ML20342A283
| ML20342A283 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/07/2020 |
| From: | David Curtis NRC/RGN-III |
| To: | Bryan Hanson Exelon Generation Co |
| Shared Package | |
| ML20353A400 | List: |
| References | |
| EA-20-053, EA-20-120 IR 2020090 | |
| Download: ML20342A283 (4) | |
See also: IR 05000237/2020090
Text
December 7, 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 - NRC INSPECTION
REPORT 05000237/2020090 AND 05000249/2020090
Dear Mr. Hanson:
This letter refers to the triennial heat sink inspection conducted from February 10, 2020, to
March 31, 2020, (Inspection Report Nos. 05000237/2020001 and 05000249/2020001) and from
April 1, 2020, to April 24, 2020, (Inspection Report Nos. 05000237/2020012 and
05000249/2020012) at Dresden Nuclear Power Station, Units 2 and 3. The purpose of the
inspection was to monitor licensee performance in accordance with the Reactor Oversight
Process. The results of this inspection were discussed with Mr. P. Karaba, Site Vice President
and other members of your staff on April 24, 2020. The inspection reports provided above can
be found in the NRCs Agencywide Document Access and Management System (ADAMS) at
Accession Nos. ML20133J811 and ML20140A181, respectively. ADAMS is accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
The NRC has determined the apparent violation described in Inspection Report 05000237/2020012; 05000249/2020012 (AV 05000237,05000249/2020012-012) is a Severity
Level IV violation of NRC requirements. The NRC concluded this violation was best
characterized as a Severity Level IV violation based upon example 6.1.d.2 of the Enforcement
Policy dated January 15, 2020, because the violation resulted in a condition which was
previously evaluated as having very low safety significance (i.e., Green) as discussed in the
subject inspection report. Because you initiated condition reports demonstrating objective
evidence of plans to restore compliance, the violation is being treated as a Non-Cited Violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy. The Enforcement Policy is
included on the NRCs Web site at (http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html).
In the letter transmitting Inspection Report 2020012, we provided Exelon with the opportunity to
address the apparent violation identified in the report by either attending a pre-decisional
enforcement conference or by providing a written response before we made our final
enforcement decision. Although Exelon provided a response to the apparent violation in a letter
B. Hanson
2
dated July 2, 2020, "Response to Apparent Violation in NRC Inspection Report 05000237/2020012 and 05000249/2020012; EA-20-053," (ML20184A260) the NRC did not use
the information in the letter to make its final enforcement decision. As stated above, the NRC
made its final enforcement decision solely based upon example 6.1.d.2 of the Enforcement
Policy.
However, while reviewing the information submitted by Exelon, the NRC identified that
10 CFR 50.59 Evaluation 2020-02-001, Update to UFSAR Section 9.2.5.3.1, DOA 0010-01,
and DTS 4450-04, Revision 1, did not consider the plants original design and licensing basis: a
loss of the dam due to a seismic event coincident with a loss of offsite power (LOOP).
Region III inspectors reviewed the design and licensing basis of the facility and consulted with
the Division of Reactor Oversight in the Office of Nuclear Reactor Regulation to determine a
seismically induced dam failure coincident with a LOOP was originally part of the design and
licensing basis for Dresden Station. The NRC will follow up on this issue of concern using either
Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including
Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative
Dispute Resolution Confirmatory Orders, or another baseline inspection effort.
If you contest the violation or the severity of the violation 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.
This letter, its enclosure, and your response, if you choose to provide one, 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. To the extent
possible, your response should not include any personal privacy or proprietary information so
that it can be made available to the Public without redaction.
Sincerely,
David Curtis, Deputy Director
Division of Reactor Safety
Docket Nos. 05000237 and 05000249
License Nos. DPR-19 and DPR-25
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Digitally signed by David
Curtis
Date: 2020.12.07 14:11:07
-06'00'
Package: ML20353A400
NCP-2020-010: ML20342A287
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RIII
RIII
RIII
RIII
NAME
LRodriguez:mb LR
Non-Concur
KStoedter via e-mail
JCameron via e-mail
DCurtis
DATE
11/4/2020
11/5/2020
11/5/2020
12/7/2020
Enclosure
DOCUMENTS REVIEWED
Type
Designation
Description or Title
Revision or
Date
Calculations
DRE16-0011
Required Ultimate Heat Sink (UHS) Capacity
1
Corrective Action
Documents
Resulting from
Inspection
2020 UHS Inspection - 50.59 Apparent Violation
05/19/2020
Drawings
M-194
Outdoor Piping
U
Drawings
M-355
Diagram of Service Water Piping
SQ
Drawings
M-52
Circulating Water Piping Plan
K
Drawings
M-53
Circulating Water Piping Sections
K
Engineering
Changes
631940
Determination of the Volume of Water Contained in Piping
Between the Condenser and the Circ Pumps for a Loss of
Dam Event
0
Engineering
Changes
DFL 12-007
UFSAR Change 12-007
0
Engineering
Evaluations
2012-0067
UFSAR Changes Related to Loss of Dam
0
Engineering
Evaluations
2020-02-001
Update to UFSAR Section 9.2.5.3.1, DOA 0010-01, and DTS
4450-04
1
Miscellaneous
SVPLTR 20-0037
Response to Apparent Violation in NRC Inspection Report 05000237/2020012 and 05000249/2020012; EA-20-053
07/02/2020
Procedures
DGA-12
80
Procedures
DOA 0010-01
Dresden Lock and Dam Failure
37
Procedures
DOP 1300-03
Manual Operation of the Isolation Condenser
38
Procedures
DTS 4450-04
Dresden Credited Ultimate Heat Sink Bathymetric
Surveillance for Intake and Discharge Canals
2