ML20133J811
| ML20133J811 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/11/2020 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020001 | |
| Download: ML20133J811 (34) | |
See also: IR 05000237/2020001
Text
May 11, 2020
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Co., LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED
INSPECTION REPORT 05000237/2020001 AND 05000249/2020001
Dear Mr. Hanson:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Dresden Nuclear Power Station, Units 2 and 3. On April 8, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of
these findings involved violations of NRC requirements. One Severity Level IV violation without
an associated finding is documented in this report. We are treating these violations as non-cited
violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector
at Dresden Nuclear Power Station, Units 2 and 3.
B. Hanson
2
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/
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
cc w/ encl: Distribution via LISTSERV
X
SUNSI Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE RIII
NAME
CPhillips:wc
KRiemer via email
DATE
5/11/2020
5/11/2020
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000237 and 05000249
License Numbers:
Report Numbers:
05000237/2020001 and 05000249/2020001
Enterprise Identifier: I-2020-001-0045
Licensee:
Exelon Generation Company, LLC
Facility:
Dresden Nuclear Power Station, Units 2 and 3
Location:
Morris, IL
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
J. Corujo-Sandin, Senior Resident Inspector
G. Edwards, Health Physicist
R. Elliott, Resident Inspector
M. Garza, Emergency Preparedness Inspector
T. Go, Health Physicist
J. Park, Reactor Inspector
C. Phillips, Project Engineer
L. Rodriguez, Reactor Inspector
C. St. Peters, Reactor Engineer
Approved By:
Kenneth R. Riemer, Chief
Branch 1
Division of Reactor Projects
2
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
Unit 2B Low Pressure Coolant Injection Valve Damaged Due To Inadequate Inspection
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
A self-revealed Green finding and associated non-cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, was identified on October 23, 2019. During a performance of a
surveillance test on October 23, 2019, the 2B low pressure coolant injection (LPCI) pump
suction valve 2-1501-5B failed to reopen following closure resulting in the 2B LPCI pump
being declared inoperable. The licensee's evaluation of this failure identified that an
inspection was performed in 2015 with inadequate inspection guidance that should have
identified corrosion of the valve motor limit switch that lead to the failure of the valve.
Failure to Account Instrument Uncertainties
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2020001-02
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited Violation (NCV) of
10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for
instrument uncertainty in surveillance procedures' acceptance criteria for High Pressure
Coolant Injection required flow and Ultimate Heat Sink maximum temperature.
Differential Pressure Indicating Switch Failure in Low Pressure Core Injection Loop Select
Logic
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Not Applicable
Open/Closed
Not Applicable
A self-revealed Severity Level (SL) IV NCV of Technical Specifications (TS) 3.3.5.1,
Emergency Core Cooling System (ECCS) Instrumentation, was identified when the licensee
determined during routine surveillance testing that one of four (4) channels of the recirculation
pump high differential pressure function was inoperable for longer than the 24-hour allowed
outage time.
3
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
LER 2019-001-00 for
Dresden, Unit 3, Degraded
Differential Pressure
Indicating Switch in the LPCI
Loop Select Logic Caused
by Water Damage Results in
a Condition Prohibited by
Technical Specifications
Closed
4
PLANT STATUS
Unit 2 began the inspection period in a forced outage (D2F59) due to an unexplained increase
in unidentified leakage. The unit was returned to full power on January 6, 2020. On
January 7, 2020, Unit 2 was down powered to 80 percent for control rod adjustment and was
returned to full power on the same day, then remained there for the rest of the inspection period.
Unit 3 began the inspection period at full power and maintained full power throughout the first
quarter.
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/readingrm/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. From January 1 - March 19, 2020, 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President
of the United States on the public health risks of the coronavirus (COVID-19), resident
inspectors were directed to begin telework and to remotely access licensee information using
available technology. During this time the resident inspectors performed periodic site visits
each week and during that time conducted plant status activities as described in IMC 2515,
Appendix D; and observed risk significant activities when warranted. In addition, resident and
regional baseline inspections were evaluated to determine if all or portion of the objectives and
requirements stated in the IP could be performed remotely. If the inspections could be
performed remotely, they were conducted per the applicable IP. In the cases where it was
determined the objectives and requirements could not be performed remotely, management
elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-
significant systems from expected snowfall and wind gusts on
February 12 and 13, 2020
5
71111.04 - 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 High Pressure Coolant Injection (HPCI) Post Maintenance on March 5, 2020
(2)
2/3 Emergency Diesel Generator (EDG) with 2/3 EDG maintenance window on
March 24, 2020
(3)
Unit 3 Standby Liquid Control (SBLC) on March 28, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated system configurations during a complete walkdown of the
Unit 3 Isolation Condenser with Unit 3 HPCI maintenance window system on
February 25, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Fire Zone (FZ) 9.0.A, Unit 2 diesel generator elevation 517 on January 10, 2020
(2)
FZ 7.0.A.1-3 and FZ 8.2.7, Unit 2 battery room elevation 549 on January 22, 2010
(3)
FZ 8.2.8.A, Unit 3 main turbine floor elevation 561' on January 27, 2020
(4)
FZ 11.1.1, Unit 3 southwest corner room elevation 476' on January 27, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during an
announced fire drill on February 13, 2020
71111.07T - Heat Sink Performance
Triennial Review (IP Section 03.02) (2 Samples 1 Partial)
The inspectors evaluated heat exchanger/sink performance on the following:
(1)
Unit 3 Diesel Generator Cooling Water Coolers (3-6669-A/B), cooled by the service
water system, Section 02.02.b
(2)
Unit 3 HPCI Room Cooler (3-5747), cooled by the service water system,
Section 02.02.b
(3)
(Partial)
Ultimate Heat Sink, Sections 02.02.d.2 and 02.02.d.6
6
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 Unit 2
Control Room during forced outage D2F59 restart on January 3, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated 2020-OBE [out-of-the box evaluation] 03B on
January 28, 2020
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Rod block monitor (A2 at risk) on February 26, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
Unit 2 Station Blackout Diesel maintenance window on January 27, 2020
(2)
Unit 3 4 KV Technical Specification Undervoltage and Degraded Voltage Relay
Replacement (normally done off-line) on February 11, 2020
(3)
Unit 2 Rod Position Indication System (RPIS) Power Supply Replacement (on-line) on
February 24, 2020
(4)
Unit 3 work week risk on February 26, 2020
(5)
Unit 2 work week risk on February 26, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Functionality of station black out diesel generator batteries
(2)
Emergency Diesel Generator Unit 2 and Unit 3 Surveillance Requirement 3.3.8.1.4
possibly missed
(3)
Standby Gas Treatment due to use of chemicals in the turbine building
(4)
Unit 3 HPCI - operability of room cooling system with seam leaks in the room
7
(5)
Unit 2/3 EDG Operability with elevated Ultimate Heat Sink (UHS) Temperature
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
Engineering Change 622852, Revision 2, Containment Cooling Service Water 16"
