IR 05000237/2020010
| ML20059N844 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/28/2020 |
| From: | Hill D NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| EPID I-2020-010-0020 IR 2020010 | |
| Download: ML20059N844 (14) | |
Text
February 28, 2020
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000237/2020010 AND 05000249/2020010
Dear Mr. Hanson:
On January 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Dresden Nuclear Power Station, Units 2 and 3.
On January 31, 2020 the NRC inspectors discussed the results of this inspection with Mr. P. Karaba, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
David E. Hills, Chief Branch 1 Division of Reactor Projects
Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000237 and 05000249
License Numbers:
Report Numbers:
05000237/2020010 and 05000249/2020010
Enterprise Identifier: I-2020-010-0020
Licensee:
Exelon Generation Company, LLC
Facility:
Dresden Nuclear Power Station, Units 2 and 3
Location:
Morris, Illinois
Inspection Dates:
January 13, 2020 to January 30, 2020
Inspectors:
J. Gilliam, Reactor Inspector
J. Park, Reactor Inspector
J. Rutkowski, Project Engineer
Approved By:
David E. Hills, Chief
Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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
No findings or violations of more than minor significance were identified.
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Radiation Monitoring System.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment of the Corrective Action Program
Based on the activities that were selected for review, the inspection team concluded that implementation of the problem and identification process (the corrective action program) was adequate to appropriately protect the health and safety of the public and the environment.
The plant staff had a low threshold for identifying problems and entering them, in a timely manner, in the condition report/action request (AR) system. Items once entered into the corrective action program (CAP) were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that licensee reviewed Operating Experience (OE) for applicability to station activities. Audits and self-assessments seemed to be performed at an appropriate level to identify deficiencies. In interviews conducted during the inspection, most workers at the site expressed freedom to bring up nuclear safety concerns and were encouraged to enter items in the CAP system.
Effectiveness of Problem Identification
The inspection team found that issues were being identified and captured in the Condition Reporting (CR) system or the work order system. Station personnel write about 800 to 1100 ARs per month with most not being of high safety significance. Many of the ARs are written to initiate a work request/order. Usually, from data provided by the licensee, only 1-3 ARs per month merit a causal evaluation per the CAP requirements. Interviews conducted by the inspection team indicated that personnel knew the licensee procedural requirement and expectation to write ARs for issues and plant personnel usually did write ARs. Several interviewed personnel said they regularly passed issues on to supervision and supervision wrote the ARs. Several personnel also said that they felt the CAP was ineffective for less than large or nuclear safety issues. The inspectors did not identify any specific issues where it was clear that people should have written ARs and did not.
The team noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the CAP. The team found that the licensee utilized several CAP support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. The licensee performed adequate department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the CAP when they were applicable to the station.
The team determined that the licensee was generally effective at trending low level issues and taking appropriate corrective actions to prevent more significant issues from developing.
Trends for open ARs and work orders appeared reasonable. The licensee used the CAP to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of the issues related to Radiation Monitoring System (RMS). As part of this review, the team interviewed the system engineer, reviewed action requests, plant health reports, and condition evaluations. In addition, the RMS was recently moved to maintenance rule (a)(1) status. The team concluded that RMS concerns were identified and entered into the CAP at a low threshold and concerns were being resolved through appropriate corrective actions and action plans in a manner commensurate with their safety significance.
Effectiveness of Prioritization and Evaluation of Issues
Based on the samples reviewed, the team determined that licensee performance was adequate. The Management Review Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. The team observed a healthy dialogue between the members of this committee when dispositioning condition reports. The evaluations were generally completed in a timely manner.
Effectiveness of Corrective Actions
Based on the samples reviewed, the team determined that the licensee was adequately implementing corrective actions (CAs) with some licensee-identified opportunities for improvement in corrective action implementation. In general, CAs for deficiencies that were safety significant were implemented in an adequate and timely manner. The team sampled CA assignments developed for selected NRC documented violations, selected licensee event reports, some license self-assessments, and some licensee-identified issues. Where either enough time had elapsed, and/or the licensee had performed effectiveness reviews, the team also looked at the effectiveness of the corrective actions (i.e. was there a recurrence of the issues). While the team did not identify issues on the effectiveness of corrective actions, the team was aware that the licensee had identified some issues with the effectiveness of corrective actions. The licensee's Nuclear Safety Culture Monitoring Panel, in their second trimester report of 2019, determined, based upon the inputs, that Management Systems is rated as IMPROVEMENT OPPORTUNITY due to multiple examples of management failing to drive resolution to plant issues resulting in multiple repeat issues at Dresden Station.
