ML23242A188
| ML23242A188 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/06/2023 |
| From: | Jamie Benjamin NRC/RGN-III/DORS/EB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023011 | |
| Download: ML23242A188 (1) | |
See also: IR 05000237/2023011
Text
David Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3
COMPREHENSIVE ENGINEERING TEAM INSPECTION REPORT
05000237/2023011 AND 05000249/2023011
Dear David Rhoades:
On August 4, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Dresden Nuclear Power Station, Units 2 and 3 and discussed the results of this inspection with
Pat Boyle and other members of your staff. The results of this inspection are documented in the
enclosed report.
Three findings of very low safety significance (Green) are documented in this report. Three of
these findings involved violations of NRC requirements. 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.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the
NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3.
September 6, 2023
D. Rhoades
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,
Jamie C. Benjamin, Chief
Engineering Branch 1
Division of Operating Reactor Safety
Docket Nos. 05000237 and 05000249
License Nos. DPR-19 and DPR-25
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Benjamin, Jamie
on 09/06/23
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RIII
RIII
RIII
NAME
JCorujo-Sandin:gmp
DBetancourt-Roldan
JBenjamin
DATE
08/30/2023
08/31/2023
09/06/2023
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000237 and 05000249
License Numbers:
Report Numbers:
05000237/2023011 and 05000249/2023011
Enterprise Identifier:
I-2023-011-0033
Licensee:
Constellation Energy Generation, LLC
Facility:
Dresden Nuclear Power Station, Units 2 and 3
Location:
Morris, IL
Inspection Dates:
July 17, 2023 to August 04, 2023
Inspectors:
C. Baron, Contractor
J. Corujo-Sandin, Senior Reactor Inspector
K. Fay, Reactor Inspector
E. Fernandez, Senior Reactor Inspector
M. Gangewere, Reactor Inspector
J. Gilliam, Senior Reactor Inspector
M. Siddiqui, Reactor Inspector
Approved By:
Jamie C. Benjamin, Chief
Engineering Branch 1
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a Comprehensive Engineering Team 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
Failure to Correct Condition Adverse to Quality after HPCI Test Control Violation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-01
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to
establish measures to assure a condition adverse to quality was corrected. Specifically, the
licensee did not fully correct a violation of 10 CFR 50, Appendix B, Criterion XI, Test Control,
identified in an NRC 2020 Integrated Inspection report. As a result, the portion of the test
control violation related to the failure to account for instrument uncertainty in the High
Pressure Coolant Injection accident analysis or evaluation of surveillance test results
remained uncorrected.
Failure to Identify HPCI Signal Converter Lockout Function
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-02
Open/Closed
[P.5] -
Operating
Experience
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of
Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI,
Corrective Action, due to the failure to identify a condition adverse to quality when
information became available that the HPCI signal converter was installed with a lockout
function that was not evaluated. Specifically, the licensee failed to identify the HPCI signal
converter could lockout on different conditions (i.e., high temperature and high amperage).
This would result in the operators needing to take manual control of the system that is
designed to operate automatically.
Failure to Translate HPCI Room Design Basis Temperature into Surveillance Procedure
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-03
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of
10 CFR 50, Appendix B, Criterion III, "Design Control," when the licensee failed to correctly
translate high pressure coolant injection (HPCI) room design basis initial temperature into the
3
unit daily surveillance log procedure. Specifically, the licensee failed to ensure normal HPCI
room temperature would remain at or below 104 degrees Fahrenheit as assumed in HPCI
room thermal response design calculation and Updated Final Safety Analysis Report
(UFSAR) Environmental Zone 6 normal service temperature.
Additional Tracking Items
None.
4
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21M - Comprehensive Engineering Team Inspection
The inspectors evaluated the following components and listed applicable attributes, permanent
modifications, and operating experience:
Structures, Systems, and Components (SSCs) (IP Section 03.01) (8 Samples)
For each component sample, the inspectors reviewed the licensing and design bases
including: (1) the Updated Final Safety Analysis Report (UFSAR); (2) the Technical
Specifications (TS); and (3) the Technical Requirements Manual (TRM). The inspectors
reviewed a sample of operating procedures (including normal, abnormal and emergency
procedures), overall system/component health (including condition reports and operability
evaluations, if any) and associated maintenance effectiveness (e.g., Maintenance Rule,
procedures). The inspectors performed visual inspections of the accessible components to
identify potential hazards and/or signs of degradation. Additional component specific design
attributes reviewed by the inspectors are listed below.
(1)
Unit 3: 250 Volts Direct Current (VDC) Motor Control Center (MCC) #3 (3-83250-3)
1.
Protection against seismic events
2.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Load testing
b.
TS surveillance
c.
Relay calibration
d.
Terminal corrosion resistance
3.
Electrical design calculations and considerations:
a.
Short circuit calculations
b.
MCC capacity
c.
Degraded voltage
d.
Overcurrent protection
e.
Direct Current (DC) voltage to MCC breakers
(2)
Unit 3: 250 VDC MCC 3A and 3B (3-83250-3A and 3-83250-3B)
1.
Protection against seismic events
2.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Load testing
b.
TS surveillance
c.
Relay calibration
5
d.
Terminal corrosion resistance
3.
Electrical design calculations and considerations:
a.
Short circuit calculations
b.
MCC capacity
c.
Degraded voltage
d.
Overcurrent protection
e.
(3)
Unit 2/3: 250 VDC 2/3 Swing Battery Charger (2/3-83250)
1.
Translation of vendor specifications
2.
Protection against seismic events
3.
Test/inspection procedures, acceptance criteria, and recent results:
4.
Electrical design calculations and considerations:
a.
Duty cycle
b.
Sizing of protective fuses/breakers/relays
c.
Voltage drop calculation
d.
Configuration of electrical distribution
e.
Cable ampacity
(4)
Unit 3: Electromatic Relief Valve (ERV) 3D and 3E (3-0203-3D and 3-0203-3E)
1.
Environmental qualification
2.
Protection against High Energy Line Break (HELB)
3.
Mechanical design calculations and considerations: Relief capacity
4.
