IR 05000237/2025001

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Integrated Inspection Report 05000237/2025001 05000249/2025001 and 07200037/2025001
ML25127A001
Person / Time
Site: 05000236, Dresden
Issue date: 05/08/2025
From: Robert Ruiz
NRC/RGN-III/DORS/RPB1
To: Rhoades D
Constellation Energy Generation
Shared Package
ML24312A374 List:
References
IR 2025001
Download: ML25127A001 (1)


Text

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2025001; 05000249/2025001 AND 07200037/2025001

Dear David Rhoades:

On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On April 15, 2025, the NRC inspectors discussed the results of this inspection with H. Patel, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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.

May 8, 2025 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000237; 05000249 and 07200037 License Nos. DPR-19 and DPR-25

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000237; 05000249 and 07200037

License Numbers:

DPR-19 and DPR-25

Report Numbers:

05000237/2025001; 05000249/2025001 and 07200037/2025001

Enterprise Identifier:

I-2025-001-0064 and I-2025-001-0082

Licensee:

Constellation Energy Generation, LLC

Facility:

Dresden Nuclear Power Station, Units 2 and 3

Location:

Morris, IL

Inspection Dates:

January 01, 2025 to March 31, 2025

Inspectors:

N. Audia, Reactor Inspector

B. Lin, Senior Health Physicist

J. Meszaros, Resident Inspector

M. Porfirio, Illinois Emergency Management Agency

C. St. Peters, Senior Project Engineer

J. Steffes, Senior Resident Inspector

Approved By:

Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

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. A licensee-identified non-cited violation is documented in report section: 71152

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On March 7, 2025, power was reduced to approximately 80 percent to perform control rod recovery following scram valve maintenance. The unit returned to rated thermal power the next day. On March 21, 2025, power was reduced to approximately 55 percent to perform scram valve maintenance, rod sequence exchange and 2D condensate/condensate booster pump maintenance. The unit returned to rated thermal power on March 23, 2025, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 3 began the inspection period at rated thermal power. On February 26, 2025, power was reduced to approximately 32 percent to troubleshoot and correct a drywell pneumatic leak and perform rod sequence exchange. The unit was returned to rated thermal power on February 28, 2025, and remained at or near rated thermal power 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

Standby liquid control, station batteries, and emergency diesel generators, on January 6 - 10, 2025

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather of high winds and possible tornadic activity on March 14, 2025.

71111.04 - 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 standby liquid control system on January 6, 2025
(2) Unit 2 standby diesel generator system on January 8, 2025
(3) Unit 3 isolation condenser on January 23 - 30, 2025
(4) Unit 2 isolation condenser during high pressure core injection work window on March 26-27, 2025

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) Fire zone (FZ) 7.0 B, Unit 3 battery room elevation 551', and FZ 6.1, Unit 3 250V battery charger room elevation 538', on January 3, 2025
(2) FZ 11.2.1, Unit 2 southwest corner room elevation 476', on January 14, 2025
(3) FZ 6.2, Unit 2/3 comp room and auxiliary electrical room elevation 517', on January 31, 2025

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on February 7, 2025.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 3 "B" reactor building closed cooling water system heat exchanger

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 the Unit 3 planned downpower and subsequent power ascension due to a drywell pneumatic leak on the 1A MSIV on February 26, 2025 and February 28th, 2025.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed crew performance in the main control room simulator on January 24, 2025.

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) Drywell continuous air monitor system, due to failures
(2) Maintenance rule periodic 10CFR50.65 (a)(3) assessment Quality Control (IP Section 03.02) (1 Partial)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1)

(Partial)

Unit 2 high pressure coolant injection booster pump fitting repair per Work Order (WO) 5540836

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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 2 plant risk review and management action implementation associated with action green and blue fire risks due to planned maintenance on the high pressure coolant injection system on March 25-27, 2025

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (1 Sample)

(1) Post-maintenance testing followed planned maintenance on the 3C shutdown cooling breaker, per WO 4598872

Surveillance Testing (IP Section 03.01) (2 Samples)

(1) DIS 0250-02, Main Steam Line Low Pressure Isolation Switch Calibration (Reactor Mode Switch in Run Position), on January 17, 2025
(2) Unit 3 division 2 core spray logic system function test per WO 5350913 on March 20-21, 2025

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) Unit 2 diesel generator cooling water pump test per WO 5615641
(2) Unit 2A standby liquid control pump surveillance per WO 5619671

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (2 Samples)