Pipe Replacement - DIV I Line 2-1510-16"-D Pipe Penetration on 517" Elevation of
the Turbine Building
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance test activities to verify system
operability and functionality:
(1)
Unit 2 Station Blackout Diesel Generator surveillance run after scheduled
maintenance window on January 30, 2020
(2)
Unit 3 HPCI on February 27, 2020
(3)
Containment vent and purge isolation valve on February 28, 2020
(4)
Unit 2 RPIS power supply replacement on February 25, 2019
(5)
Unit 2 EDG on March 11, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated D2F59 forced outage due to generator hydrogen leak,
which began in December 2019 and ended on January 3, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (6 Samples)
(1)
Unit 2/3 EDG Monthly Surveillance on January 6, 2020
(2)
Unit 3 HPCI Fast Start Surveillance under Work Order (WO) 04733340-01
(3)
Unit 2/3 B Isolation Condenser Makeup Pump Quarterly Operability under
(4)
Recirculation pump DP indication and setpoint calibration on March 20, 2020
(5)
Electromatic relief valve and Target Rock valve calibration and functional test on
March 31, 2020
(6)
Unit 2 HPCI, Core Spray and LPCI Verification systems discharge piping are full of
water, WO 05003761-01, WO 0500370-01, and 05003762-01 on February 19, 2020
8
Inservice Testing (IP Section 03.01) (1 Sample)
(1)
3A Core Spray In-service Test on February 3, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
(1)
The inspectors evaluated the following maintenance and testing of the alert and
notification system:
2018 Annual Preventive Maintenance
2019 Annual Preventive Maintenance
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
(1)
The inspectors evaluated the readiness of the Emergency Preparedness
Organization
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
(1)
The inspectors evaluated the maintenance of the emergency preparedness program
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
(1)
2020-Out-of-Box Evolution-03B on January 28, 2020
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation
systems:
(1)
Unit-2/3 Standby Gas Treatment System and Control Room Emergency Ventilation
System (CREVS) Diagram M-49
9
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1)
Temporary portable high-efficiency particulate air (HEPA) ventilation unit located in
the Unit-3 reactor building 545' shutdown cooling heat exchanger room
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated the licensees use of respiratory protection devices
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated licensee performance as it pertains to radioactive source
term characterization
External Dosimetry (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated licensee performance as it pertains to external dosimetry
that is used to assign occupational dose
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments for actual internal
exposures:
(1)
Dose assessment of individuals potentially exposed to airborne radioactivity during
the clean up and inspection of Unit 2 steam jet ejector 2-300B valve on
November 11, 2019, Doc: DR-02-19-00808
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
(1)
Dose assessment for two declared pregnant workers
10
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)
(1)
3rd quarter 2019 through 4th quarter 2019
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 2 1st quarter through 4th quarter 2019
(2)
Unit 3 1st quarter through 4th quarter 2019
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
(1)
3rd quarter 2019 through 4th quarter 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
(2 Samples)
(1)
Unit 2 1st quarter through 4th quarter 2019
(2)
Unit 3 1st quarter through 4th quarter 2019
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
(1)
3rd quarter 2019 through 4th quarter 2019
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 2 1st quarter through 4th quarter 2019
(2)
Unit 3 1st quarter through 4th quarter 2019
71153 - Followup of Events and Notices of Enforcement Discretion
Event Followup (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated Loss of Power to Non-Power Block Buildings and licensees
response on March 12, 2020
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1)
LER 05000249/2019-001, Unit 3, Degraded Differential Pressure Indicating Switch in
the LPCI Loop Select Logic Caused by Water Damage Results in a Condition
Prohibited by Technical Specifications (ADAMS Accession No. ML19325C091). The
inspection conclusions associated with this LER are documented in this report under
Inspection Results Section 71153
11
INSPECTION RESULTS
Unit 2B Low Pressure Coolant Injection Valve Damaged Due To Inadequate Inspection
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
A self-revealed Green finding and associated non-cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, was identified on October 23, 2019. During a performance of a
surveillance test on October 23, 2019, the 2B low pressure coolant injection (LPCI) pump
suction valve 2-1501-5B failed to reopen following closure resulting in the 2B LPCI pump
being declared inoperable. The licensee's evaluation of this failure identified that an
inspection was performed in 2015 with inadequate inspection guidance that should have
identified corrosion of the valve motor limit switch that lead to the failure of the valve.
Description:
On October 23, 2019, the 2-1501-5B was closed during a surveillance test. The valve limit
switch had corroded in position and did not remove the torque switch bypass during valve
closure resulting in the actuator over thrusting the valve by 250 percent of the rated actuator
thrust limit. The actuator springpack, limit switch, torque switch, motor, and operator bolts
were replaced. The valve stem and yoke were inspected and were found to be satisfactory.
Upon closure, the valve could not be reopened and the 2B LPCI pump was declared
The licensee's evaluation of the event determined that this valve had experienced historical
wetting on top of the actuator due to ground water intrusion from as early as 2006. The
ground water leakage was eventually repaired in 2009. In 2010 Exelon operating experience
required a review of risk significant components that had experienced wetting from internal
leakage. The station identified the 2-1501-5B as a component of interest even though it was
not considered a risk significant component. An inspection of the actuator was performed
during the next 6-year preventive maintenance window for the valve in 2015.
On March 3, 2015, the licensee competed Work Order (WO) 01216146 which performed a
PM inspection on the limit switch and torque switch of 2-1501-5B per MA-AA-723-301,
Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated
Valves. During the PM, the limit switch cover and the torque switch were found degraded.
The torque switch and limit switch cover gasket were replaced, and rust found on the limit
switch cover was cleaned. Pictures taken during this inspection showed the limit switch rotor
base showed signs of corrosion. The corrosion of the limit switch base was not identified, or
at least not recorded, during the inspection. The licensee's evaluation stated that the
procedure guidence was not clear as to what should have been done about the corrosion on
the limit switch base. The inspectors reviewed the licensee's evaluation (which included
pictures of the limit switch rotor in 2015) and the 2015 completed work order. Procedure
MA-AA-723-301, Step 4.4.5 stated, "inspect limit switch compartment for moisture, corrosion,
foreign materials leaking lubricant and casting irregularities. Record inspection results on
Attachment 2." The inspectors determined that, based on the guidance given in the work
order, corrosion found during the inspection was unsatisfactory and should have been
12
addressed either by cleaning or replacement of the limit switch rotor at that time. The
licensee's corrective actions were not complete at the time of the inspection.
Corrective Actions: The licensee replaced the actuator springpack, limit switch, torque
switch, motor, and operator bolts. The valve stem and yoke were inspected and were found
to be satisfactory. The licensee planned to train electrical maintenance personnel on the
results of the equipment failure evaluation.