Electrical design calculations and considerations:
a.
Solenoid minimum voltage
b.
Control power
c.
Cable ampacity
d.
Voltage drop
e.
Degraded voltage effects
f.
Control logic instrumentation and setpoints
(5)
Unit 2/3: Condensate Storage Tank (CST) 2/3 A and B (2/3-3303-A and 2/3-3303-B)
1.
Protection against external events:
a.
Flooding
b.
Seismic
c.
2.
Mechanical design calculations and considerations:
a.
Available and required volume (Loss of Coolant Accident)
b.
Available and required volume (Station Blackout)
c.
Available and required volume (Feed and Bleed)
d.
Level setpoints
e.
Instrument uncertainty
f.
Design pressure
g.
Overpressure protection (e.g., relief valve or vent sizing)
h.
Temperature limits
i.
Post-accident leakage from Emergency Core Cooling Systems
(ECCS) - impact to Main Control Room (MCR) dose analysis
j.
Heat tracing
3.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Temperature
6
b.
Heat tracing
c.
Volume
d.
Instrument setpoints
e.
TS surveillances
4.
Electrical design calculations and considerations:
a.
Control logic for switchover to recirculation / make-up source
5.
Ultrasonic Testing (UT) Examinations of Tank Bottom
(6)
Unit 3: High Pressure Coolant Injection (HPCI) Pump, Booster Pump, and Turbine
(3-2302, 3-2302-1 and 3-2301)
1.
Environmental qualification
2.
Mechanical design calculations and considerations:
a.
Flow capacity & balance
b.
Minimum flow
c.
Runout flow
d.
Required submergence: net positive suction head (NPSH) and
vortexing prevention
e.
Tank level setpoints and instrument uncertainty
f.
CST vent and/or instrument line freeze protection
g.
Hydraulic transients (water hammer), including flashing in discharge
piping due to reactor coolant system interface
h.
Gas intrusion & accumulation
i.
Room heat up calculations
j.
Room cooling
3.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Pump comprehensive In Service Testing (IST) surveillances
b.
Pump quarterly IST surveillances
c.
TS instrument surveillances
4.
Electrical design calculations and considerations:
a.
Control instruments
b.
Set point calculations
c.
Control voltage
5.
a.
Volumetric Examination of Pressure Retaining Bolts and Studs
b.
Surface examination of pump casing welds
c.
Surface examination of welded attachments
(7)
Unit 3: HPCI Steam Supply Motor Operated Valve (MOV) (3-2301-3)
1.
Environmental qualification
2.
Protection against external events:
a.
Flooding, including sump pump
b.
Seismic
c.
3.
Mechanical design
a.
Weak link analysis
b.
Required thrust (torque)
c.
Pressure locking and/or thermal binding
d.
Closure/Opening time
e.
Maximum allowed leakage
f.
Maximum differential pressure
7
4.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Leakage
b.
c.
Thermal overload testing
d.
TS required surveillance
e.
Leak Rate Testing (LRT)
5.
Motor power requirements:
a.
Voltage drop
b.
Control logic
c.
Control voltage drop
d.
Load flow
e.
Thermal overload
f.
Required minimum voltage
g.
Degraded voltage effects
h.
Brake horsepower
i.
Motor thermal overload protection
j.
Cable ampacity
k.
Protective devices
l.
Emergency power (Emergency Diesel Generator and/or, battery)
6.
ASME Section XI: Surface exam of valve body welds
(8)
Unit 3: HPCI Room Cooler (Heat Exchanger Coil and Fan) (3-5747)
1.
Environmental Qualification
2.
Design calculations and considerations:
a.
Minimum cooling water flowrate
b.
Maximum cooling water temperature
c.
Minimum working fluid flowrate
d.
Maximum working fluid temperature
e.
Tube plugging limit
f.
Fan motor minimum voltage
g.
Fan motor cable ampacity
h.
Control logic
i.
Control circuit voltage Fan motor protective device
j.
Heat transfer capacity
3.
Test/inspection procedures, acceptance criteria, and recent results:
a.
Generic Letter 89-13 visual inspections and cleanings
b.
4.
a.
System pressure test
b.
Visual Testing (VT) examinations of welded attachments
Modifications (IP Section 03.02) (6 Samples)
(1)
Engineering Change (EC) 632912, Revision 0 - HPCI Steam Rupture Disk - Allow
Use of 140 PSIG Rated Set for 3-2301-68 and 3-2301-69
(2)
EC 397957, Revision 7 - Replace HPCI Signal Converter and Flow Indicating
Controller
(3)
EC 629898, Revision 1 - Install HPCI AOP Jumper in 902-3 Panel 2-2302-AOP
(4)
EC 625763, Revision 0 - 3-2301-3 Pressure Locking / Thermal Binding Susceptibility
Remediation
8
(5)
EC 638016, Revision 1 - Containment Cooling Service Water (CCSW) Line
3-1510-16" / Code Repair of Through Wall Leak
(6)
NED-I-EIC-0111, Revision 6 - High Pressure Coolant Injection Steam Line High Flow
Isolation Setpoint Error Analysis
10 CFR 50.59 Evaluations/Screening (IP Section 03.03) (13 Samples)
(1)
Evaluation 2023-01-001 - Replace HPCI Signal Converter and Flow Indicating
Controller
(2)
Screening 2019-099 - Loss of Feedwater Heaters
(3)
Screening 2019-028 - Provide Temporary Cooling to U2 HPCI Room Due to High
Vibes in 2-5747 HPCI Room Cooler
(4)
Screening 2019-036 - Feedwater Regulating Valve (FWRV) Operation
(5)
Screening 2019-039 - Replace CCSW Vault Cooler Cooling Coils U2 Div I
(Coolers A & B)
(6)
Screening 2019-047 - Loss of Heating Boilers
(7)
Screening 2020-014 - High Pressure Coolant Injection System Standby Operation
(8)
Screening 2020-016 - Diesel Generator Cooling Water Pump Quarterly and
Comprehensive/Preservice Test for Operational
(9)
Screening 2021-005 - Unit 2(3) Monthly Station Battery Inspection
(10)
Screening 2022-007 - CCSW Vault Coolers 2C/2D Replacement
(11)
Screening 2022-009 - Calibrate Venturi Feedwater Flow Rate for Unit 2
(12)
Screening 2023-007 - HPCI Signal Converter and Flow Indicating Controller
(13)
Screening 2020-104 - Procedure Enhancement to Take Actions to Secure HPCI to
Prevent Spurious Injection to Ensure Functionality of the Isolation Condenser
System.