Assessment 71152B Use of Operating Experience (OE)
Based on the samples reviewed, the team determined that licensee performance in the use of OE was adequate. The licensee screened industry and NRC OE information for station applicability. Based on these initial screenings, the licensee initiated actions in the CAP to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented in a timely manner to prevent similar issues from occurring. Operating Experience lessons-learned were communicated and incorporated into plant operations.
The licensee maintains control of the OE review activity under the station operating experience process governed by the PI-AA-115 series procedures and manuals. The review of OE items that are transmitted by regulatory, technical or other industry entities are initiated and screened first by the Fleet OE Coordinator before they get disseminated to the site for detailed review and processing. The 10 CFR Part 21 review activity is initiated and screened initially by the corporate organization. Where an issue is deemed applicable or requires further review to determine applicability at a site, then the station receives review assignments. The licensee categorizes the above OE items as OPEX Evaluation Level 3, and its review is conducted in accordance with governing procedures.
Assessment 71152B Self-Assessments and Audits
The licensee listed 61 self-assessments and eight Nuclear Oversight audits completed over a period of approximately 2 years. The inspectors reviewed several of those completed documents and deemed the assessments for the selected areas of review as thorough and intrusive with regards to following up with the issues that were identified through previous NRC inspections and in the self-assessments and fleet oversight audits. Reviewed corrective actions for the identified issues were deemed reasonable and completed commensurate with safety significance. The inspectors regarded licensee performance as adequately self-critical of their own performance and that performance-related issues were being identified through their self-assessment process.
Assessment 71152B Safety Conscious Work Environment (SCWE)
As part of inspection, the inspectors interviewed or talked to approximately 30 people in small focus groups and in one-on-one or small group short discussions. The major area of focus was to ascertain if employees were free to bring up issues without fear of retaliation. An additional area of focus was to understand employee's perception of the effectiveness of CAP and the Employee Concerns Program. Several people stated that while the CAP worked for important items, they believed it did not work well for lesser items or sometimes for items that were important to them. All interviewed personnel, when specifically asked the question, stated that they would discuss and have discussed issues with their supervisors and would bring up all nuclear safety issues.
Employee Concerns Program (ECP)
As part of the overall SCWE inspection effort, the inspectors reviewed the 2018 and 2019 ECP program logs and five case files. No items of concern were identified. The files reviewed appeared comprehensive. Also, during the interviews, employees generally said that if they could not get issues addressed through their supervisor they might use the ECP.
The inspectors did not identify any issues with the ECP.
Employee Value Survey
In 2019, the licensee changed methods for evaluating safety culture. Previously, the licensee used a stand-alone survey to measure safety culture attributes, but this process was changed to a combined Employee Value Survey (EVS). The EVS had 71 questions and 46 of those questions were evaluated by the licensee for safety culture impacts. The survey did not directly measure employees willingness to report safety issues and the licensee's analysis did not document any particular issue with Dresden's SCWE. The inspectors, in reviewing the EVS results, found that in several station departments, one-third or less of respondents had a favorable view of the licensee's management of change processes. Several other questions associated with communications within the organization received favorability ratings less than fifty percent. The inspectors did not find that the low favorability ratings had a direct adverse impact on employee's willingness to raise safety issues.
Observation: Corrective Action Programs Observations 71152B Corrective Action Programs Observations
The inspectors encountered some difficulty in following and verifying the actual completion of some CAs. When a corrective action was closed to another process, the continuity of the CA's completion path was sometimes hard to follow. The inspectors identified four examples of ARs/Issue Reports addressing industry operating experience which had indeterminate completion status upon initial review of CAP documentation. However, the licensee was able to explain the status of the action and the inspectors did not find any examples where actions were not specifically addressed. This problem for the inspectors had been mentioned previously to the licensee.
Observation: Operability Assessments 71152B The inspectors noted that guidance on considerations for addressing past operability concerns did not exist. Past operability evaluation serves as a means to determine whether a condition had existed that would have made it reportable under the regulations.