The inspectors evaluated:

(1) Focus area drill on January 30, 2025
(2) Focus area drill on February 4,

OTHER ACTIVITIES - BASELINE

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) Evaluation and corrective actions for the discolored and contaminated oil, as documented in Action Request (AR) 4790335 and AR

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of An ISFSI Operation of An ISFSI

(1) The inspectors evaluated the licensee's independent spent fuel storage installation (ISFSI) cask loading activities from March 17 through March 21, 2025. Specifically, the inspectors observed the following activities during the loading of Multi-Purpose Canister (MPC) No. 840:
  • heavy load movement of loaded MPC out of the spent fuel pool
  • canister blowdown
  • closure welding and non-destructive evaluations
  • radiological field surveys The inspectors performed walkdowns of the ISFSI pads and haul path, which also included performing independent radiation surveys.

The inspectors evaluated the following:

  • spent fuel selected for loading into dry cask storage during this loading campaign
  • selected corrective action program documents
  • selected 72.48 screenings and evaluations
  • changes to the site's 10 CFR 72.212 report since the previous inspection

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71152A This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification Section 5.4.1.a. requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 9 addresses Procedures for Performing Maintenance and Section 9.a, addresses maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

The licensee established Procedure MA-AA-716-006, Control of Lubrication Program, Revision 16, to address instructions for the storage, control, use and disposal of lubricants, and provides guidance for oil sampling and analysis. Procedure MA-AA-716-006, Control of Lubrication Program, Revision 16, Step 4.4.3 requires "STORE radiologically clean waste oils/greases in designated containers in appropriate storage rooms, (or other area directed),for proper disposal at some later date.

Contrary to the above, prior to May 14, 2024, to January 17, 2025, the licensee failed to implement Step 4.4.3 of procedure MA-AA-716-006, Control of Lubrication Program, Revision 16. Specifically, the licensee did not implement the proper storage of lubricants as outlined in MA-AA-716-006, allowing the drum of Mobil DTE 746 to become contaminated with a non-similar oil type and was later added to the upper reservoir for the 2D low pressure coolant injection (LPCI) motor, a safety related component.

Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors answered "NO" to questions A.1. through A.6, and determined that the finding was of very low safety significance (Green).

Corrective Action References: AR 4790335, Mobil DTE 746 Oil Drum - Discolored Oil AR 4792117, Mobil DTE 746 Oil Drum - Discolored Oil (F/U to IR 04790335 AR 4829285, 2D LPCI Motor-Abnormal Oil Samples (F/U to IR 04792117)

EXIT MEETINGS AND DEBRIEFS

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

  • On April 15, 2025, the inspectors presented the integrated inspection results to H. Patel, Plant Manager, and other members of the licensee staff.
  • On March 31, 2025, the inspectors presented the ISFSI cask loading inspection results to H. Patel, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DR-0-25-00205

Combined ALARA Plan/Micro-ALARA Plan

2/06/2025

ALARA Plans

RP-AA-401

ALARA Work-In-Progress Review

03/21/2025

4500105

NOS ID: HI-Storm Move Sheet for 2020

05/16/2022

4500125

22 ISFSI NRC Inspection-HI-STAR Cask Degraded

Areas

05/16/2022

4501575

22 Dry Cask Cask #2 Completion

05/23/2022

4777107

Soft Deposits on HI-Storm 100-010

05/29/2024

Corrective Action

Documents

4810843

Work Request for Leak Test of HI-TRAC

10/21/2024

Corrective Action

Documents

Resulting from

Inspection

4846657

NRC ID: 2025 Dresden FSP Typographical Error

03/18/2025

Engineering

Changes

DRE25-0001

Dresden Unit 2 Fuel Selection Packages and Alternate

Assembly List for the 2025 SFLC - ISFSI

2.48-755

Radiological and Licensing DCR for South ISFSI Expansion

Pad

2.48-775

Dry Cask Storage/ISFSI Inspection Surveillance Program

2.48-777

Implementation of Holtec ECO No. 5014-312 R0 for Storage

of Select Foreign Materials in the HI-STORM 100 System via

2.212 Change Requests 22-01 R0 and 22-02 R0

2.48-792

Holtec Independent Spent Fuel Storage Installation (ISFSI)

Radiation Survey

Miscellaneous

2.48-801

Spent Fuel Casks for the 2025 Loading Campaign (Dresden

ISFSI)