Operating Experience Samples (IP Section 03.04) (2 Samples)
(1)
Generic Letter 2008-01 - Managing Gas Accumulation in ECCS, Decay Heat
Removal and Containment Spray Systems
(2)
Information Notice 2009-09 - Improper Flow Controller Settings
INSPECTION RESULTS
Failure to Correct Condition Adverse to Quality after HPCI Test Control Violation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-01
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to
establish measures to assure a condition adverse to quality was corrected. Specifically, the
licensee did not fully correct a violation of 10 CFR 50, Appendix B, Criterion XI, Test
Control, identified in an NRC 2020 Integrated Inspection report. As a result, the portion of the
test control violation related to the failure to account for instrument uncertainty in the High
Pressure Coolant Injection accident analysis or evaluation of surveillance test results
remained uncorrected.
9
Description:
The NRC first quarter Integrated Inspection Report issued on May 11, 2020, (Inspection
Report 05000237/2020001; 05000249/2020001, ML20133J811) identified a 10 CFR 50,
Appendix B, Criterion XI, Test Control, violation, in part, for the licensees failure to account
for instrument uncertainty when establishing acceptance criteria in the High Pressure Coolant
Injection (HPCI) surveillance procedure, DOS 2300-03 High Pressure Coolant Injection
System Operability and Quarterly IST Verification Test, Revision 117. Technical
Specification (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. Procedure DOS 2300-03 step H.5.a and Data
Sheet 2 implemented this TS SR and established acceptance criteria for HPCI flow equal to
or greater than 5,000 gpm. Flow was measured by Flow Controller FIC 2(3)-2340-1.
Calculation NED-I-EIC-0109, Revision 6, Section 15, Conclusions determined average
instrument uncertainty associated with Unit 3 FIC was +/- 254 gpm under normal plant
conditions and +/- 848 gpm under accident conditions.
In response to the test control violation, the licensee entered this issue into their Corrective
Action Program (CAP) as Action Request (AR) 04331189. AR assignments completed a
generic BWR fleet and Dresden specific sensitivity study to approximate built in
conservatisms to Dresdens current licensing basis ECCS evaluation model utilizing
Appendix K to Part 50 ECCS Evaluation Models methodology. These assignments studied
the impact reduced ECCS flow rates had on peak cladding temperature. This AR was closed
on December 16, 2022.
The inspectors reviewed UFSAR Table 6.3-20b for HPCI LOCA (loss of coolant accident)
analysis minimum flow rate and the current accident analysis, ANP-3749P, Dresden
Units 2 and 3 Atrium 10 XM LOCA Break Spectrum Analysis with Increase ADS Flow,
Revision 0. The inspectors noted the HPCI assumed flowrates were both 5,000 gpm and
remained unchanged since the 2020 test control violation was identified. Since the accident
analysis did not account for instrument uncertainty, the inspector verified if TS SR 3.5.1.6
implementing procedure, DOS 2300-03, Revision 119, was revised to evaluate the test
results to ensure HPCI accident analysis flowrate of 5,000 gpm could be achieved. The
inspectors concluded instrument uncertainty was neither accounted for in the design analysis
nor the TS SR implementing procedure and therefore, AR 04331189 corrective actions did
not correct the 2020 test control violation.
The inspectors noted under Work Order 05271158 on September 15, 2022, and Work Order 05096718 on November 18, 2022, the recorded HPCI flow rate for the TS SR test were 5,225
and 5,220 gpm respectively. These were below the required flow rate if instrument
uncertainty was included in the acceptance criteria. The inspector verified Work Order 05128666 on March 3, 2023, achieved a HPCI flow rate greater than the acceptance criteria
plus instrument uncertainty.
Corrective Actions: The licensee entered this issue into their CAP and planned for
engineering to evaluate, determine extent of condition with any additional actions to address,
and communicate any corrective actions applicable to fleet plants. The licensee reviewed
recently performed IST tests which established a flow range acceptance criteria greater than
the TS SR instrument uncertainty and verified IST as-found flow values remained above the
TS SR plus instrument uncertainty value and therefore, Unit 2 and 3 HPCI remained
10
Corrective Action References: AR 04695296, 2023 CETI-NRC ID: Issue with uncertainty not
in ECCS testing.
Performance Assessment:
Performance Deficiency: The licensee's failure to correct a condition adverse to quality was
contrary to 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and was a
performance deficiency. Specifically, when corrective actions to the 2020 test control violation
were closed on December 16, 2022 (under AR 04331189), the licensee failed to account for
instrument uncertainty in the accident analysis or TS SR implementing procedure, to ensure
the analyzed HPCI required flowrate of 5,000 gpm could be achieved.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control 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. Specifically, the current accident analysis, ANP-3749P, Revision 0, design did
not account for instrument uncertainty in the assumed HPCI flowrate, and the analysis
flowrate of 5,000 gpm was directly translated into the TS SR implementing procedure, DOS
2300-03, Revision 119, without accounting for the instrument uncertainty calculated in design
calculation NED-I-EIC-0109, Revision 6. HPCI surveillance test completions under Work
Order 05271158 and 05096718 both failed to stay within the bounds of the accident analysis
design flowrate of 5,000 gpm if instrument uncertainty was accounted for in the procedure.