Nevertheless, opportunities were available for the issues to be reviewed and screened through various station committees, such as the Station Oversight Committee (SOC), the Management Review Committee (MRC), and the Plant Operations Review Committee (PORC). Among the considerations given during the station review and screening process was the potential for past operability concern. The inspectors noted that some of the considerations and guidelines delineated in OP-AA-108-115-1002 for determining on-shift immediate operability were also applied to the thought process for considering past operability. The inspectors did not identify any examples of the station failing to report a condition deemed required by the regulations due to not considering a potential for past operability. Rather, the inspectors did have an example of an issue where the station performed a past operability evaluation that ultimately identified a reportable condition.
Observation: Maintenance Rule Program Review 71152B The inspectors reviewed the Dresden Maintenance Rule (MR) program and the last 2-year program review. Dresden had as of December 2019 eight systems in MR (a)(1) monitoring status and 3 additional systems in (a)(1) - a total of 11 systems. The inspectors initially considered the number of (a)(1) high but the inspectors, after review of the station's history, deemed the number consistent with Dresden past evaluation periods. The Dresden MR program 2-year required review evaluation appeared comprehensive; the inspectors determined that the licensee was adequately implementing its Maintenance Rule program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 31, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
28751
RX BKDG Vent RAD Monitor Failed Upscale
07/15/2015
4090593
Maintenance Functional Area Audit Report NOSA-DRE-18-
2/21/2018
23889
PMC OPEX: FP Preaction Systems
04/06/2018
29112
Fleet Adverse Trend in Clearance and Tagging
04/19/2018
4130810
U2 MT CV#1 EHC Accumulator Re-Torque per QDC NER
QC-17-014
04/25/2018
4132543
NER NC-16-016-Y PRC-005 Issues Identified
04/30/2018
4134105
Training and Staffing Audit Report NOSA-DRE-18-07
06/20/2018
4152442
GE-H 21.21(B) Power Supply DA343A1281P002 Potential
Derating
07/02/2018
4152606
PMC: OPEX Review Peach Bottom ASD Trip 6/8/2018
07/02/2018
4156632
NRC IN 2018-07 - Pump/Turbine Bearing Oil Sightglass
Problems
07/18/2018
4160095
PMC: 2A ASD Coolant Fittings (OPEX)
07/30/2018
4160102
07/30/2018
4160789
GE AK-50 OPEX IER L3-18-8 Applicable to Dresden / Quad
08/01/2018
4162726
High Vibes on U3 HPCI Room Cooler
08/08/2018
4163042
PMC Analog Portion 2-2202-156A-FM1 Inaccurate
08/09/2018
4173984-61
Event Number 54238; Part 21 Notification - Loose Butterfly
Valve Taper Pins
09/19/2019
4175581
OPEX Review of Clinton NER CL-17-005 Green - NCV
09/21/2018
4182344
2019 NOS Audit Performance and Effectiveness Review
2/18/2019
4182544
NRC RIS 2018-05: Supplier Oversight Issues Identified by
NRC Inspection
10/11/2018
4183698
Effective use of OPEX in Preparing and Reviewing Mods
03/28/2019
4186766
Operations Training Mid-Cycle Self-Assessment with
Simulator Management Compliance
08/13/2019
4187763
Recommend Reassessment of MSIV Design Vulnerability
10/25/2018
4189257
D3R25 LLRT 3-0203-1A Exceeded Tech Spec Limit of < 34
SCFH
10/30/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4191108
MOV 3-1201 As-Left Diag Test Flags Requiring ENG Review
11/01/2018
4198610
Relay did not Respond as Expected
11/29/2018
201134
NER NC-18-025-Yellow: Main Turbine Turning Gear Failure
2/07/2018
209504
Security Programs Audit Report NOSA-DRE-19-02
2/13/2019
211037
TR-22 TRIP on Sudden Pressure
2/22/2019
242417
EOC Loss of Oil Flow Alarm Functional Checks for U3 MPT
TR3
04/22/2019
247636
Blocked Quill Oil Passage Causes Turbine Trip and RX
05/09/2019
247636
