IR 05000237/2019003

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Integrated Inspection Report 05000237/2019003 and 05000249/2019003
ML19305B804
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 11/01/2019
From: Kenneth Riemer
Division Reactor Projects III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2019003
Download: ML19305B804 (28)


Text

November 1, 2019

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2019003 AND 05000249/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On October 8, 2019, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba 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 did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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. 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 10 CFR 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:

05000237/2019003 and 05000249/2019003

Enterprise Identifier: I-2019-003-0063

Licensee:

Exelon Generation Company, LLC

Facility:

Dresden Nuclear Power Station, Units 2 and 3

Location:

Morris, IL

Inspection Dates:

July 01, 2019 to September 30, 2019

Inspectors:

L. Alvarado Guilloty, Resident Inspector

R. Elliott, Resident Inspector

M. Garza, Emergency Preparedness Inspector

J. Havertape, Resident Inspector

A. Nguyen, Senior Resident Inspector

C. Phillips, Project Engineer

M. Porfirio, Illinois Emergency Management Agency

Approved By:

Kenneth R. Riemer, Chief

Branch 1

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Inadequate Work Instructions for Operationally Critical Work Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000249,05000237/2019003-01 Open/Closed

[H.2] - Field Presence 71152 A self-revealed finding of very low safety significance was identified for the licensees failure to provide adequate work instructions for maintenance activities on multiple occasions in accordance with procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks. Specifically, between December 2018 and May 2019, two instances of inadequate work instructions were identified as being primary causes of improper maintenance performed on OPCC systems that caused operational transients.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000237/2019-002-00 LER 2019-002-00 for Dresden Nuclear Power Station, Unit 2 Scram Due to Main Turbine Low Oil Pressure Trip.

71153 Closed

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On July 13, 2019, the unit was down powered to 70 percent for a control rod pattern adjustment. The unit returned to full power on July 14, 2019. On August 3, 2019, the unit was down powered to 68 percent for a control rod pattern adjustment. The unit returned to full power on August 4, 2019. Unit 2 began coast down for the upcoming scheduled refueling outage, D2R26, on August 14, 2019, and ended the inspection period in coast down.

Unit 3 began the inspection period at rated thermal power. On September 23, 2019, the unit performed an emergent down power and was taken off-line to repair an oil leak on the Unit 3 Main Power Transformer. During the forced outage (D3F52) for the transformer repairs, the unit maintained approximately 20 percent thermal power output without being connected to the grid.

The unit synchronized back to the grid on September 27, 2019, and returned to full power on September 29, 2019. The unit remained at rated thermal power for the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Q - 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 2 isolation condenser alternate injection sources (primary out of service for maintenance) on September 3, 2019
(2) Unit 2 core spray system on September 17, 2019
(3) Unit 2 high pressure coolant injection system (HPCI) on September 19, 2019

71111.04S - Equipment Alignment

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

(1) The inspectors evaluated system configurations during a complete walkdown of the cooling water systems on July 16 - 18, 2019.

71111.05A - Fire Protection (Annual)

Annual Inspection (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade performance during a drill in the administration building on July 18, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (6 Samples)

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

(1) Fire Zone 8.2.1B, Unit 3 Condensate Pump Floor, Elevation 469 on July 9, 2019
(2) FZ 8.2.2B, Unit 3 CCSW Pump Floor, Elevation 495 on July 9, 2019
(3) FZ 1.1.2.3, Unit 2 Reactor Building General Area, Elevation 545 on July 31, 2019
(4) FZ 8.2.6A, Unit 2 Reactor Feed Pump Ventilation and Hydrogen Seal Oil Area, Elevation 538 on July 31, 2019
(5) FZ 8.2.5.C, Unit 2/3 EHC Reservoir and Condensate Demineralizer Areas, Elevation 517' on September 9, 2019
(6) FZ 8.2.6.C, Unit 2/3 Lube Oil Reservoir and Common Mezzanine Areas, Elevation 534' on September 9, 2019

71111.07A - Heat Sink Performance

Annual Review (IP Section 02.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 2A and 2C shutdown cooling heat exchangers

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 an emergent down power on Unit 3 to take the turbine off-line for repairs to the Main Power Transformer on September 24, 2019.

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

(1) The inspectors observed and evaluated licensed operator requalification training with Emergency Preparedness requalification requirements in the control room simulator on August 29, 2019.
(2) The inspectors observed and evaluated licensed operator requalification training with Emergency Preparedness requalification requirements in the control room simulator on September 12, 2019.

71111.12 - Maintenance Effectiveness

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

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

(1) Repetitive failures of the auxiliary electric equipment room (AEER) ventilation chiller compressors
(2) Unit 2 and 3 125V DC Power system and Batteries

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Unit 2 and 3 service water pump seal failures

71111.13 - Maintenance Risk Assessments and Emergent Work Control

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

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

(1) Elevated plant risk and fire risk for emergent work on the service water (SW) and Unit 2 control rod drive (CRD) systems July 7 - 10, 2019
(2) Elevated plant risk due to emergent leak on the Unit 2 stator water cooling system on July 25, 2019
(3) Elevated plant risk due to emergent troubleshooting and repair of the Unit 2 channel

'B' fuel pool radiation monitor and the 3A service water pump on August 5, 2019

(4) Unit 2 on-line risk increase to Yellow due to trip of 345 kV Line 1202 and emergent work on Unit 3 to troubleshoot and repair the 3A fuel pool radiation monitor on September 3-5, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (4 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1)3A containment cooling service water (CCSW) keepfill system pressure below minimum limit

(2) Unit 3 125 VDC system level II ground (3)3B electromatic relief valve (ERV) flange torque low
(4) Potential vulnerability identified with torus vacuum breakers

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 and Unit 3 Fuel Pool Cooling pumps trip logic (permanent modifications)
(2) Defeating the Unit 2 'C' Moisture Separator High Level Switches Automatic Turbine Trip function (temporary modification)