Corrective Action References: Action Request 04290376, 2-1501-5B Valve Failure During
DOS 1500-01
Performance Assessment:
Performance Deficiency: The failure to follow procedure MA-AA-723-301, Step 4.4.5, in part,
to inspect the limit switch compartment for moisture, corrosion . . . Record inspection results
on Attachment 2, during the inspection of the actuator for 2-1501-5B was a performance
deficiency. Valve 2-1501-5B was a safety-related valve and the inspection of the valve
actuator was an activity that affected quality. Title 10 CFR Part 50, Appendix B, Criterion V,
required that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Human Performance attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. The maintenance technicians that inspected that valve actuator for corrosion
in 2015 failed to identify, document, and correct corrosion that existed on the 2-1501-5B limit
switch actuator. This corrosion later resulted in the failure of the valve during surveillance
testing. The inspectors determined that this example was similiar to IMC 0612, Appendix E,
January 1, 2020, examples 4.c and 4.k.
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 Mitigating Systems cornerstone and determined to be of very low safety
significance (Green) because the inspectors answered no all six questions in IMC 0609,
Appendix A, Exhibit 2, dated December 13, 2019.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance. The cause of this valve failure was greater than three years old and not
considered present performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, requires, in part, that activities affecting quality be prescribed by documented
procedures of a type appropriate to the circumstances and be accomplished in accordance
with these procedures. The licensee established MA-AA-723-301, Periodic Inspection of
Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves, Revision 10, as the
implementing procedure for WO 01216146, D2 6Y MOV [motor operated valve] Diagnostic
Testing & Limitorque Surv [surveillance] 2-1501-5B, an activity affecting quality.
13
Procedure MA-AA-723-301, Step 4.4.5 states, inspect limit switch compartment for moisture,
corrosion, foreign materials leaking lubricant and casting irregularities. Record inspection
results on Attachment 2.
Contrary to the above, on March 3, 2015, licensee personnel performed an inspection of the
2-1501-5B LPCI 2B pump suction valve, an activity that affected quality, but did not
accomplish the inspection in accordance with procedures that were appropriate to the
circumstances. Specifically, licensee personnel failed to follow Step 4.4.5, of procedure
MA-AA-723-301 by inspecting the 2-1501-5B limit switch compartment with corrosion present
on the limit switch rotor base and did not mark the presence of the corrosion in Attachment 2.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Account Instrument Uncertainties
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2020001-02
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited Violation (NCV) of
10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for
instrument uncertainty in surveillance procedures' acceptance criteria for high pressure
coolant injection required flow and Ultimate Heat Sink maximum temperature.
Description:
When using an instrument to measure a quantity, the recorded value will always have an
amount of uncertainty. These uncertainties need to be accounted for to ensure that when a
quality related test is performed the results collected validate the associated SSCs remain
withing licensing and design bases values. During their review, the inspectors noted at least
two safety-related and Technical Specifications (TS) systems' surveillance tests where the
licensee failed to account for said instrument uncertainties. The systems with the deficiencies
identified were the high-pressure coolant injection (HPCI) systems and the Ultimate Heat Sink
(UHS).
For the HPCI systems, the TS Surveillance Requirement (SR) 3.5.1.6 required the licensee
"to verify the HPCI pump can develop a flow rate greater than or equal to 5,000 gpm against
a system head corresponding to reactor pressure." The UFSAR Table 6.3-20b described the
HPCI LOCA analysis value for the Minimum Rated Flow Over Range as 5,000 gpm. After
conversations with the licensee, it was also established that Technical Specifications pump
flows were used as inputs into the LOCA analyses without adjustments for uncertainty. This
condition was repeated as the licensee transitioned through different nuclear fuel vendors
(GE, Westinghouse, and Areva). Procedure DOS 2300-03, "High Pressure Coolant Injection
System Operability and Quarterly IST Verification Test," Revision 11, was the implementing
procedure to comply with TS SR 3.5.1.6. Step H.5.a and Data Sheet 2 to this procedure
established a HPCI flow of equal or greater than 5,000 gpm in order to meet the procedure's
acceptance criteria. Flow was measured using Flow Controller FIC 2(3)-2340-1. In
licensee's calculation NED-I-EIC-0109, Revision 6, Section 13, "Conclusions", the associated
flow instrument uncertainties were determined (these vary depending on the model of the
instrument installed and the unit it is installed). The average instrument uncertainty
14
associated with FIC 2(3)-2340-1 was +/- 255 gpm under normal plant conditions and +/- 846
gpm under accident conditions.
For the UHS, the TS Surveillance Requirement 3.7.3.2 required the licensee to verify the
average water temperature of the UHS was less than or equal to 95 degrees Fahrenheit (F).
The UFSAR Section 6.2.1.3, Table 6.2-7 and Section 9.5.5 described 95 degrees F as the
maximum inlet water temperature for the Diesel Generator Cooling Water and the
Containment Cooling Service Water systems. Both of these systems are supplied by the
UHS. A sampling review of calculations related to the UHS and supplied systems also noted
that 95 degrees F was the maximum UHS supplied water temperature assumed (Reference
calculations ATD-0400, "Unit 2/3 Diesel Generator Jacket Water Capacity", Revision 0; and
DRE98-0077, "Dresden HPCI Room Thermal Response with Reduced Room Cooler
Capability", Revision 001C). Procedure Unit 2(3) Appendix B, "Assist NSO and Common
Unit Daily Surveillance Log" Revision 90, was the implemented procedure to comply with TS
SR 3.7.3.2. Attachment A to this procedure established an acceptance criteria for the UHS
average water temperature of less than or equal to 95 degrees F as measure by instrument
TR 2/3-4441-16. The licensee informed the inspectors that instrument TR 2/3-4441-16
had an uncertainty of +/- 1 degree F when measuring temperatures between 90 and
100 degrees F.
Based on the above, the inspectors were concerned that failure to account for said
uncertainties could result in a situation where a surveillance test was declared satisfactory
when in reality the structure system or component (SSC) could be within the unacceptable
results range once uncertainties were considered. Since these were safety-related and TS
SSCs a failed TS Surveillance would result in the SSC becoming inoperable and the
associated LCO action statement must be entered. A review of the results from the last time
the affected surveillances were performed showed results which were satisfactory even when
accounting for uncertainties.
In addition, based on the licensee's initial understanding of this issue, the inspectors believed
an extent of condition would reveal additional surveillance tests which fail to account for
instrument uncertainties. This concern was shared with the licensee. The licensee was
evaluating if an extent of condition review was needed.
Corrective Actions: The licensee has validated, currently, there are no challenges to meeting
Technical Specifications Surveillance Requirements, and the affected equipment remains
operable and able to perform their function. In addition, the licensee was recommending:
1) to revise procedures for HPCI (DOS 2300-03) and UHS (Daily Surveillance Log
Appendix B) to account for instrument uncertainty; 2) revise setpoint calculations output
listings to designate the associated surveillance procedure; and 3) perform extent of condition
review.
Corrective Action References: AR 04315614, NRC Question on DOS 2300-03 Acceptance
Criteria
AR 04317369, NRC Ultimate Heat Sink (UHS) Inspection Question
AR 04318639, NRC UHS Open Question 011-2
AR 04331189, NRC Procedures and Instrument Uncertainty
15
Performance Assessment:
Performance Deficiency: The licensee surveillance procedures' acceptance criteria for HPCI
required flow and UHS maximum temperature failed to account for instrument uncertainty.
