 Generic ECCS Flow Reduction SAFER Sensitivity Study 0

CMED-057604 Evaluation of the Functional Capability of Components 1

Located in Dresden Unit 3 EQ Zones 4, 5, 6 for Elevated

Temperature Resulting from Loss of Room Coolers

Miscellaneous 08-22 Permanent Scaffold Request Form 04/09/2008

13659-M1 Installation, Operation, and Maintenance Manual for HPCI 1

Signal Converter Nutherm Model 73315

2006-0256 50.59 Screening - Implement WestinghouseOptima2 0

Nuclear Fuel - Impact on Alternate Source Term (AST)

Bases

71111.21M Miscellaneous 2023-007 Replace U2(3) HPCI Signal Converter and Flow Indicating 0

Controller

21A5779 Data Sheet for Auxiliary Steam Turbine Drives (HPCI 1

System)

257HA353AB High Pressure Coolant Injection System Data Sheets 3

970321F Dresden Nuclear Power Station Units 2 and 3 Evaluation of 03/21/1997

Methods to Address ECCS Flow and Pressure

Measurement Uncertainties

Bulletin 77-3001I BS&B Installation Instructions Type B and D Rupture Disks 09/01/2000

D1596 Vendor Manual for Model 2539 Controller 0

D1622, Vol II Battery Charger Vendor Manual 2

DBD-DR-001 High Pressure Coolant Injection System - 5.9.1 HPCI Safety A

Head (Rupture Disc)

DOA 3500-02 50.59 Screening Loss of Feedwater Heaters 48

DRE22-0006 Operation Manual Action Timeline Analysis 06/22/2023

ED-100D ERV Actuator, General Electric Model 352B2632G001, Used 1

with the Dresser 1525VX Electromatic Relief Valve

GE-NE-A22- Task T0404: High Pressure Coolant Injection System 0

00103-33-01

GEK-26901 Instrumentation Subsystem of the Dresden 2 High Pressure 0

Coolant Injection (HPCI) System Vendor Technical Manual

IST-DRE-BDOC- Inservice Testing Basis Document 2-2301-20 07/27/2003

V-15

IST-DRE-BDOC- Inservice Testing Basis Document 3-2301-6 01/26/2015

V-15

IST-DRE-BDOC- Dresden - Inservice Testing Bases Document 07/19/2023

V-15

NA Inservice Testing (IST) Program Plan 5

OPXR 00935420- IN 2009-09 Response 09/23/2009

RS-01-033 Supplement to GE-14 Fuel License Amendment Request 03/01/2001

UFSAR Change Dresden Units 2 & 3 UFSAR Change under Design Change 10/23/2006

06013 Package 350134

Procedures CC-AA-103-100 Configuration Change Control for Permanent Physical Plant 2