Therefore, absent TS SR procedural controls, the design margins to ensure the capability of
the HPCI system to mitigate a small break loss of coolant accident, as analyzed in the current
accident analysis, remain vulnerable. This is a concern since Dresdens accident analysis has
transitioned through different nuclear fuel vendors (GE, Westinghouse, and Areva), and
currently no design control measures have ensured the HPCI system would remain within the
bounds of the analysis of record.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the inspectors determined that 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. Specifically, although the inspectors identified
completed surveillance tests outside the bounds of the current accident analysis design if
instrument uncertainty was accounted for, review of additional surveillance tests ensured the
HPCI pump could meet the accident analysis design flow rate if the design margins were
more closely guarded.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe in order to proceed, rather than unsafe in order to stop. As a result of
the test control violation, corrective actions under AR 04331189 completed a sensitivity study
to measure the impact of ECCS reduced flow rate on peak cladding temperature. However,
the corrective actions did not establish measures to account for instrument uncertainty in the
HPCI accident analysis design nor the TS SR implementing procedure to ensure the
assumed design flowrate of 5,000 gpm could be achieved.
11
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in
part, that measures shall be established to assure that conditions adverse to quality, such as
deficiencies, deviations and nonconformances are corrected.
Contrary to the above, as of December 16, 2022, the licensee failed to establish measures to
assure conditions adverse to quality were corrected. Specifically, a non-cited violation of
Appendix B, Criterion XI, Test Control, was identified in a 2020 NRC Integrated Inspection
Report, in part, for the failure to account for instrument uncertainty in the acceptance criteria
of HPCI surveillance procedure DOS 2300-03, High Pressure Coolant Injection System
Operability and Quarterly IST Verification Test, Revision 117. The licensee documented this
violation in their CAP as AR 04331189. This was closed on December 16, 2022, and failed to
establish measures that assured the HPCI system would remain within the bounds of the
analyzed design such that the HPCI flowrate of 5,000 gpm would be achieved if instrument
uncertainty was accounted for in the accident analysis or TS SR implementing procedure.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Identify HPCI Signal Converter Lockout Function
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-02
Open/Closed
[P.5] -
Operating
Experience
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title
10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI,
Corrective Action, due to the failure to identify a condition adverse to quality when
information became available that the HPCI signal converter was installed with a lockout
function that was not evaluated. Specifically, the licensee failed to identify the HPCI signal
converter could lockout on different conditions (i.e., high temperature and high amperage).
This would result in the operators needing to take manual control of the system that is
designed to operate automatically.
Description:
The inspectors reviewed the modification package, 50.59 evaluation, and screening
associated with the licensees replacement of HPCI signal converter which the licensee
installed in March of 2023 on Unit 1 and 2. The purpose of the HPCI signal converter is to
provide positioning signals to the motor gear unit (MGU). When the HPCI system sends a
flow demand change through the flow indicating controller (FIC), the signal converter sends a
signal to the MGU which results in the MGU changing positions and the system flow equaling
to the FIC flow demand. These actions are designed to happen automatically. HPCI is a
safety-related system.
In April 2023, via operating experience from another site, the licensee learned that the HPCI
signal converter was installed with a lockout feature that was not expected. This feature
allows the HPCI signal converter to trip on different conditions (i.e., high temperature and
high amperage). If the HPCI signal converter locks out, the operators would have to take
manual actions to operate the system. Based on the inspectors review it was identified that
12
the licensee had not entered this condition adverse to quality in their corrective action
program to evaluate the impact to their site and implement corrective actions.
After further inspector questions the licensee determined that while they had not experienced
issues with the signal converters lockout feature, their installed design was susceptible to the
failure mode. The inspectors subsequently reviewed licensee provided documentation, such
as training materials, procedures, and the corrective action document written after inspector
identification. Based on the completed review, the inspectors did not identify any concerns
with operability.
Corrective Actions: The licensees current corrective actions are to contact the vendor to
remove the lockout function of the HPCI signal converter and reinstall.
Corrective Action References: AR 04694214, "HPCI Signal Converter Servo Amp Hardening
Opportunity"
Performance Assessment:
Performance Deficiency: The licensee failed to identify a condition adverse to quality when
information became available that the HPCI signal converter was installed with a lockout
function that was not evaluated. This was contrary to 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control 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. Specifically, lockout of the HPCI signal converter would result in the operators
having to take manual action to control HPCI flow which is designed to be an automatic
function and it was not evaluated.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the finding screened as having very low safety significance (green) because they
answered 'yes' to the questions: If the finding is a deficiency affecting the design or
qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality.
The inspectors determined the finding did not cause a loss of PRA functionality.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and
effectively collects, evaluates, and implements relevant internal and external operating
experience in a timely manner. Specifically, the licensee became aware of Operating
Experience associated with their HPCI signal converter modification in April 2023 and did not
enter the condition adverse to quality in the corrective action program.
Enforcement:
Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,
Criterion XVI, Corrective Action, states, in part, measures shall be established to assure that
conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations,
defective material and equipment, and nonconformances are promptly identified and
corrected.
Contrary to the above, from April 15, 2023 to August 2, 2023, the licensee failed to identify a
13
condition adverse to quality. Specifically, the licensee became aware of a previously
unevaluated installed lockout feature associated with the HPCI signal converter, a deficiency,
and did not enter the condition adverse to quality into the corrective actions program.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Translate HPCI Room Design Basis Temperature into Surveillance Procedure
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000237,05000249/2023011-03
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10
CFR 50, Appendix B, Criterion III, "Design Control," when the licensee failed to correctly
translate high pressure coolant injection (HPCI) room design basis initial temperature into the
unit daily surveillance log procedure. Specifically, the licensee failed to ensure normal HPCI
room temperature would remain at or below 104 degrees Fahrenheit as assumed in HPCI
room thermal response design calculation and UFSAR Environmental Zone 6 normal service
temperature.
Description:
Dresden Power Station had a safety-related High Pressure Coolant Injection (HPCI) system
to provide core cooling under loss-of-coolant-accident (LOCA) conditions which do not result
in rapid depressurization of the reactor pressure vessel. The HPCI system consisted of steam
driven pumps, piping, and valves to transfer water from the suction source to the reactor core.