This was contrary to Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, and was a
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because if left uncorrected, it would have the potential to lead to a more significant safety
concern. Specifically, implementing the acceptance criteria as written, without accounting for
the associated instruments' uncertainty, could result in a satisfactory test result, when in
actuality the SSCs had failed the surveillance test. Since the acceptance criteria values used
in the procedure are the same as those used in Technical Specifications and their associated
analysis, this would have resulted in the licensee failing to declare the associated equipment
inoperable, entering the required TS Limiting Condition of Operation (LCO) action and
potentially place the plant in an unanalyzed configuration. This is consistent with the
guidance provided in IMC 0612, Appendix E, Example 3.g.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. Specifically, the
inspectors determined this finding is of very low safety significance (Green) because: the
performance deficiency was not a design or qualification issue; it did not represent a loss of
the system function; the associated trains were neither inoperable for greater than its allowed
outage time nor was it inoperable for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and were not part of an external
event mitigating system. The inspector was unable to find an example where the deficient
procedures resulted in an actual failed surveillance test.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that
a test program be established to assure that all testing required to demonstrate that
structures, systems, and components will perform satisfactorily in service is identified and
performed in accordance with written test procedures which incorporate the requirements and
acceptance limits contained in applicable design documents.
For high pressure coolant injection, a safety-related SSC:
Procedure DOS 2300-03, "High Pressure Coolant Injection System Operability and Quarterly
IST Verification Test," Revision 11, is the implementing procedure to comply with applicable
design documents. Section H of this procedure, "Acceptance Criteria", include step H.5.a
which states "The HPCI pump develops a flow of greater than or equal to 5000 gpm against a
system head corresponding to reactor pressure head with reactor pressure greater than or
equal to 920 psig and less than or equal to 1005 psig. (Tech Spec SR 3.5.1.6)."
For the Ultimate Heat Sink, a safety-related SSC:
Procedure Unit 2(3) Appendix B, "Assist NSO and Common Unit Daily Surveillance Log,"
Revision 90, is the implemented procedure to comply with applicable design documents.
Attachment A to this procedure was a table which included the established acceptance
16
criteria for the UHS average water temperature of less than or equal to 95 degrees F as
required by TS SR 3.7.3.2.
Contrary to the above, as of March 11, 2020, the licensee failed to assure that the testing
required to demonstrate that the HPCI and UHS systems would perform satisfactorily in
service was identified and performed in accordance with written test procedures which
incorporated the requirements and acceptance limits contained in applicable design
documents, as evidenced by the following examples:
1) Specifically, for the HPCI systems' procedure DOS 2300-03, Revision 117, the licensee
failed to account for instrument uncertainties when establishing the acceptance criteria to
ensure successful completion of these tests would ensure the associated SSCs would remain
operable and within the acceptable limits as determined by applicable design documents.
2) Specifically, for the UHS system's procedure Appendix B, Revision 90, the licensee failed
to account for instrument uncertainties when establishing the acceptance criteria to ensure
successful completion of these tests would ensure the associated SSCs would remain
operable and within the acceptable limits as determined by applicable design documents.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Differential Pressure Indicating Switch Failure in Low Pressure Coolant Injection Loop Select
Logic
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not
Applicable
Open/Closed
Not
Applicable
A self-revealed Severity Level (SL) IV NCV of Technical Specifications (TS) 3.3.5.1,
Emergency Core Cooling System (ECCS) Instrumentation, was identified when the licensee
determined during routine surveillance testing that one of four (4) channels of the recirculation
pump high differential pressure function was inoperable for longer than the 24-hour allowed
outage time.
Description:
This LER is associated with a Differential Pressure Indicating Switch (DPIS) failure in the Low
Pressure Coolant Injection (LPCI) Loop Select Logic that was inoperable for greater than the
TS LCO 3.3.5.1. On September 20, 2019, while performing LPCI reactor recirculating pump
A and B Differential Pressure Indication switch channel calibration and channel functional test
(DIS 1500-09), it was determined that DPIS 3-0261-35C was inoperable. The licensee
entered TS LCO 3.3.5.1 condition C, replaced DPIS 3-0261-35C and restored operability
within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Licensee operations staff requested a past operability evaluation of the Unit
3 LPCI Loop selection design function.
On June 20, 2019, water from the Unit 3 East LPCI corner room cooler was leaking (AR
04258407) onto the instrument rack that contained the DPIS 3-0262-35C. The licensee
installed a deflector to prevent water from dripping onto the instrument rack. On July 6, 2019,
a ground was identified (AR 04262209) on the Unit 3 125 VDC battery. The licensee entered
17
DOP 6900-07 (125 VDC Ground Detection) to try and locate and eliminate the ground. The
ground alarm cleared and it was determined that the ground did not affect operability of the
125 VDC system. Two subsequent grounds were identified. The first on July 28, 2019,
(AR 04267550) and the second on August 15, 2019, (AR 04272156) on the Unit 3 125 VDC
battery system which were determined not to affect the operability of the 125 VDC system.
The 125 VDC battery ground issue was resolved when DPIS 3-0262-35C, which was not
qualified for spray or submergence, was replaced on September 20, 2019.
On July 30, 2019, during the reactor recirculation pump running differential pressure switch
functional test, the results for all DPISs were satisfactory, therefore it was reasonable to
conclude that DPIS 3-0262-35C failed and was inoperable between July 30, 2019, and
September 20, 2019. Failure of DPIS 3-0262-35C did not impact the ability of the LPCI
system to perform its safety function in the event of an accident. Failure of one DPIS impacts
one division of LPCI Loop Select Logic, however the unaffected division remains capable of
performing the designed safety function.
Corrective Actions: The DPIS 3-0262-35C was replaced, tested, and the channel of
recirculation pump high differential pressure function was restored to an operable status. The
licensee performed a past operability evaluation for all DPISs that were used to support LPCI
system Loop selection design function and all remained functional with the exception of
DPIS 3-0262-35C. The licensee also performed a corrective action program evaluation to
identify programmatic factors. Service water was isolated to the Unit 3 East LPCI room
cooler until the leak was repaired.
Corrective Action References: AR 04290427, Historical Operability Review for
DPIS 3-0261-35C and AR04280928, DPIS Will Not Trip
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the
licensee and therefore is not a performance deficiency. The inspectors determined that
because the licensee initially took actions to protect the DPIS from the leaking water and
successfully completed the surveillance requirement that specifically tested the DPIS post
leakage, the failure was not reasonably foreseeable and preventable.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory
process impact in its assessment of licensee performance. Therefore, it is necessary to
address this violation which impedes the NRCs ability to regulate using traditional
enforcement to adequately deter non-compliance. Traditional Enforcement is being used
because a violation existed, however, there was no performance deficiency. The inspectors
used the Interim Guidance for Dispositioning Severity Level IV Violations with No Associated
Performance Deficiencies, issued June 15, 2018 (ML18158A220).
Severity: This violation is characterized as a Severity Level IV NCV based on its similarity to
SL IV example 6.1.d.1 in the Enforcement Policy.