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) DOS 1300-05, 2/3 B isolation condenser makeup pump capacity test, after preventive maintenance on August 21, 2019
(2) DFPS 4123-06, 2/3 diesel fire pump capacity test, after replacement on July 24 - 26, 2019
(3) DOS 6600-01, Unit 3 emergency diesel generator surveillance test, after work on the lubricating oil system on September 16, 2019
(4) DIS 1500-06, Unit 3 low pressure coolant injection recirculation loop select logic on September 3, 2019
(5) WO 4962865-13, Electrical Testing of Main Power Transformer 3, after bushing replacement on September 25, 2019

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated D3F52, Unit 3 forced outage to replace a leaking bushing on the Main Power Transformer, from September 23-27, 2019.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) DIS 0260-12, U3 reactor core flow calibrated transmitter calibration on July 24, 2019
(2) DES 8300-58, Unit 2 125V main station battery technical specification surveillance test on September 10, 2019
(3) DOS 6600-08, Unit 3 EDG cooling water pump comprehensive test on September 16, 2019

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Work Order 04936060-01, Unit 2 HPCI Inservice testing surveillance (IST) on September 18, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
  • Evaluation 18-45; Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30; February 7, 2019

This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1)3rd Quarter Emergency Preparedness Full Team Drill on August 20,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 2, July 1, 2018 - June 30, 2019
(2) Unit 3, July 1, 2018 - June 30, 2019

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 2, July 1, 2018 - June 30, 2019
(2) Unit 3, July 1, 2018 - June 30, 2019

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 2, July 1, 2018 - June 30, 2019
(2) Unit 3, July 1, 2018 - June 30, 2019

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 2, July 1, 2018 - June 30, 2019
(2) Unit 3, July 1, 2018 - June 30, 2019

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Complete loss of power to security equipment due to failure of the UPS batteries
(2) Unit 2 turbine trip and reactor scram

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000237/2019-002-00, Unit 2 Scram due to Main Turbine Low Oil Pressure Trip (ADAMS ML19189A087)

The circumstances surrounding this LER are documented in report Section 71152.

A Green finding related to this follow-up inspection is documented in the Results section.

INSPECTION RESULTS

Inadequate Work Instructions for Operationally Critical Work Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events

Green FIN 05000249,05000237/2019003-01 Open/Closed

[H.2] - Field Presence 71152 A self-revealed finding of very low safety significance was identified for the licensees failure to provide adequate work instructions for maintenance activities on multiple occasions in accordance with procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks. Specifically, between December 2018 and May 2019, two instances of inadequate work instructions were identified as being primary causes of improper maintenance performed on OPCC systems that caused operational transients.

Description:

On May 9, 2019, Dresden Unit 2 turbine tripped on low oil pressure which resulted in a reactor SCRAM. The turbine was inspected and found to have severe damage to the spline interface between the Main Gear Quill Shaft and the High Pressure turbine rotor. This led to a loss of power transfer between the main turbine and the Main Shaft Oil Pump (MSOP)which supplies bearing header pressure at rated speed, thus causing the low oil trip. The licensee performed a root cause analysis subsequent to this event and identified that the cause of the spline damage was due to oil starvation because of an improperly fabricated gasket that blocked oil lubrication feeding the Quill Shaft. The root cause was determined to be improper work order instructions that lacked detail needed to prevent human error during installation of the Quill Shaft Oil Nozzle. The work order instructions contained one step for the installation of the oil spray nozzle, which simply instructed workers to install the oil spray nozzleand verify the nozzle is centered. The actual work needed to complete this step involved identifying the proper gasket and fabricating it appropriately to fit the oil block, verifying proper oil flow after installation, and aligning the nozzle to ensure the oil lubrication traveled to all the correct components. Also, it was identified that a post-maintenance test (PMT) was never completed for the work (all work collectively) on the turbine front standard which could have included verifying proper lubrication of components. The contributing cause was determined to be inadequate supervision which failed to catch the missing work step details and provide intrusive observations during the work activity.

Exelon procedure, MA-AA-716-010, Maintenance Planning, Revisions 21-26, section 4.10 describes the level of detail required for work instructions. Level 1 work packages are for complex, infrequently performed work that presents high risk of single failure or errors that could cause a unit/generator trip or transient. These packages should contain minimal reliance on skill of the craft, must clearly provide acceptance criteria, such as clearances and torque values, and shall have technical human performance standards incorporated to prevent human performance errors, which include having steps to verify new parts satisfy fit, form, and functions and assuring appropriate detail to install components is provided. This procedure also provides the definition of a Critical Activity, which is an activity where the quality of the work cannot be fully assured through a PMT or the PMT can only be performed in a condition where the correction of any failure would cause a down power, dose impact, or impact outage critical path. Procedure MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks, Revisions 0-5, provide the definition of OPCCs and the categories of work for OPCC tasks. An Operational Critical Component (OPCC) is a critical component whose failure alone has or could have directly led to a significant (>20%) plant power transient. Operational Critical Component Work Requirement Standards are additional work controls administered through verification, oversight, technical review, or additional or more restrictive tolerances, that are incorporated into the work instructions for an OPCC that reduce the risk of introducing latent issues or operational failures because of improperly performed work.

For the turbine front standard work, as described above, the one large step of installing the oil spray nozzle did not meet the requirements of MA-AA-716-010 for a Level 1 package. Clear acceptance criteria were not provided, technical human performance standards were not adequately incorporated, and Critical Activities throughout the work package were not identified since no PMTs were required to validate the system configuration after maintenance. Also, the planning standards for OPCC work were not put into the work package, such as having additional verification, technical oversight, and supervisory oversight.

An additional example of a lack of adherence to proper work planning practices was identified that was similar in nature to the turbine front standard work. The inspectors determined that these items together (along with other equipment issues that did not have operational consequences) were indicative of programmatic issues with the licensee failing to follow the Maintenance Planning and Planning of OPCC Tasks procedures. The additional example is described below.

