ML030300803
| ML030300803 | |
| Person / Time | |
|---|---|
| Site: | Dresden  (DPR-019, DPR-025) |
| Issue date: | 01/30/2003 |
| From: | Pederson C Division of Reactor Safety III |
| To: | Skolds J Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-02-264 IR-01-021 | |
| Download: ML030300803 (5) | |
See also: IR 05000237/2001021
Text
January 30, 2003
Mr. John L. Skolds, President
Exelon Nuclear
Exelon Generation Company, LLC
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
DRESDEN NUCLEAR POWER STATION
NRC INSPECTION REPORT 50-237/01-21(DRS); 50-249/01-21(DRS);
Dear Mr. Skolds:
On October 16, 2001, the NRC completed an inspection at your Dresden Nuclear Power
Station. While the inspection findings were discussed on October 16, 2001, with Mr. P.
Swafford of your Dresden staff and documented in Inspection Report 50-237/01-21(DRS);
50-249/01-21(DRS), dated November 16, 2001, it was not until December 3, 2002, when
Licensee Event Report (LER) No. 2002-005-00, Unit 3 High Pressure Coolant Injection System
Inoperable Due to Water Hammer Event, was issued, that the significance of the issue could
be fully evaluated. Further discussion occurred on January 27, 2003, following our review of
your operability determination.
The report discusses a finding that appears to have a low to moderate safety significance.
As described in Section 1R15 of the report, the issue pertains to operability of the Unit 3
High Pressure Coolant Injection (HPCI) system with a degraded pipe support between July 5,
2001, and September 30, 2001. The HPCI pipe support was likely damaged when HPCI
automatically activated during a July 5, 2001 scram. A hydrodynamic transient/water hammer
event occurred as a result of a combination of air pockets and steam voids in the piping due to
inadequate venting of the system. The ability of the HPCI system to perform its designed
safety functions was an unresolved item pending further review and determination of operability
while in the damaged state. After your staff determined in the above LER that the Unit 3 HPCI
system was inoperable during the July 5 to September 30, 2001 time period, the finding was
assessed using the applicable significance determination process and was preliminarily
determined to be White, i.e., a finding with some increased importance to safety, which may
require additional NRC inspection. The finding has a low-to-moderate safety significance based
on the Significance Determination Process (SDP) Phase 2 analysis results using the
benchmarked SDP notebook and the Standardized Plant Analysis Risk (SPAR) model.
J. Skolds
-2-
On September 30, 2001, the damaged Unit 3 HPCI pipe support was repaired, and an adjacent
hanger was adjusted to support pipe dead weight loads. By October 3, 2001, venting of the
Unit 2 and Unit 3 HPCI pump discharge piping was completed. Dresden procedures were
revised to vent HPCI intermediate high points and to require the venting of HPCI pump
discharge piping while aligned to the contaminated condensate storage tank.
As discussed with Dresden staff on January 27, 2003, the NRC has concluded that the finding
is an apparent violation of Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B, for
failure to promptly correct conditions adverse to quality and for failure to take corrective action
to preclude repetition in the case of a significant condition adverse to quality. Your staff did not
promptly correct damaged pipe support M-1187D-80 on the Unit 3 HPCI system after it was
identified on July 19, 2001, a significant condition adverse to quality, and your staff did not take
corrective action to preclude repetition until prompted by NRC staff on September 30, 2001.
The finding is also an apparent violation of NRC requirements and is being considered for
escalated enforcement action in accordance with the General Statement of Policy and
Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current
Enforcement Policy is included on the NRCs website at www.nrc.gov/OE.
We believe that sufficient information was considered to make a preliminary significance
determination. However, before we make a final decision on this matter, we are providing you
an opportunity to present to the NRC your perspectives on the facts and assumptions, used by
the NRC to arrive at the finding and its significance, at a Regulatory Conference or through the
submittal to the NRC of your position on the finding in writing. If you choose to request a
Regulatory Conference, it should be held within 30 days of the receipt of this letter and we
encourage you to submit supporting documentation at least one week prior to the conference in
an effort to make the conference more efficient and effective. If a Regulatory Conference is
held, it will be open for public observation. If you decide to submit only a written response, such
submittal should be sent to the NRC within 30 days of the receipt of this letter.
Please contact Mr. David Hills at (630) 829-9733 within 10 business days of the receipt of this
letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will
continue with our significance determination and enforcement decision and you will be advised
by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for this inspection finding at this time. In addition, please be advised that the number
and characterization of apparent violations described above may change as a result of further
NRC review.
Today, we are also issuing correspondence concerning a Predecisional Enforcement
Conference concerning possible incomplete or inaccurate information provided to the NRC staff
on September 27, 2001 about the water hammer event on July 5, 2001 (NRC Office of
Investigations Case No. 3-2001-054).
J. Skolds
-3-
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA by Roy Caniano Acting For/
Cynthia D. Pederson, Director
Division of Reactor Safety
Docket No. 50-249
License No. DPR-25
cc:
Site Vice President - Dresden Nuclear Power Station
Dresden Nuclear Power Station Plant Manager
Regulatory Assurance Manager - Dresden
Chief Operating Officer
Senior Vice President - Nuclear Services
Senior Vice President - Mid-West Regional
Operating Group
Vice President - Mid-West Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing - Mid-West Regional
Operating Group
Manager Licensing - Dresden and Quad Cities
Senior Counsel, Nuclear, Mid-West Regional
Operating Group
Document Control Desk - Licensing
M. Aguilar, Assistant Attorney General
Illinois Department of Nuclear Safety
State Liaison Officer
Chairman, Illinois Commerce Commission
J. Skolds
-3-
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA by Roy Caniano Acting For/
Cynthia D. Pederson, Director
Division of Reactor Safety
Docket No. 50-249
License No. DPR-25
cc:
Site Vice President - Dresden Nuclear Power Station
Dresden Nuclear Power Station Plant Manager
Regulatory Assurance Manager - Dresden
Chief Operating Officer
Senior Vice President - Nuclear Services
Senior Vice President - Mid-West Regional
Operating Group
Vice President - Mid-West Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing - Mid-West Regional
Operating Group
Manager Licensing - Dresden and Quad Cities
Senior Counsel, Nuclear, Mid-West Regional
Operating Group
Document Control Desk - Licensing
M. Aguilar, Assistant Attorney General
Illinois Department of Nuclear Safety
State Liaison Officer
Chairman, Illinois Commerce Commission
DOCUMENT NAME: G:\\DRS\\ML030300803.wpd
To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy
OFFICE
RIII
RIII
RIII
RIII
RIII
NAME
ADunlop for
JNeurauter:sd
DHills
MRing
CWeil for
BClayton
RCaniano for
CPederson
DATE
01/28/03
01/28/03
01/28/03
01/29/03
01/30/03
OFFICIAL RECORD COPY
J. Skolds
-4-
ADAMS Distribution:
SECY
WDT
WFK
FJC
JLD, OE
JED2
SJC1
RWB1
WDR
TJK3
Enforcement Coordinators
RI, RII, RIII, RIV (DJH, CFE, HBC, GFS)
TJF
SFG
HTB
GPC
RCP2
RJS2
AJM
RidsNrrDipmIipb
GEG
DRC1
DRPIII
DRSIII
PLB1
JRK1
OEMAIL
CHW1
LAD
JGL
MJR1