Violation: Dresden Nuclear Power Station, Unit 3 TS 3.3.5.1, "Emergency Core Cooling
System Instrumentation," Condition C requires, in part, that if one or more channels are
inoperable, the channel must be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
18
Contrary to the above, from July 30, 2019, to September 20, 2019, one or more channels
associated with TS 3.3.5.1, Condition C, was inoperable and was not restored to an operable
status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Specifically, the 3A reactor recirculation pump DPIS 3-0261-35C was
inoperable due to water intrusion on June 20, 2019, which eventually caused the DPIS to fail.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 8, 2020, the inspectors presented the integrated inspection results to
Mr. P. Karaba, Site Vice President, and other members of the licensee staff.
On February 28, 2020, the inspectors presented the Radiation Protection inspection
results to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.
On March 12, 2020, the inspectors presented the Triennial Heat Sink inspection results
to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.
On March 27, 2020, the inspectors presented the Emergency Preparedness Program
inspection results to Mr. P. Karaba, Site Vice President, and other members of the
licensee staff.
19
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-DR-108-111-
1004
Cold Weather Strategy
00
Corrective Action
Documents
04190166
3-1105-B 3B SBLC Pmp Relief Valve did not Lift at Set Point
10/31/2018
04296647
2A SBLC Heat Trace Not Working Properly
11/12/2019
04304584
3B SBLC RV Failed Testing
12/17/2019
04313364
Evaluate Ops SBLC Tank Level Surv Acceptance Criteria
01/28/2020
2693730
2/3-5748-2B Indicating Short
07/18/2016
4272885
2/3 B ISO Cond M/U Pump Failed to Start Initially
08/19/2019
4318748
2-1301-607 Has a 1 Drop per 10 Second Packing Leak
02/17/2020
4319355
Fuel Leak on 2/3 B ISO Cond Make Up Pump
02/19/2020
4321473
NRC Question
02/25/2020
4321772
Loose Handlewheel Found
02/26/2020
Drawings
20600-001
High Pressure Coolant Injection (HPCI) System and
Instrumentation
05
20700LN001-001
Unit 2 Isolation Condenser System
03
DOP 1300-M1/E1
Unit 3 Isolation Condenser System Checklist
26
Miscellaneous
Dresden UFSAR
13
Procedures
DOP 1100-M1/E1
Unit 3 Standby Liquid Control (SBLC) System Checklist
16
DOP 1300-M2
Isolation Condenser Makeup Pump Fuel Oil System
03
DOP 2300-01
High Pressure Coolant Injection (HPCI) System Standby
Operation
59
DOP 2300-M1/E
Unit 2 HPCI System Checklist
39
DOP 2300-MI/E1
Unit 2 HPCI System Checklist
39
DOP 2300-MI/E1
Unit 2 HPCI System Checklist
39
DOP 6600-01
Diesel Generator 2(3) Preparation for Standby Operation
34
DOP 6600-E1
Unit 3 Standby Diesel Generator
06
DOP 6600-E1
Unit 2 Standby Diesel Generator
04
DOS 1100-02
Standby Liquid Control Tank Heater Surveillance Test
17
Corrective Action
Documents
4290524
Fire Door #67 on 545' Elevation Degraded but Functional
10/23/2019
4290768
Fire Door 67 Inoperable
10/24/2019
4318345
Operations 4.0 Critique for Fire Drill (Crew 4, 2-15-2020)
02/15/2020
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
4309021
U2 EDG Fire Door 17A Inoperable
01/09/2020
4309433
NRC Questions Regarding EDG Fire Doors & U2 DW O2
Analyzer
01/10/2020
4311928
NRC Question Regarding EDG Fire Door Failure Mechanism 01/22/2020
4313138
NRC Identified Issues
01/27/2020
Drawings
12-2350B
Schematic Diagram Diesel Generator 2 Auxiliaries and Start
Relays
Key Diagram Turbine Building 480V Motor Control Centers
28-2 and 29-2
Schematic Diagram Fire Protection Co2 System Part 2
W
M-974
Diagram of Diesel Generator Room Ventilation
L
Fire Plans
117 U3RB-20
Dresden Generation Station Pre-Fire Plan FZ 11.1.1
3
173 U3TB-84
Dresden Generation Station Pre-Fire Plan FZ 8.2.8A
4
Miscellaneous
D1620
Kinnear (Division of HARSCO Corporation) Automatic
Closing Atler Doors
000
Gaseous Suppression System B 3.7.k
65
Procedures
88-4-26
Checklist No. 1; Acceptance Criteria
0
DFPP 4175-01
24
DFPS 4145-01
Cardox System Operability Test
35
Fire Drill Performance
17
Attachment 1
"Sample" - Fire Drill Record
17
Calculations
87-0870/915
Unit 3 Diesel Cooling Water Pump NPSH, Fuel Oil Line
Pressure Head and Air Start Receiver Valve Pressure
Rating Evaluation
1C
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
0D
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
0
ATD-0400
Unit 2/3 Diesel-Generator Jacket Water Cooler Capacity
0B
CMED-057604
Evaluation of the Functional Capability of Components
Located in Dresden Unit 3 EQ Zones 4, 5, 6, for Elevated
Temperature due to Loss of Room Coolers
1
DRE03-0026
Analysis of the Intake Canal, CCSW Heat Exchanger, and
Temporary Pumps Following a Dam Failure and 1 Inch
1
21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DRE16-0011
Required Ultimate Heat Sink (UHS) Capacity
0A
DRE16-0011
Required Ultimate Heat Sink (UHS) Capacity
0
DRE98-0077
Dresden HPCI Room Thermal Response With Reduced
Room Cooler Capability
1C
RSA-D-92-06
HPCI Room Thermal Response With Loss of HPCI Room
Cooler at Dresden Station
0
Corrective Action
Documents
0770694
Enhance Accuracy for Intake Temperature Monitoring
05/01/2008
1021725
U3 DGCW Flanges Less Than B16.5 Minimum Thickness
01/26/2010
1084166
DTP 09: Small Steam Leak
06/24/2010
2532555
UHS Insp. - Calc for DGCW Pumps Based at 501 Elevation
07/24/2015
2532734
UHS NRC Insp. - Basis for UHS Vol. (2 Million Gallons)
07/25/2015
2533713
Further Information for IR 02532555
07/28/2015
3949714
U3 HPCI Room Cooler Fan Degraded
12/06/2016
3984974
Unit 3 HPCI Room Cooler Eddy Current Results
03/14/2017
4058405
DTP 09: Small Steam Leak on HPCI Turbine Poppet Valves
10/02/2017
4093842
Small U3 HPCI Room Cooler Leak Identified by NLO on
Rounds
01/16/2018
4109028
HPCI Room Cooler Tube Plugging
02/27/2018
4110057
Unit 3 HPCI Turbine-CV Rack Steam Leak at Flange Mating
Surf.