On December 20, 2018, it was identified that a leak on the Unit 3 electro-hydraulic control (EHC) skid had degraded significantly to a steady stream of approximately 10 gallons per day (from 2 gallons per day). At this time, the decision was made to emergently down power the unit to affect repairs to a leaking fitting on the suction line that leads to the accumulators on the EHC skid. An equipment cause evaluation was performed and determined that one of the causes of the event was maintenance leadership missed an opportunity for proper work order instruction challenge and oversight to support execution. During the prior refueling outage (October 2018), the EHC system had maintenance performed on it by supplemental employees which included replacing this fitting. The work package for this work was not considered a Level 1 work package and the EHC system was not flagged as an operationally critical system or component. However, further investigation revealed that the EHC system was, in fact, classified as an OPCC back in 2009 but the information for the system was not updated appropriately to account for this. Due to those facts, the package did not receive extensive reviews or challenges during the work planning process. Another cause identified for the leak was that the wrong material was selected for the fitting due to a lack of procedural guidance. There was operating experience available for proper material selection that was not incorporated into the work planning process. If the work package had been categorized differently, the more robust work planning standards of ensuring proper parts that satisfy form, fit, and function and work packages that contain minimal reliance on skill of the craft, would have been included in the work planning process. Also, additional supervisor oversight and reviews would have been required prior to and during the work.

Corrective Actions: For the turbine trip root cause, the licensee implemented corrective actions to prevent recurrence (CAPRs) which included updating the model work orders for maintenance on turbine front standards to ensure all steps had proper level of detail for work execution with minimal reliance on skill of the craft and added PMT steps for verifying proper oil flow for the front standard components. Another corrective action for this issue included developing a Key Steps process where all OPCC work orders, as a minimum, will have steps identified that require supervisor sign-offs and oversight, because of the execution significant or risk significant nature of the step.

For the EHC leak issue, the licensee implemented a Supplemental Worker Oversight Plan to improve work order challenges and increase the level of oversight at the time of work execution. Another corrective action for this issue included developing procedural guidance, including material selection and appropriate tightening methods, for flared fittings used in the EHC system.

Corrective Action References: ARs 4204937 and 4247636

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to follow procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks, was a performance deficiency. Specifically, on two separate occasions, equipment failures on OPCC systems occurred that caused operational transients (either needed emergent down powers for repair or caused a plant trip). The causes of the equipment failures were determined to be inadequate work instructions. The aforementioned procedures delineate the requirements for the level of detail needed in Level 1 work packages and also needed for OPCC work activities.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, on two separate occasions, equipment failures on OPCC systems, caused by inadequate work instructions, occurred that caused operational transients (either needed emergent down powers for repair or caused a plant trip).

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance (Green) because even though one of the events caused a reactor trip, mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition was not lost.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, for the events related to this finding, it was identified that management oversight of the work planning and execution processes was lacking and contributed to the events that occurred. It was determined that oversight of supplemental workers was lacking as a whole, including reviewing work packages and performing supervision of field activities. The licensee generated corrective actions from these events, as well as others, to address the intrusiveness, standards, and expectations of supervisors going forward and clearly defining their roles and responsibilities in the work planning process.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: Loss of Power to all Security Equipment due to UPS Battery Failure 71152 On November 4, 2018, power for critical security equipment was being transferred from the security diesel generator back to its normal power supply. As part of this evolution, an uninterruptible power supply (UPS) carries the loads for a certain period of time. It was during this time on the UPS system that a loss of power occurred to all the loads being carried by the UPS. Appropriate compensatory measures were put into place, power was restored after the initial inspection of equipment, and an equipment cause analysis was performed after the event. Two causes were identified during the causal review: 1) the licensee failed to properly monitor the UPS battery conditions which prevented identification of the degraded battery and 2) improper technical rigor was used during the engineering change that replaced the batteries after a similar failure occurred in 2014. The inspectors reviewed the supporting information for these cause determinations and concluded the most likely causes were failure to properly monitor the UPS battery conditions and inappropriate corrective actions taken for previously identified conditions (i.e. battery environment) from the 2014 failure. The licensee also had operating experience available in the 2014 and subsequent time frames to be able to identify that the batteries were not being maintained properly from both environmental conditions and from monitoring and control perspectives.

The licensee agreed with the inspectors that their actions taken from previous events could have mitigated, if not prevented, this failure and are taking appropriate actions to incorporate the lessons learned into their CAP process. The inspectors reviewed the licensee's corrective actions for this event and determined that they were written to address the identified causes properly and were executed in a timely manner in accordance with their safety significance. There was a performance deficiency identified by the inspectors for this event. It will be documented in Inspection Report 2019-0411.

Observation: Review of Root Cause for Unit 2 Turbine Trip 71152 On Thursday, May 9, 2019, Dresden Unit 2 turbine tripped on low oil pressure which resulted in a reactor SCRAM. The turbine was inspected and found to have severe damage to the spline interface between the Main Gear Quill Shaft and the High Pressure turbine rotor. This led to a loss of power transfer between the main turbine and the Main Shaft Oil Pump (MSOP) which supplies bearing header pressure at rated speed, thus causing the low oil trip.

The licensee performed a root cause analysis subsequent to this event to review the turbine inspection information, prior work history for the main turbine, and relevant operating experience. It was identified that the cause of the spline damage was due to oil starvation because of an improperly fabricated gasket that blocked oil lubrication feeding the Quill Shaft.