The HPCI room was equipped with a room cooler and fan to maintain HPCI room
temperature at acceptable levels during prolonged operation. During normal operation, the
room cooler was cooled by non-safety service water (SW). The Containment Cooling Service
Water (CCSW) system provided a safety-related back up source of cooling water to the room
cooler to keep the HPCI room from reaching the automatic isolation temperature setpoint of
173 +/- 5 degrees Fahrenheit and to maintain its Environmental Qualification (EQ)
temperature requirements.
The inspectors reviewed HPCI EQ requirements and associated exemptions. UFSAR Section
3.11.1.4.1 Harsh Post-Accident Areas stated, exception to above 120 degrees Fahrenheit
definition is taken for the HPCI Rooms where the peak temperature resulting from a LOCA is
127 degrees Fahrenheit with room coolers and 134 degrees Fahrenheit without room coolers
and the environment is considered mild. UFSAR Table 3.11-1 Environmental Zone
Parameters for Normal Service Conditions established the temperature for Zone 6, including
HPCI rooms, as 104 degrees Fahrenheit. The inspectors reviewed design calculation
DRE98-0077, Dresden HPCI Room Thermal Response with Reduced Room Cooler
Capability Essential Calc, major revision 001 issued June 18, 2004. This is the current
design bases calculation of record. The calculation concluded peak room temperatures
during continuous operation of HPCI turbine was 127 degrees Fahrenheit when CCSW flow
to the room cooler was initiated after 600 seconds and 134 degrees Fahrenheit after four
hours without the room cooler or fan operating. These temperatures agreed with the UFSAR
credited EQ temperature exemptions.
14
The inspectors reviewed DRE98-0077 minor revision 001C issued February 28, 2018, and
noted changes that decreased available design margins. For example:
Minor revision 001C concluded total tube plugging limit for HPCI room cooler was
14 tubes based on 20 GPM CCSW flow to maintain the EQ basis for equipment in the
HPCI Room. Eddy Current Testing under Work Order 05142242 on March 2, 2023,
determined 39 tubes exceeded the predetermined tube plugging criteria of 70%. The
14 tubes that exceeded 90% tube plugging criteria were plugged and the inspection
interval was shortened from 2 years to 1 year. Increased tube erosion was attributed
to running non-safety SW at double the heat exchanger design flowrate.
Superseded calculation, RSA-D-92-06 HPCI Room Thermal Response with Loss of
HPCI Room Cooler at Dresden Station revision 0 assumed a fan flow rate of 4750
cfm. In contrast, DRE98-0077 used the fan name plate rating of 4950 cfm. No
surveillances to verify the rated flow were performed.
Relative humidity from DRE98-0077 revision 001 to 001C changed from 95% to 0%.
AR 04518422 U3 HPCI Room Coolers was reviewed which noted potential steam
leaks in the U3 HPCI room.
Based on the above, the inspectors were concerned that decreased margins in HPCI room
thermal response could impact conclusions in calculation DRE98-0077 and therefore, HPCI
room EQ requirements. Specifically, a DRE98-0077 assumption stated, in part, initial room
temperature is at 104 degrees Fahrenheit. This assumption was first established in revision
0 of the calculation issued on April 10, 1998. To validate this assumption, the inspectors
reviewed Unit 2 (3) Appendix A, Unit Daily Surveillance Log, Revision 146. The surveillance
procedure directed operators to maintain HPCI room temperature less than 100 degrees
Fahrenheit however, it directed operators to operate the HPCI room cooler as necessary to
reduce the temperature to less than or equal to 120 degrees Fahrenheit and then HPCI may
be declared operable with no additional testing. This would invalidate the calculation design
initial temperature assumption and Environmental Zone 6 normal service temperature. During
an event requiring prolonged HPCI operation, exceeding the initial room temperature of
104 degrees Fahrenheit would cause higher than the peak 127 and 134 degree temperatures
that current design bases calculation analyzes for, and exceed the temperatures that exempt
the HPCI room from EQ harsh temperature requirements. Failure to translate the HPCI
design basis initial temperature into the surveillance log procedure was determined to affect
both Unit 2 and 3.
Inspectors also noted operators would not receive a control room alarm until HPCI room
temperature reached 110 degrees Fahrenheit. The inspectors reviewed past condition reports
and confirmed the HPCI room temperature had exceeded the design basis initial temperature
of 104 degrees Fahrenheit as documented in AR 01245549.
Corrective Actions: The licensee entered this issue into their Corrective Action Program and
planned to review HPCI room temperature design basis and evaluate appropriate
recommendations to review HPCI room cooler calculations and/or operations procedure. The
licensee determined no compensatory actions were currently needed based on shiftily
monitoring of room temperature, and available historical calculation information to support
continued HPCI operability.
Corrective Action References: AR 04694742, "2023 CETI - HPCI Room Temp Calc and
Procedure Discrepancies.
15
Performance Assessment:
Performance Deficiency: The licensee's failure to correctly translate HPCI room design basis
initial temperature assumptions into the Operations daily surveillance log procedure
acceptance criteria was contrary to 10 CFR 50 Appendix B, Criterion III, "Design Control,"
and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Procedure Quality 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. Specifically, failure to translate HPCI room design basis temperature into the
surveillance log procedure failed to ensure design assumptions would remain valid. The Unit
Daily Surveillance Log Unit 2 (3) Appendix A would allow the HPCI room temperature to
reach 120 degrees Fahrenheit. This would invalidate an initial assumed HPCI room
temperature of 104 degrees Fahrenheit in the design calculation and UFSAR Environmental
Zone 6 normal service temperature which would prevent exceeding peak room temperatures
of 127 and 134 degrees Fahrenheit to protect HPCI from reaching the automatic isolation
setpoint temperature, and to exempt the HPCI room from EQ harsh environment
requirements.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the finding screened to Green (very low safety significance) because it did not
result in the loss of operability or functionality. This was based on shiftily monitoring of room
temperature, and available historical calculation information to support continued HPCI
operability.
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 50 Appendix B, Criterion III, "Design Control," requires, in part, that
measures shall be established to assure that applicable regulatory requirements and the
design basis are correctly translated into specifications, drawings, procedures and
instructions.