03/01/2018
4204847
Leak Identified During VT-2 Inspection of CREVS Cooling
12/20/2018
4206201
Bathymetric Survey Results for 2018
12/27/2018
4206210
U2 HPCI Room Cooler Leak Identified
12/27/2018
4206439
UFSAR Update Required to Address UHS Related Issue
12/28/2018
4227793
Strategic Engineering Review of 2018 UHS Survey Results
03/08/2019
4297362
Bolted Connection 20 DPM Leak on 2B LPCI Room Cooler
11/14/2019
4309911
DTP 09 - Steam Leak on HPCI Turbine
01/13/2020
Corrective Action
Documents
Resulting from
Inspection
4316968
U3 Diesel Generator Cooling Water Pump
02/11/2020
4316989
NRC - Scaffolding Left Past due Date Near 3D CCSW Pump
02/11/2020
4317210
NRC Identified Corrosion on SW Elbow in U3 HPCI Room
02/12/2020
4317369
NRC Ultimate Heat Sink (UHS) Inspection Question
02/12/2020
4317374
NRC Question on U3 EDG CWP Motor Cooler Inspection
02/12/2020
4317695
DOS 6600-08 Opportunity to Improve Writers References
02/13/2020
22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4318541
NRC UHS Inspection - Basis for HPCI Operability in UFSAR
02/17/2020
4318639
NRC UHS Open Question 011-2
02/17/2020
4318708
NRC Question of 50.59 Screening
02/17/2020
4322212
2020 UHS Inspection: DRE16-0011 UFSAR Timely Update
02/28/2020
4322375
2020 NRC UHS Inspection: UFSAR Revision UHS Volume
02/28/2020
4322395
2020 UHS Inspection - NRC Calculation Question
02/28/2020
4323025
2020 UHS Inspection - IR 2533713 Action not Complete
03/02/2020
4325402
Timber Mat Contact
03/10/2020
Engineering
Changes
363202
ENGR Review Material Change and EDG Thermal Report
for EDG Heat Exchangers
0
382082
Licensing Basis of the Ultimate Heat Sink (UHS) and the
Impact of Silting
0
403120
Computation of DGCW Pumps NPSHA During Dam Failure
0
629625
Licensing Basis of the Ultimate Heat Sink (UHS) Credited
Volume and UFSAR Update
0
Engineering
Evaluations
2020-02-001
Update to UFSAR Description of the Ultimate Heat Sink
(UHS) Credited Volume
0
Miscellaneous
23218036.00
2018 Bathymetric/Volume Survey of the Intake/UHS Canal
10/25/2018
23219026.00
2019 Bathymetric/Volume Survey of the 2/3 Intake/UHS
Canal
10/23/2019
50384
BEM Condition Assessment of 24" Carbon Steel Piping
CCSW Unit 2 - 2-1505-24"
12/03/2019
AH1406-
40656587
Long Range Guided Wave Ultrasonic Pipe Screening
Results
06/18/2019
AH1406-
40656587PIMS
Long Range Guided Wave Ultrasonic Pipe Screening
Results
06/24/2019
EA Project No.
1500411
2017 Bathymetric Survey of the Intake Canal at Exelon
Generation Company's Dresden Generating Station
1
SL-013900
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals August 2017
0
SL-014493
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals June 2018
0
SL-015035
Field Surveillance Report Annual Lake Monitoring and
Examination of Circulating Water Canals June 2019
0
23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operability
Evaluations08-005
U3 EDG Cooling Water (DGCW) Heat Exchanger (HX) Flex
Hoses
2 10-006
U3 EDG Jacket Water Inlet Temperature Running Higher
Than Normal
2
Procedures
DIP 3900-01
Diesel Generator Cooling Water Flow Indicator and Pump
Suction and Discharge Gauge Preparation for In-Service
Testing
9
DIS 3900-03
Diesel Generator Cooling Water Pump Suction and
Discharge Pressure Indicator Calibration
13
DOA 0010-01
Dresden Lock and Dam Failure
36
DOA 0010-01
Dresden Lock and Dam Failure
35
DOA 0010-S1
Key Phone Numbers for DOA 0010 Block Procedures
16
DOS 0010-01
Dresden Dam Failure Equipment Test
23
DOS 6600-08
Diesel Generator Cooling Water Pump Quarterly and
Comprehensive/Preservice Test for Operational Readiness
and In-Service Test (IST) Program
65
System and Equipment Health Monitoring
22
Service Water Heat Exchanger Inspection Guide
8
Screening and Evaluation of Potential Aging Issues
4
Work Orders
01102337
D3 2Y PM Standby Diesel Generator Inspection
01/27/2010
01545660
D3 6Y PM Standby Diesel Generator Inspection
02/23/2018
01592255
D3 8Y PM Replace HPCI Room Cooler Cooling Coil
05/03/2019
01640181
D3 2Y TS D/G CLG WTR PMP Comprehensive Test for IST
Program
07/29/2015
01709946
D3 6Y PM D/G Conduct Eddy Current Test 3-6669-A
02/26/2016
01709947
D3 6Y PM D/G Conduct Eddy Current Test 3-6669-B
02/26/2016
01711473
D3 2Y PM Standby Diesel Generator Inspection
02/25/2016
01711473(SUP)
Supplemental - 00006645-10, PMSR, D3 2Y PM Standby
Diesel Generator Inspection, E: 3-6601, DGNA, E15
02/22/2016
01837703
D3 4Y PM D/G CLG WTR Pump Press. Gauge CAL
09/18/2019
04706728
D3 2Y TS D/G CLG WTR PMP Comprehensive Test for IST
Program
09/16/2019
04797971
U3 HPCI Room Cooler Degrading
05/03/2019
24
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04799354
D3 AN COM Inspections of Buried Piping
05/29/2019
04799356
D2/3 AN COM Inspections of Buried Piping
05/29/2019
04870742
D1/2/3 AN PM River Temp Recorder Cal.
01/09/2020
04962726
D3 QTR TS (IST) EDG CLG WTR PMP Test for IST
Program Surviel.