The root cause was determined to be improper work order instructions that lacked detail needed to prevent human error during installation of the Quill Shaft Oil Nozzle. The contributing cause was determined to be inadequate supervision which failed to catch the missing work step details and provide intrusive observations during the work activity. The inspectors reviewed the work order and the licensees procedures for work and maintenance planning and determined that the root cause was reasonable. The work order instructions contained one step for the installation of the oil spray nozzle, which simply instructed workers to install the oil spray nozzleand verify the nozzle is centered. The actual work needed to complete this step involved identifying the proper gasket and fabricating it appropriately to fit the oil block, verifying proper oil flow after installation, and aligning the nozzle to ensure the oil lubrication travels to all the correct components. Also, it was identified that a post-maintenance test (PMT) was never completed for the work (all work collectively) on the turbine front standard which could have included verifying proper lubrication of components.

The licensee determined that a PMT was not standard practice for this type of work activity..

The licensee implemented corrective actions to prevent recurrence (CAPRs) which included updating the model work orders for maintenance on turbine front standards to ensure all steps had proper level of detail for work execution with minimal reliance on skill of the craft and added PMT steps for verifying proper oil flow for the front standard components. The inspectors concluded that these CAPRs seemed appropriately focused to address the root cause and preclude repetition. The CAPRs were also being implemented in a timely fashion prior to start of the next refueling outage when turbine front standard work will be conducted.

Another corrective action included developing a Key Steps process where all operationally critical (OPCC) work orders, as a minimum, will have steps identified that require supervisor sign-offs and oversight, because of the execution significant or risk significant nature of the step. This action addressed both the root cause and the contributing cause. The inspectors will ensure the effectiveness of this corrective action when reviewing work orders for the next refueling outage to ensure the process is utilized appropriately.

The licensee also performed an extent of cause and extent of condition review for this event.

It was determined that the work order for the turbine front standard work was classified as a Level 1 work package on an OPCC component. Per the licensees work and maintenance planning processes, Level 1 package should include sufficient detail with minimal reliance on skill of the craft and can include Critical Activities to ensure a high level of maintenance work execution. As corrective actions to address this, the licensee reinforced the standards for planning and reviewing Level 1 OPCC work packages and performed a comprehensive review of other work on the turbine and generator systems prior to the next refueling outage to ensure Critical Activities were identified for component work that had the potential to impact the proper operation of the systems once returned to service (i.e. ensuring design features that could block or resist flow were properly fabricated and assembled). The licensee also shared this operating experience with the other sites within the fleet that could be impacted by work on GE turbines done by supplemental workers. The inspectors determined that the licensee appropriately performed the extent of condition and cause assessments, although it was noted that other systems, not just the turbine and generator systems, could be considered Level 1 OPCC activities that could be completed by supplemental workers and should be considered when reviewing work packages for identifying Critical Activities and Key Steps. This was discussed with the licensee and these work packages are currently under review prior to the next refueling outage. The inspectors determined that the corrective actions for the extent of cause and condition seemed reasonable, were being implemented in a timely manner, and were appropriately shared within the fleet as operating experience to address any potential generic implications when conducting this type of maintenance.

This event and cause evaluation was reviewed by the inspectors for a potential performance deficiency. A finding was identified for failure to provide adequate work instructions to perform the work, as described by the identified root cause above. This finding is documented in the results section.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 8, 2019, the inspectors presented the integrated inspection results to Mr. P. Karaba and other members of the licensee staff.
  • On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per IP 71114, Attachment 4 inspection results to Mr. L. Baker, EP Fleet Programs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04Q Corrective Action