21227-840-04

Canister Lid to Shell

03/21/2025

21227-840-05

Canister Lid to Drain Port Cover with Setscrews

03/21/2025

21227-840-06

Canister Lid to Vent Port Cover with Setscrews

03/21/2025

NDE Reports

21227-840-07

Canister Shell and Lid to Closure Rings

03/21/2025

Quality Assurance Manual

GQP-9.6

Visual Examination of Welds

60855

Procedures

LS-AA-114

Constellation 72.48 Review Process

MA-DR-MM-4-

58904

Dry Cask Storage Special Lifting Device Inspection/Testing

MA-DR-MM-5-

58003

Visual Inspection and Preventive Maintenance of Unit 1, Unit

2, Unit 3, and Unit 2-3 Overhead and Gantry Cranes

NF-AA-622-1000

Fuel Characterization for Dry Storage

NO-AA-10

Quality Assurance Topical Report

Procedures

OU-MW-671-200

MPC Processing Forced Helium Dehydration (FHD) for

BWRs

24-215149

Radiological Survey of East ISFSI Pad

04/10/2024

24-218725

Radiological Survey of West ISFSI Pad

06/04/2024

Radiation

Surveys

25-236614

Radiological Survey of Cask Pad

03/17/2025

Self-Assessments NOSA-DRE-22-

Independent Spent Fuel Storage Installation Audit Report

05/25/2022

4946090-01

D2/3 3Y COM ISFSI Integrity Surveillance

08/02/2022

24566-01

EWP EM D2/3 1Y COM OSHA Insp Crane - Rx Bldg

Overhead

2/14/2025

24566-02

EWP EM D2/3 1Y COM OSHA Insp Crane - Festoon

Inspection

2/14/2025

60855

Work Orders

24567-01

MM D2/3 1Y COM Reactor Building Overhead Crane Inspctn

2/15/2025

26954

SBLC 3B Relief Valve Line Heat Trace Not Completely on

Pipe

01/07/2025

28014

NRC Questions from Plant Walkdown

01/07/2025

Corrective Action

Documents

Resulting from

Inspection

4845456

NRC Identified Missile Hazards

03/14/2025

Miscellaneous

Certification of 2024-25 Winter Readiness

11/15/2024

DOA 0010-02

Tornado Warning/Severe Winds

DOA5700-01

Loss of Heating Boilers

DOS 0010-22

Preparation for Cold Weather Operations for Unit 2

DOS 0010-25

Preparation for Cold Weather Operations for Unit 3

OP-AA-108-111-

1001

Severe Weather and Natural Disaster Guidelines

OP-DR-108-111-

1004

Cold Weather Strategy

71111.01

Procedures

OP-DR-108-111-

1006

Intake Blockage Station Response

71111.04

Drawings

M-173

Diagram of Corrosion Test Diesel Start-up Air Piping

BJ

M-22

Diagram of Service Water Piping

FA

M-28

Diagram of Isolation Condenser Piping

LS

M-33

Diagram of Standby Liquid Control Piping

IB

M-359

Diagram of Isolation Condenser Piping

BR

M-40

Diagram of Turbine Building Equipment Drains and Diesel

Air Intake And Exhaust

ZN

M-41

Diagram of Turbine and Diesel Oil Piping

AI

M-478

Diagram of Diesel Generator Lube Oil Piping

J

M-517

Diesel Generator Engine Cooling Water System

I

M-518

Diesel Generator Fuel Oil System

F

M-974

Diagram of Diesel Generator Room Ventilation

L

DOP 1100-01

Standby Operation of Standby Liquid Control System

DOP 1100-M1

Unit 2 Standby Liquid Control System Checklist

DOP 1300-M1/E1

Unit 3 Isolation Condenser System Checklist

DOP 1300-M1/E1

Unit 2 Isolation Condenser System Checklist

DOP 6600-01

Diesel Generator 2 Preparation for Standby Operation

Procedures

DOP 6600-M1

Unit 2 Standby Diesel Generator

Calculations

DRE97-0105

Determination of Combustible Loading

Corrective Action

Documents

4835485

4.0 Critique Crew 5 Q1 Announced Fire Drill

2/07/2025

100 Prefire Plan

Master Legend

Dresden Generating Station Pre-Fire Plan

2 U2RB-2

FZ 11.2.1 Unit 2 Southwest Corner Room Eleve. 476'

143 U2TB-46

FZ 6.2 Unit 2/3 Comp Room & Auxiliary Electrical Room

Elev. 517

169 U3TB-79

FZ 7.0 B Unit 3 Battery Room Elev. 551'