12/19/2019
99207934
D3 6Y PM Standby Diesel Generator Inspection
11/13/2006
71111.11Q Miscellaneous
2020-OBE-03B
Jan 2020
Corrective Action
Documents
4323125
U3 RBM 7 Iprm Input Downscale Trip Ref out of Tolerance
03/02/2020
Miscellaneous
Maintenance Rule
System Basis
Document
Dresden, Unit 3, Rod Block Monitor (RBM)
02/26/2020
Maintenance Rule
System Basis
Document
Dresden, Unit 3, Reactor Protection System (RPS)
02/26/2020
MR Function
Evaluation
Dresden, Unit 3, Reactor Protection System
01/03/2020
MR Function
Evaluation
Dresden, Unit 3, U3 0708-2-N
01/03/2020
Procedures
Inspection
Procedure
Maintenance Effectiveness
01/01/2020
Corrective Action
Documents
4318369
Momentary Loss of Half the Core RPIS Indications
02/16/2020
Drawings
Turbine Building Closed Cooling Water (TBCCW)
1
Miscellaneous
Protected Equipment Lists for Unit 2 and Unit 3 Risk
Significant Systems
On-Line Risk Management
11
Protected Equipment List - ADS
02/23/2020
Procedures
DOP 6400-13
Electrical Yard Switching
55
DOP 6400-13
Electrical Yard Switching
55
DOS 1100-04
Standby Liquid Control System Quarterly/Comprehensive
Pump Test for the Inservice Test (IST) Program
53
DOS 1100-04
Standby Liquid Control System Quaterly/Comprehensive
53
25
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Pump Test for the Inservice Testing (IST) Program
DOS 5750-04
Control Room Train B HVAC and Air Filtration Unit
Surveillance
55
DOS 5750-04
Control Room Train B HVAC and Air Filtration Unit
Surveillance
55
MA-DR-771-403
Unit 3 - 4 KV Tech Spec Undervoltage and Degraded
Voltage Relay Routines
15
Protected Equipment Program
5
Work Orders
04982736-01
D2/3 Qtr Com 'B' Iso Cond Make-up Pump Operability
02/19/2020
050008840
IMD TS&R RPIS Power Supply (PSX6)
02/17/2020
Calculations
ATD-0400
Unit 2/3 DG Jacket Water Cooler Capacity
0
ATD-0400
Unit 2/3 Diesel Generator Jacket Water Cooler Capacity
000A
Calibration
Records
127-1-B33-1
Relay Routine for 4 KV Buss 33-1 Undervoltage Relays
02/10/2020
127-2-B33-1
Relay Routine for 4 KV Buss 33-1 Undervoltage Relays
02/10/2020
Corrective Action
Documents
347338
DG Ventilation Calculation Weaknesses
06/24/2005
4162726
High Vibes on U3 HPCI Room Cooler
08/08/2018
4244414
Unexptected Alarm 903-4 C-22 Due to 3-2301 Opening
04/29/2019
4262603
IEMA Question Related to IR 4244414 3-2301-14 Valve
Opening
07/08/2019
4312803
Integrated Risk Mitigation
01/26/2020
4315913
NRC Question Regarding DOP 7500-01 Limitations and
Actions
02/06/2020
4315913
NRC Question Regarding DOP 7500-01 Limitations and
Actions
02/06/2020
4316185
NRC SRI Question on Procedural Guidance
02/07/2020
4316185
NRC SRI Question on Procedural Guidance
02/07/2020
4316185-02
NRC SRI Question on Procerdural Guidance
02/25/2020
4316326
Review of STI-16-011
02/08/2020
Corrective Action
Documents
Resulting from
Inspection
04329174
NRC DOP 7500-01 Limitations
03/24/2020
26
Drawings
Schematic Diagram High Pressure Coolant Injection
Auxiliary Valves
X
Wiring Diagram Reactor Building 250V DC Motor Control
Center 3 Part 1 (3-83250-3B)
V
13524-DGI-N102
Environmental Zone Map (Basement Floor Plan) Elev.
476'6" Figure 1
5
CCSW Subsystem 1
05
M-374
Diagram of High Pressure Coolant Injection Piping
CX
Miscellaneous
Dresden UFAR
4
Operations Log
01/22/2020 -
01/29/2020
Design
Engineering
0006216498
Dresden Unit 2, HPCI Room Cooler Operability System
Code 1500, 2300, 3900
07/07/2000
Dresden Internal
Flood Evaluation
Summary and
Notebook
Table 3.3.1 Isolation of Standby Systems
4
Letter from
Commonwealth
Edison to A.
Giambusso, U.S.
Atomic Energy
Commissioin
Dresden Station Units 2 and 3 - Special Report No. 37 -
Analysis of Pipe Breaks Outside Containment - AEC
Dockets 50-237 and 50-249
01/23/1974
Procedures
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
32
DIS 2300-06
Unit 3 HPCI Room Temperature Switch Layout
18
DOP 1500-02
Torus Water Cooling Mode of Low Pressure Coolant
Injection System
70
DOP 1500-02
LPCI/CCSW Operation During Transient Situations
70
DOP 6600-05
Diesel Generator 2/3 Startup
42
DOP-1500-03
Containment Spray Cooling Mode of Low Pressure Coolant
Injection System
37
DOS 8300-14
Non-Safety Related 125 VDC and 250 VDC Battery
Surveillance
30
27
Surveillance Test Interval (STI) Change Request
DRE-16-011
0
Dedicated Operator - Proprietary
29
Corrective Action
Documents
4313545
Air Leak on 2A SBO Eng Start Air LB Supply AOV Iso Vlv
01/29/2020
4313609
U2 SBO 'A' Engine Low Oil Temp
01/29/2020
4313832
U2 SBO D/G Lube Oil Temp Proc Enhancement to DOP
6620-16
01/30/2020
4313837
Ops U2 SBO 'A' Diesel Low Jacket Water and Lube Oil T/S
01/30/2020
Drawings
Schematic Diagram Engine A/B 125V DC Starting/Auxiliary
Equipment Station Blackout
A
20600-001
High Pressure Coolant Injection (HPCI) System and
Instrumentation
05
M-4308A
Diesel Generator Starting Air Piping and Instrument Diagram
Station Blackout
B
Miscellaneous
Operations Log
01/29/2020
Dresden 7 Day Schedule
01/27/2020
Procedures
DOS 2300-03
Initial HPCI Standby Lineup
117
DOS 2300-03
High Pressure Coolant Injection System Operability and
Quarterly IST Verification Test
117
DOS 6600-01
Diesel Generator Surveillance Tests
143
DOS 6600-08
Diesel Generator Cooling Water Pump Quarterly and
Comprehensive/Preservice Test for Operation Readiness
and In-Service Test (IST) Program
66
DOS 6620-07
SBO 2 (3) Diesel Generator Surveillance Tests
48
DOS 6620-07
SBO 2(3) Diesel Generator Surveillance Tests
48
Administrative Requirements for Inservice Testing
13
MA-DR-MM-5-
66001
Diesel Generator Post Maintenance Testing Run
19
Work Orders
01002305
D2 12Y PM Diesel Cooling Water Pump Motor Replacement
02/03/2020
01573090
D2 8Y EQ Replace ASCO SOL on DW Purge Valve 1601-56
01/21/2020
04774873
D2 AN COM Replacement Air Start Regulating Valve on
02/03/2020
04829226
Proactive Replacement of U2 EDG Potential Transformer
03/10/2020
04987753
Proactive Replacement of 2-6699-114 Swing Check Valve
03/10/2020
28
Work Orders
05001931
D3 QTR TS (IST) HPCI Pump Operability Test and IST
Surveillance
02/07/2020
05008145
D2 1M TS (IST) Unit Diesel Generator Operability
03/01/2020
Corrective Action
Documents
4308111
DOA 6100-01 Entry for TR2 Cooling
01/05/2020
4308854
4.0 Critique for D2F59 Startup
01/05/2020
Procedures
DOA 5600-01
35
DOA 6100-01
Main Transformer Trouble
37
DOS 1600-10
Drywell Closeout Inspection Plan
51
Start-Up Checklist
20
Calculations
NED-I-EIC-0109
HPCI Pump Discharge Flow Loop Accuracy and Minimum
Flow Setpoints Essential Calc
6
NED-I-EIC-0109
Instrument Uncertainty Calculation for FIC-2(3)-2340-I
6
Corrective Action
Documents
04290376-09
2-1501-5B Valve Failure During DOS 1500-01
12/12/2019
4310164
4.0 Critique U3 HPCI Fast Start Surveillance
01/13/2020
4319355
Fuel Leak on 2/3 B ISO Cond Makeup Pump
02/19/2020
Drawings
M-4203
Flow Diagram Isolation Condenser Make Up System
G
Procedures
DIS 0202-05
Recirc Pump dP Indication and Setpoint Calibration
06
DOS 1300-03
2/3A(B) Isolation Condenser Makeup Pump Quarterly
Operability
26
DOS 2300-03
High Pressure Coolant Injection System Operability and
Quarterly IST Verification Test
117
DOS 2300-07
High Pressure Coolant Injection Fast Initiation Test
45
Unit 2(3)
Appendix B
Assist NSO and Common Unit Daily Surveillance Log
90
Work Orders
01216146
D2 6Y MOV [Motor Operated Valve] Diagnostic Testing &
Limitorque Surv [Surveillance] 2-1501-5B, an Activity
Affecting Quality.