Documents

2509721

Water Leaking Out of Capped End of 2/3-4399-41B

06/02/2015

4144225

Isolation Condenser 2-1301-3 Valve Troubleshooting

06/04/2018

231262

Solenoid Buzzing on 2-1301-20 Valve

03/19/2019

277181

OPS Services Crew Clock Reset - Tagout Special

Instructions

09/03/2019

Drawings

M-27

Diagram of Core Spray Piping

AAN

M-28

Diagram of Isolation Condenser Piping

LR

M-51

Diagram of High Pressure Coolant Injection Piping

CV

M-51

High Pressure Coolant Injection System and Instrumentation

Miscellaneous

Tagout: 02-43-

2019043-001

Disassemble & Inspect 2-4399-73, Iso Fill Check Valve

09/03/2019

Procedures

DOP 1300-M1/E1

Unit 2 Isolation Condenser System Checklist

DOP 1400-E1

Unit 2 Core Spray System Electrical Checklist

DOP 1400-M1

Unit 2 Core Spray System

DOP 2300-M1/E1

Unit 2 HPCI System Checklist

DOS 1300-02

Isolation Condenser Valve Operability Check

71111.04S

Corrective Action

Documents

1671923

TBCCW HX SW Inlet Vlv Leaking

06/17/2014

2603789

U2 TBCCW TCV Tube Track Support for Air Lines Not

Secured

2/22/2015

2647884

Degraded Flex Hose for 3A CB Casing Eqz ISO Valves

03/30/2016

29005

MO 2-3903-B Will Not Close From Remote Control Switch

10/17/2016

4059747

TBCCW Piping at 3B Cond Pump in Contact - Needs

Support

10/02/2017

4165056

U3 EHC TBCCW TCV has Corrosion

08/17/2018

4190724

3-3903-A Did Not Operate From the Control Room

11/01/2018

4191332

3A TBCCW HX Tube Side Vent Plugged

11/02/2018

4191334

3B TBCCW HX Vent Line Plugged

11/02/2018

4193329

Packing Leak Noted on 3-3903-B

11/09/2018

216616

Packing Leak on U2 'B' TBCCW HX SW Inlet Valve

2/02/2019

231347

3B TBCCW Heat Exchanger Tube Plugging

03/20/2019

231399

3B TBCCW Heat Exchanger Flange Corrosion

03/20/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

249402

3-3399-451B 3B TBCCW HX Tube Side Drn Vlv Leaking By

05/15/2019

264483

2A TBCCW Pump Seal Leak

07/16/2019

265165

3B RBCCW HC TCV is Full Open and Bouncing

07/18/2019

Engineering

Changes

2648

RBCCW/TBCCW Tube Plugging Evaluation

01/2018

Procedures

DOP 3700-M2/E2

Unit 2 RBCCW System Checklist

DOP 3800-1

Unit 3 Turbine Building Closed Cooling Water System

Checklist

DOP 3800-M1

Unit 2 Turbine Building Closed Cooling Water System

Checklist

71111.05A

Fire Plans

FZ N/A

Administration Building, 1st Floor

Procedures

OP-AA-201-003

Fire Drill Performance

71111.05Q Corrective Action

Documents

277837

Work Not Performed Due to Leaky Isolation

09/09/2019

Drawings

M-23

Diagram of Fire Protection Piping

AJ

Fire Plans

FZ 1.1.2.3

Unit 2 Reactor Building General Area, Elevation 545

FZ 8.2.1B

Unit 3 Condensate Pumps Floor, Elevation 469

FZ 8.2.2B

Unit 3 CCSW Pumps Floor, Elevation 495

FZ 8.2.5.C

Unit 2/3 EHC Reservoir Area Elevation 517'

FZ 8.2.5.C

Unit 2/3 Cond. Demin. Area Elevation 517'

FZ 8.2.6.C

Unit 2/3 Lube Oil Reservoir Area Elev. 534'

FZ 8.2.6.C

Unit 2/3 Heat Exchanger Area Elevation 534'

FZ 8.2.6A

Unit 2 Reactor Feed Pump Ventilation and Hydrogen Seal

Oil Area, Elevation 538

Miscellaneous

Tagout: 00-41-

2019041-005

2/3 Cable Tunnel Fire Protection Strainer Inspection and

Misc. Work

09/09/2019

Procedures

OP-AA-201-007

Fire Protection System Impairment Control

OP-AA-201-009

Control of Transient Combustible Material

71111.07A

Corrective Action

Documents

268275

FME in 2A SDC HX 2-1003-A

07/31/2019

274841

FM Retrieved From 2C SDC Heat Exchanger

08/27/2019

282295

Results of SPC 4268275-04

07/31/2019

Miscellaneous

Eddy Current Examination Final Report for 2A Shutdown

Cooling Heat Exchanger

July 2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

DTP 75

Heat Exchanger Inspection Program

ER-AA-310-1002

Service Water Heat Exchanger Inspection Guide

Work Orders

00847755

Eddy Current Test on 2A SDC HX

08/20/2011

01477606

Eddy Current Test 2A SDC HX

07/30/2019

71111.11Q Corrective Action

Documents

281544

Steam Leak From 3B1 FW Heater Upstream of 3-3607A

09/23/2019

281563

Unexpected Alarm 903-3 F-1, Area Rad Monitor Downscale

09/23/2019

281573

U3 CRD H-06 Failure to Settle During Downpower

09/23/2019

Miscellaneous

LORT Simulator Guide with DEP Opportunity 19-01A

08/29/2019

Procedures

DGP 01-01

Unit Startup

197

71111.12

Corrective Action

Documents

4082328

AEER Thermostat Not Controlling Proper AEER Temp

2/08/2017

4140956

U1 125 VDC Battery Terminal Corrosion

05/24/2018

4166399

U2/3 BOP 250 VDC Batt Sys Trouble

08/22/2018

4172858

U2 250VDC Charger DC Voltmeter

09/13/2018

4175775

U1 125 VDC Battery Discrepancy Found During Quarterly

Surveillance

09/22/2018

4183312

250 V Voltmeter at 903-8 Requires Calibration

10/13/2018

4183443

Compressor Trip Leads to DOA Entry (DOA 5750-01)