Changes

CC-AA-112 Temporary Configuration Changes 31

CC-AA-256 Process for Managing Plant Modifications Involving Digital 9

Instrumentation and Control Equipment and Systems

DAN 902(3)-3 C-7 Unit 2 (3) HPCI Auto Isol Initiated 14

DAN 902(3)-3 E- 3E Electromatic Relief Vlv OPEN 18

DAN 902(3)-6 A-5 Cond Storage Tank Lvl HI-LO 19

DAN 923-5 H-4 Reactor Building Ventilation System 13

DEOP 0100-00 Reactor Pressure Vessel Control 14

DEOP 0400-06 Alternate RPV Level-Pressure Control 0

DEOP 0500-02 Bypassing Interlocks and Isolations 23

DEOP 0500-07 Alternate Emergency Depressurization Systems 2

DES 8300-01 Inspection and Maintenance of DC-Operated Cutler- 15

Hammer Reversing and Field Contactors Model 912 and

2 and MODEL ME

DGA-12 Loss of Offsite Power 80

DGA-22 Station Blackout 4

DIS 0250-05 ADS Valve Auto-Actuation abd Loss of Control Power Logic 51

Test

DMP 2300-14 HPCI Rupture Disc Maintenance 9

DOA 2300-02 HPCI Fast Startup 12

DOC 2300-03 High Pressure Coolant Injection System Operability and 119

Quarterly IST Verification Test

DOS 0250-07 Electromatic Relief Valve Testing with the Reactor 6

Depressurized

ER-AA-700-1003 Use of Operating Experience for License Renewal 6

Implementation/Aging Management

ER-DR-200-201 Periodic Monitoring for Gas Accumulation in ECCS Systems 8

IP-ENG-001 Standard Design Process (EB-17-06) 3

LS-AA-104 Exelon 50.59 Review Process 12

MA-MW-726-022 Electrical Cable Termination and Inspection 14

NES-MS-04.1 Seismic Prequalified Scaffolds 7

OP-AA-102-106 Operator Response Time Program 8

OP-DR-102-106 Operator Response Time Program at Dresden 14

Unit Daily Unit 2 (3) Appendix A 146

Surveillance Log

Work Orders 00507529 Battery Charger 2/3 10Y PM Replace All Vendor 01/16/2014

Recommended Components

00654428 D2 6rFL COM HPCI TURB Dismantle 11/17/2015

227541 10Y COM PM Internal Inspection of CCST-B Tank Bottom 01/22/2015

01423636 00007025-01, PMSR, D3 6Y PM 250VDC BKR 2301-3 HPCI 03/02/2018

Steam Supply VLV, E: 3-83250-3BK2, MCCA, M05

01430387-01 D3 8Y COM HPCI Lube Oil Cooler INSP/CLEAN/EDDY 02/26/2019

CURRENT TEST

01592255-01 D3 8Y PM Replace HPCI Room Cooler Cooling Coil 05/03/2019

01805281-01 EWP D2/3 5Y COM PM Inspection of CCST A Tank 05/02/2019

01911751-08 EWP EM Install/Remove Temp Power to 20 Ton HVAC Unit 02/20/2019

04570331 D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During 11/12/2018

Startup

04877127 Replace 3D Electromatic Relief Valve 11/10/2022

04880337 TS D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During 11/07/2020

Startup

04894499 TS D3 QTR TS HPCI Pump Comprehensive Oper Test and 02/24/2021

IST Sur

04921734-01 EWP D3 2Y Com Open/Clean/Insp/Eddy Current HPCI Rm 02/24/2021

Clr Coil

04921737-01, 02 EWP EM Post-OOS Portion of Clr Fan Mtr HPCI Rm 02/23/2021

04975780 Unit 2 HPCI AOP Failed to Stay Running 11/02/2019

05068923 Replace Relay 3-0287-114D 08/13/2020

05095264 D3 RFL PM Electromatic Relief E Replace Pilot 11/08/2022

05096712 D3 RFL ED Eng W/D Perm Scaffold 11/18/2022

05096718 TS D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During 11/18/2022

Startup

05107156-01 24 Month 250VDC 2/3 Battery Charger Four Hour Load Test 01/06/2023

05124083 D3 RFL PM Maint-Surv on 3-203-3D Electromatic 11/16/2022

05125118 D3 RFL PM Maint-Surv on 3-203-3E Electromatic 11/14/2022

05128666 TS D3 2Y TS (IST) HPCI Pump Comprehensive Oper Test 03/03/2023

and IST Sur

05130803-01 D3 2Y PM HPCI Rm Cooler Fan Motor Bridge/Meg Cln Insp 03/01/2023

Belt Re

05142242-01, 04 MM EWP 2Y Com Open/Clean/Insp/Eddy Current HPCI 03/02/2023

235883-01 EWP MM D3 SA PM Fan Brgs HPCI Pmp Room 08/23/2022

Clg - Grease Fittings

271158 TS D3 QTR TS (IST) HPCI Pump Oper Test and IST Surv 09/15/2022

287575-01 D3 SA PM Fan Brgs HPCI Pmp Room Cooler - Grease 02/22/2023

Fittings

05303110 TS D3 QTR TS (IST) HPCI Pump Oper Test and IST Surv 11/19/2022

05312584-01 ASME Section XI Repair/Replacement Plan 06/15/2023

05355681 TS D3 31D TS HPCI Disch Piping Water Solid Verification 05/17/2023

05366756 TS D3 31D TS HPCI Disch Piping Water Solid Verification 06/13/2023

05377956 TS D3 31D TS HPCI Disch Piping Water Solid Verification 07/13/2023

24