03/03/2015
04795477
D3 8Y PM Recirc Pump DP Indication & Setpoint Cal
03/20/2020
04966573-01
OP D3 QTR TS HPCI Pump Oper Test and IST Surv
01/13/2020
04966573-01
D3 Qtr TS (IST) HPCI Pump Oper Test and IST Surv
01/13/2020
Work Orders
04983344-01
D3 QTR [quarterly] TS [Technical Specification] CS [Core
Spray] Pump Test with Torus Available for IST [In-Service
Test] Data Surv [Surveillance]
02/03/2020
04985748-01
D2/3 1 M TS Unit Diesel Generator Operability
01/06/2020
Corrective Action
04116367
EP-Siren Failure (DR02)
03/19/2018
29
Documents
04145905
EP-Siren Failure (BD10)
06/11/2018
04154129
Siren Failures (DR01, DR06)
07/09/2018
04167408
EP-Siren Failure (BD02)
08/27/2018
04208595
EP- Siren Failure (DR27)
01/07/2019
04223376
EP-Siren Failure (DR09)
02/25/2019
04229307
EP-Siren Failure (BD18)
03/14/2019
04269606
EP-Siren Failure (BD05)
08/05/2019
04292284
Inadvertent Siren Activation Of Will County Sirens
10/29/2019
04294339
EP-Siren Failure (DR01)
11/04/2019
04295174
EP-Will County Siren Controller Failure
11/05/2019
04300920
EP- Siren Failure BD11
12/02/2019
04309736
EP-Siren Failure (DR15,DR22)
02/20/2020
Miscellaneous
Braidwood/Dresden 2018 Warning System Maintenance and
Operational Reports
Braidwood/Dresden 2019 Warning System Maintenance and
Operational Reports
Dresden Generating Station Alert and Notification System
(ANS) Design Report
Corrective Action
Documents
04176439
EP . Drive-In Drill / Off Hours Drill Program Administration
09/24/2018
04176441
EP. Drive-In Drill / Off Hours Drill Facilities and Equipment
09/24/2018
04176442
EP . Drive-In Drill / Off Hours Drill Combined FAC
Comments
09/24/2018
04198974
Individual's ERO FMT Qualification Expiring
11/29/2018
04270502
3rd Quarter TSC inventory Issues
08/08/2019
04271572
3rd Quarter EP Mazon Relocation Center Inventory Issues
08/09/2019
04327348
Field Team Inventory 1Q2020 Items
03/17/2020
Miscellaneous
4th Quarter 2019 Call-In Augmentation Drill Results
12/17/2019
3rd Quarter 2019 Call-In Augmentation Drill Results
09/16/2019
4th Quarter 2018 Call-In Augmentation Drill Results
12/03/2018
Dresden 2018 Drive-In and Off Hours Drill Evaluation Report
08/29/2018
Emergency Response Organization (ERO) - Emergency
Response Facility (ERF) Activation and Operation
22
Corrective Action
Documents
DR-EP-2019-PEX-MCR-FAILED-DCS
06/25/2019
DR-EP-2019-PEX-TSC-FAILED-DCS
06/25/2019
DR-EP-2019-PEX-OSC-FAILED-DCS
06/25/2019
30
DR-EP-2019-NRC-MCR-FAILED-DCS
07/30/2019
DR-EP-2019-NRC-TSC-FAILED-DCS
07/30/2019
DR-EP-2019-NRC-OSC-FAILED-DCS
07/30/2019
Documentation of Completing hh2/155b Requirement
02/11/2020
Miscellaneous
Dresden Letters of Agreement Annual Review List 2019
Standardized Radiological Emergency Plan
33
Radiologicaly Emergency Plan Annex For Dresden Station
38
Self-Assessments NOSA-DRE-18-
03
Emergency Preparedness Audit Report for Dresden Station
04/18/2018
NOSA-DRE-19-
03
Emergency Preparedness Audit Report for Dresden Station
04/24/2019
Calibration
Records
DTS-7500-07
Standby Gas Treatment System Air Filter Unit Performance
Requirements (Methyl Iodide Removal and Charcoal Leak
Test
04/23/2018
MSA Posi3
- L04480
Posi3 USB Test Results; Facepiece/Airline Apparatus Test
06/062019
MSA SCBA FireHawk Monthly Inspection list
11/06/2019
Corrective Action
Documents
Unexpected Condition during SCBA Air Compressor
Preventive Maintenance
02/13/2019
Precautionary Measure for SCBA Bottle from Surveillance
05/02/2019
Drawings
M-49 Critical
Control Room
Drawing
Diagram of Standby Gas Treatment (SBGT)
12
Miscellaneous
NCS Corporation
- 0040599
Radioiodine Penetration/Efficiency Test Records SBGT
03/20/2019
PSI #00473572
Quarterly Service Air and Self-Contained Breathing
Apparatus
10/25/2019
Respiratory Inspection and Certification Log (Monthly
Inspection)
12/04/2019
Calculations
Intake Investigation Form #4513
11/07/2019
Intake Investigation Form #9316
01/09/2019
Intake Investigation Form #023119
01/09/2019
Intake Investigation Form # 040479
01/09/2019
Calibration
Records
NVLAP Lab
Code: 100518
NVLAP Certificate of Accreditation; Landauer, Inc
01/01/2020
Miscellaneous
Declaration of Pregnancy Form #SEGAT6114
09/17/2019
31
Declaration of Pregnancy Form #027354
03/27/2019
Corrective Action
Documents
Resulting from
Inspection
4317754
NRC ID: Cables Running Into Plant by U3 Trackway
02/13/2020
Corrective Action
Documents
04280928
02/20/2020
04290427
Historical Operability Review for DPIS 3-0261-35C
10/23/2019
04326046
Security - Loss of Power Affects EWS Zones/Cameras
03/12/2020
Corrective Action
Documents
Resulting from
Inspection
04319675
The NRC Resident Question of LER -2019-001-00
03/21/2020
Procedures
DOA 0040-03
Loss of Power to Non-Power Block Buildings
18