10/14/2018

4184691

AEER Condensing Unit Trip

10/17/2018

4186708

Aux Electric Equipment Room A/C Unit Keeps Tripping

10/23/2018

4187463

U3 250 VDC Battery Surveillance Descrepancies

10/25/2018

4189223

'B' AEER Compressor Not Running

10/30/2018

4193837

U2 250 VDC Batt Ground With U3 HPCI AOP Running

11/11/2018

4196472

U3 Alt Batt Elevated Intercell Resistance Reading

11/20/2018

4197461

U3 250VDC Cell 110 Voltage Low

11/25/2018

4197708

ETB Vent Performance Challenging U2 TS Battery

Temperatures

11/26/2018

4199704

TR-86 System Battery Has a Degraded Intercell Plate

2/03/2018

202901

MRule Function 5714-1 Needs (a)(1) Determination

2/13/2018

203895

TR-86 Relay House Battery Issues

2/17/2008

204924

Corrosion on U1 Batteries

2/20/2018

204986

U1 125 VDC Has 1 Cell With Voltage Low

2/20/2018

205733

'B' AEER Compressor Found Tripped

2/25/2018

206067

AEER HVAC B Compressor Needs Eval Due To Trip On

05/27/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Low Oil

207078

U2 125 VDC Battery Ground - Unexpected Alarm

2/31/2018

207290

U3 250V Battery System Cable Insulation Cracked

01/01/2019

207616

Battery Cell Specific Gravities Found High

01/02/2019

209140

U3 125 VDC Ground

01/08/2019

209145

U3 24/28V A Negative Cell 4 Low Volts

01/08/2019

209605

Entered DOA 5750-01 for AEER Ventilation Failure

01/10/2019

212946

U2 125 VDC Battery Ground

01/22/2019

22849

Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground

2/23/2019

24966

Unexpected Alarm: U2 125 VDC Ground

2/28/2019

25117

U2 125 VDC Ground Alarm, 902-8 C-9

03/01/2019

25524

Unexpected Alarm: Unit 2 125 VDC Ground Alarm

03/01/2019

26960

Unexpected Alarm 9902-8 C-9, U2 125 VDC Batt Ground

03/06/2019

234155

Unknown Substance Found Floating in Cell of Battery

03/29/2019

234682

U1 B 125VDC Charger

03/30/2019

236853

P-105B 1B Battery Charger Could Not Maintain Correct

Voltage

04/05/2019

247556

DOA 5750-01 Entry for AEER Temp Hi

05/08/2019

250039

Corrosion Found on U1 125VDC Batteries

05/18/2019

252768

U3 125VDC Discharge Rate High Alarm

05/30/2019

254008

Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground

06/03/2019

255478

U3 125 VDC Batt Ground

06/08/2019

259821

Corrosion Identified During Battery Surveillance

06/27/2019

262209

U3 125 VDC Battery Ground

07/06/2019

262260

2/3 Service Water Pump Packing Degraded

07/06/2019

262914

Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground

07/09/2019

264658

U1 125 VDC Battery Terminal Corrosion

07/17/2019

266014

U2 125 VDC Ground Alarm

07/22/2019

267550

Unexpected Alarm: U3 125 VDC Batt Ground

07/28/2019

268532

2A LPCI Room Cooler Inspection and Testing

07/31/2019

272610

2B Service Water Pump Mechanical Seal Leakage

Excessive

08/16/2019

273689

Quality Issue from EagleBurgmann Repair Facility

08/22/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Drawings

DR-PSA-005.16

Figure 2-6, ECCS Room Cooling Water/Diesel Generator

Cooling Water

Miscellaneous

Maintenance Rule System Basis Document for Dresden

Unit 2, 39-1; Unit 0, 39-2; Unit 3, 39-2

08/12/2019

Maintenance Rule System Basis Document for Dresden

Unit 3, OOS-39-3

08/12/2019

Maintenance Rule System Basis Document for Dresden

Unit 2, 15-8

08/13/2019

Maintenance Rule System Basis Document for Dresden

Unit 2, Systems 83-1, 83-2, and 83-3

07/31/2019

U0 Auxiliary Electric Equipment Room HVAC Maintenance

Rule a(1) Action Plan

Maintenance Rule System Basis Document for Dresden

Unit 3, Systems 83-1, 83-2, and 83-3

07/31/2019

DCR EC 618991

Design Consideration Summary: Service Water Pump

Mechanical Seal VTIP D1171 Revision

000

DCR EC 628838

Design Considerations Summary: Addition of Eagle

Bergman Seals to the VTIP D1171 for Usage on Service

Water Pumps

000

DCS EC 401788

Install 2/3 Service Water Pump Open Line Shaft Design with

Greene Tweed

000

Eagle Burgmann

Mechanical Seal

(M.S.)

Manufacturer Operating Manual

7.0

Flowserve

Durametallic PSS

III, Split Seal

Installation Instructions from Manufacturer

Procedures

ER-AA-320

Maintenance Rule Implementation Per NEI 18-10

ER-AA-320

Maintenance Rule Implementation per NEI 18-10

ER-AA-320-1001

Maintenance Rule 18-10 - Scoping

ER-AA-320-1003

Maintenance Rule 18-10 - Failure Definition

ER-AA-320-1004

Maintenance Rule 18-10 - Performance Monitoring and

Dispositioning Between (a)(1) and (a)(2)

ER-AA-320-1004

Maintenance Rule 18-10 - Performance Monitoring and

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Dispositioning Between (a)(1) and (a)(2)