Calculation DRE98-0077, Dresden HPCI Room Thermal Response with Reduced Room
Cooler Capability Essential Calc, Revision 001 establishes the HPCI room design basis
temperature response and assumes an initial HPCI room temperature of 104 degrees
Fahrenheit.
UFSAR Table 3.11-1, Environmental Zone Parameters for Normal Service Conditions,
establishes Zone 6 temperature as 104 degrees Fahrenheit, which includes the HPCI rooms.
Procedure Appendix A, Unit Daily Surveillance Log Unit 2 (3), Revision 146, include HPCI
room temperature acceptance criteria which state, in part, operate HPCI room cooler as
necessary to reduce the temperature to less than or equal to 120 degrees Fahrenheit. When
the temperature is less than or equal to 120 degrees Fahrenheit, then HPCI may be declared
operable with no additional testing required.
16
Contrary to the above, as of April 10, 1998, the licensee failed to assure that applicable
regulatory requirements and the design basis were correctly translated into specifications,
drawings, procedures, and instructions. Specifically, acceptance criteria in Operations
procedure Appendix A failed to ensure the HPCI room would be maintained at or below the
assumed initial design basis temperature of 104 degrees Fahrenheit established in
calculation DRE98-0077 and UFSAR Table 3.11-1.
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 August 4, 2023, the inspectors presented the Comprehensive Engineering Team
Inspection results to Pat Boyle and other members of the licensee staff.
On August 3, 2023, the inspectors presented the Technical Debrief inspection results to
Jason Biegelson and other members of the licensee staff.
17
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
7927-52-19-2
Calculation for 250VDC Circuit Coordination Interaction for
Appendix R
B
ANP-3749P
Dresden Units 2 and 3 Atrium 10XM LOCA Break Spectrum
Analysis with Increased ADS Flow
0
CE-DR-011
Weak Link Analysis for Crane 10 Gate Valve 2(3)-2301-3
5
DR-721-M-003
The Emergency Air Cooler Coil Performance Evaluation for
the HPCI Turbine/Pump Rooms
0
DR-CID-52
Accuracy of the Contaminated Condensate Storage Tank
(CST) Level Indication Loops
1
DRE-0124
Dresden HPCI NPSH Temperature Limits
1
DRE-3-2301-3
DC Motor Operated GL96-05 Gate Valve
7
DRE-3-2302-1
Rising Stem Motor Operated Valve Data Sheet
7
DRE00-0054
HPCI Condensate Storage Tank Level Error Analysis
0
DRE01-0041
Updated EQ Zone Parameter Tables Following
Implementation of Extended Power Uprate
3
DRE01-0070
Seismic and Environmental Qualification of the 250VDC
MCC Components
0
DRE03-0015
HPCI MOV Design Basis Document and Differential
Pressure Calculation
0A, 0C
DRE18-0010
Dresden Unit 2 and 3, 250 VDC System Analysis
2
DRE96-0206
HPCI Pump Discharge Pressure for 5000 GPM Flow to
Reactor Vessel
1
DRE96-0215
Pressure Drop Analysis for HPCI Exhaust Steam Piping
1
DRE97-0063
HPCI Turbine Pump Room Cooling Load Calculation
1A
DRE97-0145
Maximum Flow Through the LPCI and HPCI Pump Minimum
Flow Lines
2A
Calculations
DRE97-0170
Dresden HPCI Room Thermal Analysis Loss of Room
Cooler
0
18
DRE98-0030
Determination of Setpoint of CST LOW-LOW Level Switches
to Prevent Potential Air Entrainment from Vortexing During
HPCI Operation
0A, 0B, 0C
DRE98-0033
Unit 3 Reactor Building MCCS Thermal Overload Heater
Sizing
2
DRE98-0077
Dresden HPCI Room Thermal Response with Reduced
Room Cooler Capability
1, 1C
DRE98-0200
Qualification of Support for CST Pressure Switches
0
DRE99-0013
Hydraulic Performance of the HPCI System
2, 2D
NED-I-EIC-0109
High Pressure Coolant Injection (HPCI) Pump Discharge
Flow Loop Accuracy and Minimum Flow Set Points
6, 6A
NED-I-EIC-0111
High Pressure Coolant Injection (HPCI) Steam Line High
Flow Isolation Setpoint Error Analysis
6
NF-BEX-13-68-P
LOCA Analysis for SVEA-96 OPTIMA2 Fuel
0
Calculations
RSA-D-92-06
HPCI Room Thermal Response with Loss of HPCI Room
Cooler at Dresden Station
0
1245549
U3 HPCI Room Temperature
07/29/2011
3988159
2-2301-3 U2 HPCI Turb Stm Supply MOV Did Not Open
03/22/2017
4109028
HPCI Room Cooler Tube Plugging
02/27/2018
4159025
Verification of HPCI Room Cooler Airflow Needed
07/26/2018
4221994
Step Increase in Vibration Levels on U2 HPCI Room Cooler
02/20/2019
4272562
OP-DR-102-106 Requires Revision
07/03/2019
4293954
Unit 2 HPCI AOP Failed to Stay Running
11/02/2019
4315614
NRC Question on DOS 2300-03 Acceptance Criteria
02/05/2020
4329276
3D ERV Tailpipe Temp Rise
03/24/2020
4331189
NRC: Procedures and Instrument Uncertainty
03/31/2020
4332151
Strengthen Procedures Involving Torquing
04/02/2020
4348755
U3 HPCI Bearing #2 Vibes Greater than 3 mils
06/11/2020
4360154
07/31/2020
4362710
3D ERV Stroking Issues
08/12/2020
4382882