Dresden Unit 2 Turbine Trip / Reactor Scram Due to Low
Turbine Oil Pressure
06/27/2019
254685
EOC Inspection of Quill Shaft Spline Interface Lubrication
06/05/2019
255207
NRC IN 2019-03: C&T Shortfalls Cause Significant
Configuration Control Events
06/07/2019
257556
U3 EDG Lower Lube Oil Sightglass Still Empty 2 Shifts After
06/17/2019
258349
NOS ID Sign Contact RP Prior to Entry Not on Scaffolds
06/20/2019
260070
NOS ID: Refuel Floor RP Tech did not Reinforce RP
Standards
06/27/2019
260078
NOS ID: Three Surveys Did Not Indicate the Location
Hotspots
06/26/2019
266698
U2 Stator Water Cooling System Leak
08/30/2019
268532
2A LPCI Room Cooler Inspection and Testing
07/31/2019
269595
Unexpected Alarm-U2 Fuel Pool CH B RAD HI
08/05/2019
273971
U2 HPCI Inlet Drain Pot Downstream Valve Wont Close
08/25/2019
276469
Reactor Monitoring System (a)(1) Determination
10/03/2019
276914
Unexpected Alarm-U3 Fuel Pool CH A RAD HI
09/04/2019
277751-03
Westinghouse A200 and Freedom Series Contactors
09/16/2019
281463-08
Oil leak identified on the High Side Neutral Ground Bushing
of Main Power Transformer 3 (3-6200-T3), Requiring Unit 3
Forced Outage to Repair
11/11/2019
284858
HPCI Room Cooler, Grease Bearings, PM Delayed
10/03/2019
290427
Historical Operability Review for DPIS 3-0261-35C
10/23/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
291993-02
Report No. 10CFR21-0127; Part 21 Notification - Emergency
Diesel Generator, EMD Fuel Injector - Seized Plunger and
10/30/2019
292782
10/30/2019
Corrective Action
Documents
Resulting from
Inspection
4313977
IEMA Observations on Fire Risk Management
01/30/2020
Miscellaneous
2T19 NSCRM
Report
Nuclear Safety Culture Monitoring Panel Report Covering
Period of May 3 to September 18, 2019
10/11/2019
Corrective Action
Program
Evaluation
4139118-05
34.5 kV Switchyard Battery Discharged During Maintenance;
07/12/2018
07/12/2018
Dresden A3 2018
Maintenance Rule Periodic Assessment #12
2/14/2018
ECP Case Files
File 2018-007, 2018-009, 2018-18, DRE 0118, DRE 0080
ECP Case Logs
Case Logs of 2018 and 2019
Operability
Evaluations17-002
NRC Question Concerning TS SR 3.8.1.10 and 3.8.1.11
Procedures
Engineering Technical Evaluations
DES 8300-14
Security UPS, Computer UPS, Lake Lift Station, Unit 1,
HCVS SBO 125VDC, 345KV Switchyard, 138KV Switchyard
and 34.5KV Switchyard Batteries Maintenance
DOP 8300-15
Monitoring Non-Safety Related DC Batteries During
Maintenance Activities
Employee Concerns Program
Employee Concerns Program Process
Maintenance Rule Implementation PER NEI 18-10
Torquing and Tightening of Bolted Connections
MA-DR-771-402
Unit 2 - 4 KV TS Undervoltage and Degraded Voltage Relay
Routines
Operability Determinations (CM-1)
OP-AA-108-115-
1002
Supplemental Consideration for On-Shift Immediate
Operability Determinations (CM-1)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-DR-201-1001
Dresden On-Line Fire Risk Management
Shutdown Safety Management Program
OU-DR-104
Shutdown Safety Management Program
OUO-AA-103-
1001
Shutdown Safety Plan Independent Review
Operating Experience Program
Processing of Level 3 OPEX Evaluations
Corrective Action Program
Self-Assessments 04180592
Condensate Chemistry
2/08/2019
04183698
Effective Use of OPEX in Preparing and Reviewing Mods
04/17/2019
04186758
Dresden M&T Training Comprehensive Self-Assessment
09/23/2019
04189480
Self-Assessment: Configuration Control
10/02/2019
214459
FIN Effectiveness
04/24/2019
257452
Self-Assessment of SA/BM NISP-PI-02 Implementation
NOSA-DRE-19-
Engineering Design Control Audit Report
08/07/2019
NOSA-DRE-19-
Radiation Protection Audit Report
07/10/2019
NOSA-DRE-19-
Operations Functional Area Audit Report
08/16/2019
Work Orders
01964822-01
OP Perform As Found LLRT Dry Test Per DOS 7000-01
10/29/2018
04945085-02
Install New PI2-7400-YGA8/YGA9
11/10/2019
095046273-09
OP Perform As Left LLRT On 203-1A MSIV
11/08/2018