ER-AA-320-1006

Maintenance Rule 18-10 - Expert Panel Roles and

Responsibilities

OP-AA-108-112

Plant Status and Configuration

OP-AA-108-112-

1001

Response to Identified Component Mispositionings

71111.13

Corrective Action

Documents

246346

3-1705-16B Spiked Causing RBV Trip and SBGT Auto-Start

05/04/2019

255645

Water Leak Between 2A Stator Pump and Head Tank

06/10/2019

261968

3A SW Pump Packing Leak

07/05/2019

262149

2B Service Water Pump Mechanical Seal Leakage

Excessive

07/05/2019

262637

2A CRD Pump Inboard Seal Leak

07/08/2019

262824

Water Inside 2A CRD Feed Pump Breaker Cubicle

07/09/2019

263043

2/3 SW Pump Breaker Closing Springs Did Not Discharge

on R/O

07/10/2019

263049

Breaker does not Indicate Disconnected when Disconnected

07/10/2019

263271

2/3 Service Water Pump Overcurrent Relay

07/11/2019

263438

3B Service Water Pump Seal Leak

07/11/2019

266695

U2 SWC Leak Upstream of 2-7400-Y-85 and 2-7400-Y-87

07/24/2019

267145

Extent of Condition for U2 SWC Leak. PI 2-7400-YGA9

07/26/2019

267145

Extent of Condition for U2 SWC Leak. Remove PI 2-7400-

YGA9

07/26/2019

267147

Extent of Condition for U2 SWC Leak. Remove PI 3-7400-

YGA8

07/26/2019

267158

Extent of Condition for U2 SWC Leak. Remove PI 3-7400-

YGA9

07/26/2019

267161

Extent of Condition for U2 SWC Leak. PI 2-7400-YGA8

07/26/2019

268629

Excessive Packing Leakage on 3A SWP

08/01/2019

269595

Unexpected Alarm - U2 Fuel Pool CH B Rad Hi

08/05/2019

269658

Corp Eng Evaluate Fleet Fuel Pool Rad Monitor Trip Logic

08/05/2019

269675

2(3)-3 E-16, RX Building Fuel Pool CH B Rad Hi DAN

Enhancement

08/05/2019

276469

Unexpected Alarm - U3 Fuel Pool CH A Rad Hi

09/03/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

276578

RB Vent Stack System Flow Rate Monitor INOP

09/03/2019

276626

Unexpected Alarm 903-3 C-16, RX Bldg Fuel Pool Ch A Rad

Hi

09/03/2019

277614

L1202 Trip Post-Job Critique

09/03/2019

Drawings

Schematic Diagram 345KV Switchyard Annunciator Panel 23-2

Y

M-22A

P&ID Stator Cooling System

I

Miscellaneous

Protected Equipment Lists for Unit 2 and Unit 3 Risk

Significant Systems

Procedures

DAN 902(3)-7 B-

Stator Clg PP Trip

DAN 903-3 C-16

RX Bldg Fuel Pool Ch A Rad Hi

DAN 923-2 A-2

GCB 3-4 Trip

DAN 923-2 A-3

GCB 4-5 Trip

DAN 923-2, A-5

Line 1202 Transfer Trip

DOA 7400-01

Failure of the Stator Coolant System

OP-AA-108-117

Protected Equipment Program

OP-DR-201-012-

1001

Dresden On-line Fire Risk Management

WC-DR-104-1001 Dresden 345KV Switchyard Configuration Risk Assessment

Work Orders

04946790

Excessive Packing Leakage on 3A SWP

08/05/2019

04947812

Troubleshoot and Repair U2 Fuel Pool CH B Radiation High

Alarm

08/05/2019

04956357

Unexpected Alarm - U3 Fuel Pool CH A Rad Hi

09/03/2019

71111.15

Corrective Action

Documents

209140

U3 125 VDC Ground

01/08/2019

212946

U2 125 VDC Battery Ground

01/22/2019

217329

Unexpected Alarm, U3 125 VDC Ground, Annunciator 903-8

C-9

2/05/2019

218106

903-8 C-9 U3 125 VDC Battery Ground During DES 0700-03

2/07/2019

24966

Unexpected Alarm: U2 125 VDC Ground

2/28/2019

25117

U2 125 VDC Ground Alarm, 902-8 C-9

03/01/2019

25524

Unexpected Alarm: Unit 2 125 VDC Ground Alarm

03/01/2019

25524

Unexpected Alarm: Unit 2 125 VDC Ground Alarm

03/01/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

26960

Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground

03/06/2019

29076

Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground

03/13/2019

249714

Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground

05/16/2019

252768

U3 125 VDC Discharge Rate High Alarm

05/30/2019

254008

Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground

06/03/2019

256427

Low Pressure at Valve 3-151-77A (PI 3-1501-61A) CCSW to

HX

06/12/2019

261991

Follow-up Investigation on IR 4256427

06/12/2019

262209

U3 125 VDC Battery Ground

07/06/2019

263744

EP Exercise Identifies Unanalyzed Condition

07/12/2019

267550

Unexpected Alarm: U3 125 VDC Batt Ground

07/28/2019

270286

Pressure Gauge Out of Tolerance During Power Labs

Calibration

08/07/2019

270818

Unexpected Alarm 902-8 C-9 U2 125 VDC Battery Ground

08/09/2019

Engineering

Changes

345321

Evaluate the Impact of Additional Weight due to Replacing

Hex Nuts with Hydraulic Nuts and Perform the Owner

Acceptance Review of the Vendor Report

Operability

Evaluations

00064004345

Containment Cooling Service Water (CCSW) System Water

Hammer/Loss of Keep-Fill Analysis

03/21/2001

Procedures

DAN 902(3)-8 C-

U2/3 125 VDC Battery Ground

DOP 6900-07

25 VDC Ground Detection - Unit 3

71111.18

Corrective Action

Documents

273402

3B FPC Pump Trip During Train Swap

08/21/2019

283066

Unexpected Alarm 902-7 B-5 DEHC and 902-6 A-3 Level

High

09/28/2019

Drawings

2E-3548

Schematic Diagram Fuel Pool Cooling Pump Alarm Circuit

and Indication

S

M-362

Diagram of Fuel Pool Cooling Piping

BG

M-373

Diagram of Fuel Pool Filter & Demineralizing Piping

AG

Engineering

Changes

27310

Modify U3 A&B Fuel Pool Cooling Pump Trips

27311

Modify U2 A&B Fuel Pool Cooling Pump Trips

29532

Defeat the Automatic Turbine Trip From the 2C Moisture

Separator High Level

000

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

CC-AA-112

Temporary Configuration Changes

DAN 902(3)-5 B-8 Moisture Separator Lvl Hi-Hi

DAN 902(3)-7 B-5 Turbine Control Minor Trouble

DAN 9902(3)-6 A-

Unit 3 Moist Separator Lvl Hi

and 07

Work Orders

04889934

Modify U2B Fuel Pool Cooling Pump Trips

08/26/2019

04889935

Modify U3A Fuel Pool Cooling Pump Trips

08/21/2019

04889936

Modify U3B Fuel Pool Cooling Pump Trips EC 627310

08/20/2019

04964530