Fire Plans

169 U3TB-80

FZ 6.1 Unit 3 250V Battery Charger Room Elev. 538'

DR-PSA-021.11

Dresden Fire PRA Summary & Quantification Notebook

71111.05

Miscellaneous

Fire Drill Scenario

25-01

U3 RB 3B Pump Back Compressor Fire

2/04/2025

NDE Reports

3B RBCCW EDDY CURRENT EXAMINATION FINAL

REPORT

01/2025

Procedures

DTP 75

Heat Exchanger Inspection Program

71111.07A

Work Orders

20289

D3 QTR COM REVIEW OF RBCCW OPERATIONAL

TREND DATA

2/21/2024

5499196

D3 QTR COM REVIEW OF RBCCW OPERATIONAL

TREND DATA

05/29/2024

5544001

D3 QTR COM REVIEW OF RBCCW OPERATIONAL

TREND DATA

08/21/2024

OBE 25-01A

LORT Scenario

Miscellaneous

OP-AB-300-1003

ReMA Plan D329-005 Unit 3 Shutdown

71111.11Q

Procedures

TQ-AA-155

Conduct of Simulator Training and Evaluation

4540536

MRULE A1 Determinations Performed Incorrectly

2/02/2022

4793017

U2 Drywell CAM Inoperable

08/09/2024

4796424

Unit 2 Drywell CAM Low Flow Issue

08/23/2024

4796772

Potential Trend IR: Unit 2 Drywell CAM Equipment Failure

08/26/2024

4812159

Trend IR for U2 DW CAM

10/25/2024

4819082

TRM 3.4.d - 30d Clock Exceeded for U2 DW CAM INOP

11/21/2024

4819869

U2 Drywell CAM Flow Indicator Light is Red

11/26/2024

24283

U2 Drywell CAM Deemed Inoperable due to Flow Issue

2/17/2024

Corrective Action

Documents

4830977

Unit 2 CAM is OOS due to High Flow

01/19/2025

Maintenance Rule Periodic Assessment #15 (10CFR50.65

(a)(3) Assessment)

10/01/2022-

09/30/2024

Miscellaneous

Maintenance Rule (a)(1) Status Report

2/06/2025

ER-AA-320

Maintenance Rule Implementation Per NEI 18-10

Procedures

ER-AA-320-1007

Maintenance Rule 18-10 - Periodic (a)(3) Assessment

71111.12

Work Orders

5084827-01

NMC Drywell Continuous Air Monitor Preventive

Maintenance and Calibration

11/24/2024

OP-AA-108-117

Protected Equipment List

03/25/2025

OP-DR-108-117-

1001

Protected Equipment and Pathway Policy

71111.13

Procedures

WC-AA-101-1006

On-line Risk Management and Assessment

71111.24

Procedures

DOS 1100-04

Standby Liquid Control System Quarterly/Comprehensive

Pump Test for the Inservice Testing Program

0607027-03

EM EWP Perform Receipt Inspection on 4KV Bkr UTC

0000873998

01/07/2025

4598872

D3 8Y PM 4KV CUB INSP BUS 34-1 CUB 14; 3C SDC PMP

01/14/2025

5396420

TS MSL Lo Press Including Time Delay Relay Cal

01/17/2025

71111.24

Work Orders

5598901

EM Swap 4KV Bkr Bus 34-1, Cubicle 14 (UTC 0000873998)

01/16/2025

1Q2025 FAD

Focus Area Drill

2/04/2025

71114.06

Miscellaneous

1Q2025FAD

Focus Area Drill

01/30/2025

4790335

Mobile DTE 746 Oil Drum - Discolored Oil

07/29/2024

4792117

Mobil DTE 746 Oil Drum - Contaminated (F/U to IR

04790335)

08/06/2024

Corrective Action

Documents

29285

2D LPCI Motor - Abnormal Oil Samples (F/U to IR

04792117)

01/13/2025

Miscellaneous

VETIP Binder #:

D1995

General Electric Tri-Clad Vertical Induction Motors

DOS 0040-02

Operator Oil Sampling for Offsite Laboratory Analysis

160

MA-AA-716-006

Control of Lubricants Program

MA-AA-716-230-

1001

Oil Analysis Interpretation Guideline

Procedures

MA-AA-716-230-

1004

Lubricant Sampling Guideline

71152A

Work Orders

5160690-01

EM EWP 4Q EQ 2D LPCI PMP MOTOR E.Q. SURV

05/14/2024