D3R26 - Steam Leak from HPCI Rupture Disc
11/07/2020
4450012
Contingency WO for Timer Relay Replacement for 2/3
250VDC Battery Charger
10/01/2021
4518422
U3 HPCI Room Concerns
08/23/2022
Corrective Action
Documents
4541698
U1 HPCI MGU Abnormal Indications During Signal
12/09/2022
19
Converter Cal
4542053
HPCI Signal Converter Servo Amplifier Fault Light Lit
12/11/2022
803865
Dresden Actions in Response to NRC GL 2008-01
08/05/2008
4691022
50.59 Screening Paperwork Supplemental Record Needed
07/17/2023
4691172
CETI 2023 - UFSAR 8.1.2 Requires Revision
07/18/2023
4691637
2023 CETI: ASME Code Related Component ISI/ANI
Documentation
07/20/2023
4691644
Missing Screws on Junction Box 3RB-53
07/20/2023
4691683
CETI 2023: FG 3-2301-70
07/20/2023
4691903
2023 CETI - EC404291 and 50.59 Documents Require
Revisions
07/21/2023
4691908
2023 CETI EC 404290 IP-ENG-001 Form 2 has Typo Error
07/21/2023
4694214
HPCI Signal Converter Servo Amp Hardening Opportunity
08/02/2023
4694498
Conflict Between ISI and IST Documents
08/03/2023
4694742
2023 CETI - HPCI Room Temp Calc and Procedure
Discrepancies
08/04/2023
Corrective Action
Documents
Resulting from
Inspection
4695296
2023 CETI-NRC ID: Issue with Uncertainty Not in ECCS
Testing
08/08/2023
12E-3462 Sheet 1
Schematic Diagram Auto Blowdown Part 2
AH
12E-3462 Sheet 3
Schematic Diagram Auto Blowdown Electromatic Relief
Valve 203-3E and 203-3D
AG
21800-001
Unit 2 ADS Initiation Logic
1
DRE206LN001
Fig 10
Circuits Initiation Trip Reset
6
M-310 Sh 62
Instrument Installation Details - Condensate System
4
M-35 Sh 1
Diagram of Demineralized Water System Piping
ER
M-374
Diagram of High Pressure Coolant Injection Piping
CZ
M-4456
HPCI Room Cooler Drip Pan & Support Structure
A
Drawings
M-51
Diagram of High Pressure Coolant Injection Piping
CX
2019-014
Loss of Heating Boilers
0
2019-036
Feedwater Regulating Valve (FWRV) Operation
0
2019-039
Replace CCSW Vault Cooler Cooling Coils-U2 DIV 1
(Coolers A&B)/EC 404290
0
2020-016
Diesel Generator Cooling Water Pump Quarterly Test
0
Engineering
Changes
2021-005
Unit2(3) Monthly Station Battery Inspection
0
20
2022-009
Calibrate Venturi Feedwater low Rate for Unit 2
0
357611
HPCI Inputs Validated for LOCA Analysis
11/16/2006
360968
Evaluation of Potential Secondary Containment Bypass
During HPCI Pipe Breach
05/12/2006
371153
NRC GL 2008-01 HPCI System Evaluation
11/24/2012
397957
Replace U3 HPCI Signal Converter and Flow Indicating
Controller
7
404291
Replace CCSW Vault Cooler Cooling Coils - U2 - Division 2
0
448508
Provide Torque Value for HPCI Rupture Discs (2(3)-2301-68
& -69) with Fully Lubricated Flange Bolts
11/02/2020
627314
Provide Temporary Supplemental Cooling to U2 HPCI Room
Due to 2-5747 U2 HPCI Room Cooler High Vibes
0
629898
Install HPCI AOP Jumper in 902-3 Panel 2-2302-AOP
1
632912
HPCI Steam Rupture Disk - Allow Use of 140 PSIG Rated
Set.
0
638016
CCSW Line 3-1510-16"/Code Repair of Through Wall Leak
1
2023-01-001
Modification to Install Alternate HPCI Signal Converter to
Replace Functions of 2(3)- 2386 with 2(3)-2386A
0
386611
Evaluation of HPCI Room Cooler (2-5747) Safety-Related
Cooling Water Requirements
11/09/2011
6216498
Dresden Unit 2 HPCI Room Cooler Operability
07/07/2000
633963
Evaluation of ECCS Instrument Uncertainties Impact on
ECCS-LOCA Analysis
06/23/2021
6N3917
Generic ECCS Flow Reduction SAFER Sensitivity Study
0
Engineering
Evaluations
CMED-057604
Evaluation of the Functional Capability of Components
Located in Dresden Unit 3 EQ Zones 4, 5, 6 for Elevated
Temperature Resulting from Loss of Room Coolers
1
08-22
Permanent Scaffold Request Form
04/09/2008
13659-M1
Installation, Operation, and Maintenance Manual for HPCI
Signal Converter Nutherm Model 73315
1
Miscellaneous
2006-0256
50.59 Screening - Implement WestinghouseOptima2
Nuclear Fuel - Impact on Alternate Source Term (AST)
Bases
0
21
2023-007
Replace U2(3) HPCI Signal Converter and Flow Indicating
Controller
0
21A5779
Data Sheet for Auxiliary Steam Turbine Drives (HPCI
System)
1
257HA353AB
High Pressure Coolant Injection System Data Sheets
3
970321F
Dresden Nuclear Power Station Units 2 and 3 Evaluation of
Methods to Address ECCS Flow and Pressure
Measurement Uncertainties
03/21/1997
Bulletin 77-3001I
BS&B Installation Instructions Type B and D Rupture Disks
09/01/2000
D1596
Vendor Manual for Model 2539 Controller
0
D1622, Vol II
Battery Charger Vendor Manual
2
DBD-DR-001
High Pressure Coolant Injection System - 5.9.1 HPCI Safety
Head (Rupture Disc)
A
DOA 3500-02
50.59 Screening Loss of Feedwater Heaters
48
DRE22-0006
Operation Manual Action Timeline Analysis
06/22/2023
ED-100D
ERV Actuator, General Electric Model 352B2632G001, Used
with the Dresser 1525VX Electromatic Relief Valve
1
