ML100610336

EOC Annual Assessment Letter, Inspection/Activity Plan

ML100610336
Person / Time
Site:	Dresden
Issue date:	03/03/2010
From:	Stephanie West Division Reactor Projects III
To:	Pardee C Exelon Generation Co, Exelon Nuclear
References
Download: ML100610336 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 March 3, 2010 Mr. Charles G. Pardee Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ANNUAL ASSESSMENT LETTER - DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 (05000237/2010001; 05000249/2010001)

Dear Mr. Pardee:

On February 11, 2010, the NRC staff completed its performance review of Dresden Nuclear Power Station, Units 2 and 3. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information.

A separate letter designated and marked as "Official Use Only -- Security Information" will include the Security Cornerstone review and resultant inspection plan.

Dresden Unit 2 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter as well as the first three quarters of the assessment cycle, was within the Licensee Response column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections on Unit 2.

Dresden Unit 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Regulatory Response column of the NRC=s Action Matrix, based on one inspection finding in the Mitigating Systems Cornerstone being classified as having low to moderate safety significance (White). This White finding, from the third quarter of 2009, involved the inadvertent withdrawal of three control rods by non-licensed operators during a shutdown condition. We will plan to conduct a supplemental inspection in accordance with Inspection Procedure (IP) 95001 in response to this White finding after we are notified of your readiness. This supplemental inspection will be in addition to baseline inspections at your facility.

C. Pardee Additionally, the staff has identified a substantive cross-cutting issue (SCCI) in the area of Human Performance (HP) with a cross-cutting theme in the aspect of Work Practices-Human Error Prevention Techniques, H.4(a). During this assessment period, there were 14 findings documented with cross-cutting aspects in the HP area. Five of these findings shared a common cross-cutting Human Error Prevention Techniques aspect and were from different cornerstones. We have a concern with your progress in addressing this issue; specifically, your corrective actions have been in place for some time but have not yet proven to be effective.

There has been no sustained period of improved performance. This substantive cross-cutting issue will remain open until the NRC gains confidence in your performance through your demonstration of positive, sustainable improvement in the area of Human Performance and after consideration of the number of findings with the same cross-cutting aspect.

In our 2009 mid-cycle assessment, we identified a cross-cutting theme in the area of Problem Identification and Resolution (PI&R) involving the stations ability to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity, P.1(d). We had determined that a substantive cross-cutting issue was not warranted in this area at the time since you had appropriately identified the theme, and scheduled or taken a range of corrective actions to address the issue. In this assessment we have determined that it appears the station has made improvement within this area as evident by the reduction in findings sharing the P.1(d) aspect.

Therefore, we are not proposing a substantive cross-cutting issue at this time.

The enclosed inspection plan details the inspections, less those related to security, scheduled through June 30, 2011. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature.

Additional inspections scheduled include: component design basis, independent spent fuel storage installation operation, post-approval license renewal (for Units 2 and 3), managing fatigue, and a supplemental inspection for the White finding on Unit 3. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

C. Pardee If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven West, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25

Enclosure:

Dresden Inspection/Activity Plan cc w/encl: Distribution via ListServ

C. Pardee If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven West, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25

Enclosure:

Dresden Inspection/Activity Plan cc w/encl: Distribution via ListServ DOCUMENT NAME: G:\1-SECY\1-WORK IN PROGRESS\2009 EOC LETTERS\DRESDEN 2009 EOC LETTER.DOC G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII E RIII RIII RIII NAME MRing:cms SWest DATE 02/24/10 03/03/10 OFFICIAL RECORD COPY

Letter to C. Pardee from S. West dated March 3, 2010

SUBJECT:

ANNUAL ASSESSMENT LETTER - DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 (05000237/2010001; 05000249/2010001)

DISTRIBUTION:

Susan Bagley RidsNrrDorlLpl3-2 RidsNrrPMDresden Resource RidsNrrDirsIrib Resource Cynthia Pederson Steven Orth Jared Heck Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

Dresden Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site ISFSI - ISFSI INSPECTION 1 03/01/2010 07/31/2010 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants BI PI&R - BIENNIAL PI&R INSPECTION 4 03/01/2010 03/19/2010 IP 71152B Identification and Resolution of Problems OL EXAM - DRESDEN INIT EXAM MARCH/2010 3 03/08/2010 03/19/2010 W90218 OL - INITIAL EXAM - MAR 2010 - DRES BI ENG - COMPONENT DESIGN BASIS INSPECTION 6 04/19/2010 05/21/2010 IP 7111121 Component Design Bases Inspection BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 05/03/2010 05/07/2010 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 05/03/2010 05/07/2010 IP 71151-BI01 Reactor Coolant System Activity BI OL - LIC. OPERATOR REQUAL. PROGRAM EVALUATION 1 05/24/2010 05/28/2010 IP 7111111B Licensed Operator Requalification Program TI - TEMPORARY INSTRUCTION 2515/180 1 06/17/2010 06/17/2010 IP 2515/180 Inspection of Procedures and Processes for Managing Fatigue BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 08/16/2010 08/20/2010 IP 71124.04 Occupational Dose Assessment 08/16/2010 08/20/2010 IP 71124.07 Public Radiation Safety 08/16/2010 08/20/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent RENEWAL - LICENSE RENEWAL 71003 - PHASE 2 - U3 7 10/18/2010 10/29/2010 IP 71003 Post-Approval Site Inspection for License Renewal RENEWAL - LICENSE RENEWAL 71003 - PHASE 1 - U3 3 11/01/2010 11/19/2010 IP 71003 Post-Approval Site Inspection for License Renewal BI ENG - ENGINEERING INSERVICE INSPECTION 1 11/01/2010 11/19/2010 IP 7111108G Inservice Inspection Activities - BWR BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 11/08/2010 11/19/2010 IP 71124.02 Occupational ALARA Planning and Controls 11/08/2010 11/19/2010 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 11/08/2010 11/19/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness BI ENG - RPV HEAVY LOADS SMART SAMPLE 1 01/10/2011 01/28/2011 IP 7111120 Refueling and Other Outage Activities OL PREP - DRESDEN INIT PREP - 02/2011 3 02/14/2011 02/18/2011 W90229 OL - INITIAL EXAM - MARCH 2011 - DRES BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 02/21/2011 02/25/2011 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Dresden Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 2/21/2011 02/25/2011 IP 71151-BI01 Reactor Coolant System Activity OL EXAM - DRESDEN INIT EXAM - 03/2011 3 3/07/2011 03/18/2011 W90229 OL - INITIAL EXAM - MARCH 2011 - DRES BI EP - EP EXERCISE INSPECTION / PI VERIFICATION 3 3/21/2011 03/25/2011 IP 7111401 Exercise Evaluation 3/21/2011 03/25/2011 IP 71151-EP01 Drill/Exercise Performance 3/21/2011 03/25/2011 IP 71151-EP02 ERO Drill Participation 3/21/2011 03/25/2011 IP 71151-EP03 Alert & Notification System BI ENG - TRIENNIAL HEAT SINK INSPECTION 1 3/28/2011 04/01/2011 IP 7111107T Heat Sink Performance BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 6/20/2011 06/24/2011 IP 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 6/20/2011 06/24/2011 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 6/20/2011 06/24/2011 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 6/20/2011 06/24/2011 IP 71124.04 Occupational Dose Assessment