Defeat the Automatic Turbine Trip From the 2C Moisture

Separator High Level Switches

09/28/2019

71111.19

Corrective Action

Documents

250799

U3 EDG Lube Oil Gallery Sightglass

05/21/2019

257556

U3 EDG Lower Lube Sightglass Still Empty 2 Shifts After

06/17/2019

267142

Incorrect Gaskets Installed on 2/3 DFP Oil Cooler

06/26/2019

268385

4.0 Critique - 2/3 DFP Capacity Run

07/27/2019

272885

2/3B Iso Cond M/U Pump Failed to Start Initially

08/19/2019

273328

Crack on Valve Cover

08/19/2019

273472

Increased Fuel Leakage Past 2/3B IC MU PP Inj Vent Valve

08/21/2019

273517

Overfilling of 2/3B ISO Condenser Coolant

08/21/2019

273842

Fuel Leak from Casing Vent on B ISCO Cond. Diesel Engine

08/21/2019

276621

dPIS 3-0261-34A Found OOT

09/04/2019

279832

U3 EDG Exhaust Manifold Cylinder #8 Temp High

09/16/2019

279835

U3 EDG Exhaust Manifold Cylinder #17 Temp Low

09/16/2019

280590

4.0 Critique on U3 EDG Work

09/19/2019

285704

Documentation of SFRA Testing of H3 Winding

09/26/2019

Drawings

203LN001-001

Low Pressure Coolant Injection System and Instrumentation

203LN001-002

LPCI Initiation Logic

203LN001-003

LPCI LOOP Select Logic

20700LN001-001

Unit 2 Isolation Condenser System

20700LN001-011

Isolation Condenser Makeup Pump System

233LN001-001

Fuel Pool Cooling System

233LN006-001

Primary Containment Atmosphere Monitoring

M-478

Diagram of Diesel Generator Lube Oil Piping

Procedures

DIS 1500-06

LPCI System Recirculation Loop Break Detection

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DOS 1300-05

2/3 A(B) Isolation Condenser Makeup Pump Capacity Test

MA-MW-773-035

Nuclear Operational Analysis Department Testing of Power

Transformers

Work Orders

01032433-01

D3 10Y PM Recirc Loop Brk LPCI Injection DPIS 34A

Replacement

09/04/2019

01930470

D2/3 2Y Com 'B' Iso Cond Make-up Pump Capacity Test

08/21/2019

04811173

PMT Replaced Pump

07/27/2019

04915930-01

Diesel Generator Fast Start Operability Surv.

09/17/2019

04924706

D2/3 Qtr Com 'B' Iso Con Make-up Pump Operability

08/21/2019

04933408-03

Replace U3 D/G Lube Oil Cooler Outlet Check Valve

09/17/2019

04933409-02

WR to install Ultrasonic Flowmeter U2 EDG Pre-Lube Oil

Line

09/16/2019

04962865-13

Elec Testing of Main Power Transformer 3

09/25/2019

71111.20

Corrective Action

Documents

281463

MPT 3 Oil Leak Identified

09/23/2019

281514

U2 and U3 Main Generator Output Spikes

09/23/2019

281858

D3F52 LL - Storage Requirements for MPT Transformer

Bushings

09/24/2019

282111

U3 MPT TR 3 Neutral H0 Bushing as Found

09/25/2019

282233

U3 Main Turbine Turning Gear Will Not Engage

09/25/2019

282235

U3 Turbine Bearing Lift Pump Trip Alarm

09/25/2019

282614

903-7 B-5 Turbine Control Minor Trouble

09/26/2019

282910

U3 Main Turbine Bearing #1 Thermocouple 3-5600-T1

Degraded

09/27/2019

283118

3B RFP Discharge Valve Failed to Open During Pump Start

09/28/2019

283235

Unexpected Alarm 903-3 A-2, MN Steam Line Rad Hi

09/28/2019

283285

Furmanite Box Leaking in U3 RFP Room

09/29/2019

Engineering

Changes

443003

Fabricate Expansion Plate for Dresden U3 MPT

Miscellaneous

OP-AA-10-117

Protected Equipment List for Unit 3 TR32

09/24/2019

Work Orders

04938495

Replace VSVA Card 3-5650-31-5-S1-10

09/25/2019

04962865

Repair/Replace U3 MPT High Side Neutral Bushing

09/25/2019

71111.22

Corrective Action

Documents

4175530

SJAE Anomalies Noted during HPCI Surveillance on Unit 2

09/20/2018

4177295

Unit 2 HPCI Oil

09/26/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

4179417

U3 HPCI Surveillance 4.0 Critique

09/12/2018

278206

U2 1125VDC Ground Alarm

09/10/2019

281159

Crew 4 Clock Reset - U2 HPCI IST Run 4.0 Critique

09/18/2019

Procedures

DES 8300-58

Unit 2 125 Volt Main Battery Modified Performance Test

DIS 0260-12

Reactor Core Flow Calibrated Transmitter Calibration

DOS 6600-08

Diesel Generator Cooling Water Pump Quarterly and

Comprehensive/Preservice Test for Operational Readiness

and In-Service Test (IST) Program

Work Orders

04678506-01

D3 24M TS RX Core Flow Calibrated Transmitter CAL

07/24/2019

04706728

D3 2Yr Diesel Generator Cooling Water Pump

Comprehensive Test for IST Program

09/16/2019

04936060-01

D2 Qtr TS HPCI Pump Oper Test and IST Surv

09/18/2019

71114.04

Miscellaneous

Evaluation

Number 18-45

Exelon Nuclear Standardized Radiological Emergency Plan,

Revision 30

2/14/2019

71114.06

Corrective Action

Documents

273314

3rd Quarter 2019 Drill Issue

08/20/2019

283661

3Q19 EP Drill Unsatisfactory Demonstration Criteria

09/30/2019

Miscellaneous

3rd Quarter 2019 Emergency Preparedness Full Drill Manual

71151

Miscellaneous

Unit 2 and Unit 3 MSPI Validation Packages for HPCI, ISO,

LPCI, Emergency AC Power, EDG and SDC

July 1, 2018

- June 30,

2019

NEI 99-02

Regulatory Assessment PI Guidance

71152

Corrective Action

Documents

204937

EHC Leakage Has Degraded Further

2/20/2018

247636

Blocked Quill Oil Passage Causes Turbine Trip and RX

Scram

05/09/2019

249933

Adverse Trend in Equipment Performance Since D3R25

05/17/2019

270769

Trend in Maintenance Work Planning Deficiencies

08/09/2019

Procedures

ER-AA-200-1001

Equipment Classification

ER-AA-2004

System Vulnerability Review Process

and 10

MA-AA-716-010

Maintenance Planning

and 26

MA-AA-716-010-

1015

Operational Critical Component Work (OPCCW) Process

0, 5, and 6

Work Orders

01081964

Turbine Front Standard Mechanical Inspect/Maint

11/11/2013

01799328

Stem/Insp Overhaul Intern Overhaul ACT for FW Reg B

11/01/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

04606118

3B EHC Discharge Pipe Leaking at Tee to Accumulator

Rack

10/29/2018