GE-NE-A22-
00103-33-01
Task T0404: High Pressure Coolant Injection System
0
GEK-26901
Instrumentation Subsystem of the Dresden 2 High Pressure
Coolant Injection (HPCI) System Vendor Technical Manual
0
IST-DRE-BDOC-
V-15
Inservice Testing Basis Document 2-2301-20
07/27/2003
IST-DRE-BDOC-
V-15
Inservice Testing Basis Document 3-2301-6
01/26/2015
IST-DRE-BDOC-
V-15
Dresden - Inservice Testing Bases Document
07/19/2023
NA
Inservice Testing (IST) Program Plan
5
OPXR 00935420-
02
IN 2009-09 Response
09/23/2009
Supplement to GE-14 Fuel License Amendment Request
03/01/2001
Miscellaneous
UFSAR Change
06013
Dresden Units 2 & 3 UFSAR Change under Design Change
Package 350134
10/23/2006
Configuration Change Control for Permanent Physical Plant
Changes
2
Procedures
Temporary Configuration Changes
31
22
Process for Managing Plant Modifications Involving Digital
Instrumentation and Control Equipment and Systems
9
DAN 902(3)-3 C-7
Unit 2 (3) HPCI Auto Isol Initiated
14
DAN 902(3)-3 E-
12
3E Electromatic Relief Vlv OPEN
18
DAN 902(3)-6 A-5
Cond Storage Tank Lvl HI-LO
19
DAN 923-5 H-4
Reactor Building Ventilation System
13
DEOP 0100-00
Reactor Pressure Vessel Control
14
DEOP 0400-06
Alternate RPV Level-Pressure Control
0
DEOP 0500-02
Bypassing Interlocks and Isolations
23
DEOP 0500-07
Alternate Emergency Depressurization Systems
2
DES 8300-01
Inspection and Maintenance of DC-Operated Cutler-
Hammer Reversing and Field Contactors Model 912 and
952 and MODEL ME
15
DGA-12
80
DGA-22
Station Blackout
4
DIS 0250-05
ADS Valve Auto-Actuation abd Loss of Control Power Logic
Test
51
DMP 2300-14
HPCI Rupture Disc Maintenance
9
DOA 2300-02
HPCI Fast Startup
12
DOC 2300-03
High Pressure Coolant Injection System Operability and
Quarterly IST Verification Test
119
DOS 0250-07
Electromatic Relief Valve Testing with the Reactor
Depressurized
6
Use of Operating Experience for License Renewal
Implementation/Aging Management
6
ER-DR-200-201
Periodic Monitoring for Gas Accumulation in ECCS Systems
8
IP-ENG-001
Standard Design Process (EB-17-06)
3
Exelon 50.59 Review Process
12
MA-MW-726-022
Electrical Cable Termination and Inspection
14
NES-MS-04.1
Seismic Prequalified Scaffolds
7
Operator Response Time Program
8
OP-DR-102-106
Operator Response Time Program at Dresden
14
Unit Daily
Surveillance Log
Unit 2 (3) Appendix A
146
23
00507529
Battery Charger 2/3 10Y PM Replace All Vendor
Recommended Components
01/16/2014
00654428
D2 6rFL COM HPCI TURB Dismantle
11/17/2015
01227541
10Y COM PM Internal Inspection of CCST-B Tank Bottom
01/22/2015
01423636
00007025-01, PMSR, D3 6Y PM 250VDC BKR 2301-3 HPCI
Steam Supply VLV, E: 3-83250-3BK2, MCCA, M05
03/02/2018
01430387-01
D3 8Y COM HPCI Lube Oil Cooler INSP/CLEAN/EDDY
CURRENT TEST
02/26/2019
01592255-01
D3 8Y PM Replace HPCI Room Cooler Cooling Coil
05/03/2019
01805281-01
EWP D2/3 5Y COM PM Inspection of CCST A Tank
05/02/2019
01911751-08
EWP EM Install/Remove Temp Power to 20 Ton HVAC Unit
02/20/2019
04570331
D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During
Startup
11/12/2018
04877127
Replace 3D Electromatic Relief Valve
11/10/2022
04880337
TS D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During
Startup
11/07/2020
04894499
TS D3 QTR TS HPCI Pump Comprehensive Oper Test and
IST Sur
02/24/2021
04921734-01
EWP D3 2Y Com Open/Clean/Insp/Eddy Current HPCI Rm
Clr Coil
02/24/2021
04921737-01, 02
EWP EM Post-OOS Portion of Clr Fan Mtr HPCI Rm
02/23/2021
04975780
Unit 2 HPCI AOP Failed to Stay Running
11/02/2019
05068923
Replace Relay 3-0287-114D
08/13/2020
05095264
D3 RFL PM Electromatic Relief E Replace Pilot
11/08/2022
05096712
D3 RFL ED Eng W/D Perm Scaffold
11/18/2022
05096718
TS D3 24M/RFL TS HPCI LP Sys Oper Verif (DS 2) During
Startup
11/18/2022
05107156-01
24 Month 250VDC 2/3 Battery Charger Four Hour Load Test
01/06/2023
05124083
D3 RFL PM Maint-Surv on 3-203-3D Electromatic
11/16/2022
05125118
D3 RFL PM Maint-Surv on 3-203-3E Electromatic
11/14/2022
05128666
TS D3 2Y TS (IST) HPCI Pump Comprehensive Oper Test
and IST Sur
03/03/2023
05130803-01
D3 2Y PM HPCI Rm Cooler Fan Motor Bridge/Meg Cln Insp
Belt Re
03/01/2023
Work Orders
05142242-01, 04
MM EWP 2Y Com Open/Clean/Insp/Eddy Current HPCI
03/02/2023
24
05235883-01
EWP MM D3 SA PM Fan Brgs HPCI Pmp Room
Clg - Grease Fittings
08/23/2022
05271158
TS D3 QTR TS (IST) HPCI Pump Oper Test and IST Surv
09/15/2022
05287575-01
D3 SA PM Fan Brgs HPCI Pmp Room Cooler - Grease
Fittings
02/22/2023
05303110
TS D3 QTR TS (IST) HPCI Pump Oper Test and IST Surv
11/19/2022
05312584-01
ASME Section XI Repair/Replacement Plan
06/15/2023
05355681
TS D3 31D TS HPCI Disch Piping Water Solid Verification
05/17/2023
05366756
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