ML25127A001
| ML25127A001 | |
| Person / Time | |
|---|---|
| Site: | 05000236, Dresden |
| Issue date: | 05/08/2025 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation |
| Shared Package | |
| ML24312A374 | List: |
| References | |
| IR 2025001 | |
| Download: ML25127A001 (1) | |
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 - INTEGRATED INSPECTION REPORT 05000237/2025001; 05000249/2025001 AND 07200037/2025001
Dear David Rhoades:
On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On April 15, 2025, the NRC inspectors discussed the results of this inspection with H. Patel, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or 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.
May 8, 2025
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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000237; 05000249 and 07200037 License Nos. DPR-19 and DPR-25
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Ruiz, Robert on 05/08/25
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RIII RIII NAME NShah:gmp RRuiz DATE 05/07/2025 05/08/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000237; 05000249 and 07200037 License Numbers:
DPR-19 and DPR-25 Report Numbers:
05000237/2025001; 05000249/2025001 and 07200037/2025001 Enterprise Identifier:
I-2025-001-0064 and I-2025-001-0082 Licensee:
Constellation Energy Generation, LLC Facility:
Dresden Nuclear Power Station, Units 2 and 3 Location:
Morris, IL Inspection Dates:
January 01, 2025 to March 31, 2025 Inspectors:
N. Audia, Reactor Inspector B. Lin, Senior Health Physicist J. Meszaros, Resident Inspector M. Porfirio, Illinois Emergency Management Agency C. St. Peters, Senior Project Engineer J. Steffes, Senior Resident Inspector Approved By:
Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety
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. A licensee-identified non-cited violation is documented in report section: 71152A.
List of Findings and Violations No findings or violations of more than minor significance were identified.
Additional Tracking Items None.
3 PLANT STATUS Unit 2 began the inspection period at rated thermal power. On March 7, 2025, power was reduced to approximately 80 percent to perform control rod recovery following scram valve maintenance. The unit returned to rated thermal power the next day. On March 21, 2025, power was reduced to approximately 55 percent to perform scram valve maintenance, rod sequence exchange and 2D condensate/condensate booster pump maintenance. The unit returned to rated thermal power on March 23, 2025, and remained at or near rated thermal power for the remainder of the inspection period.
Unit 3 began the inspection period at rated thermal power. On February 26, 2025, power was reduced to approximately 32 percent to troubleshoot and correct a drywell pneumatic leak and perform rod sequence exchange. The unit was returned to rated thermal power on February 28, 2025, and remained at or near rated thermal power for the remainder of the inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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 71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
Standby liquid control, station batteries, and emergency diesel generators, on January 6 - 10, 2025 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 impending severe weather of high winds and possible tornadic activity on March 14, 2025.
4 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
Unit 2 standby liquid control system on January 6, 2025 (2)
Unit 2 standby diesel generator system on January 8, 2025 (3)
Unit 3 isolation condenser on January 23 - 30, 2025 (4)
Unit 2 isolation condenser during high pressure core injection work window on March 26-27, 2025 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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) 7.0 B, Unit 3 battery room elevation 551', and FZ 6.1, Unit 3 250V battery charger room elevation 538', on January 3, 2025 (2)
FZ 11.2.1, Unit 2 southwest corner room elevation 476', on January 14, 2025 (3)
FZ 6.2, Unit 2/3 comp room and auxiliary electrical room elevation 517', on January 31, 2025 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 7, 2025.
71111.07A - Heat Exchanger/Sink Performance Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
Unit 3 "B" reactor building closed cooling water system heat exchanger 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 control room during the Unit 3 planned downpower and subsequent power ascension due to a drywell pneumatic leak on the 1A MSIV on February 26, 2025 and February 28th, 2025.
5 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated licensed crew performance in the main control room simulator on January 24, 2025.
71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)
Drywell continuous air monitor system, due to failures (2)
Maintenance rule periodic 10CFR50.65 (a)(3) assessment Quality Control (IP Section 03.02) (1 Partial)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)
(Partial)
Unit 2 high pressure coolant injection booster pump fitting repair per Work Order (WO) 5540836 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
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 plant risk review and management action implementation associated with action green and blue fire risks due to planned maintenance on the high pressure coolant injection system on March 25-27, 2025 71111.24 - Testing and Maintenance of Equipment Important to Risk The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (1 Sample)
(1)
Post-maintenance testing followed planned maintenance on the 3C shutdown cooling breaker, per WO 4598872 Surveillance Testing (IP Section 03.01) (2 Samples)
(1)
DIS 0250-02, Main Steam Line Low Pressure Isolation Switch Calibration (Reactor Mode Switch in Run Position), on January 17, 2025
6 (2)
Unit 3 division 2 core spray logic system function test per WO 5350913 on March 20-21, 2025 Inservice Testing (IST) (IP Section 03.01) (2 Samples)
(1)
Unit 2 diesel generator cooling water pump test per WO 5615641 (2)
Unit 2A standby liquid control pump surveillance per WO 5619671 71114.06 - Drill Evaluation Additional Drill and/or Training Evolution (2 Samples)
The inspectors evaluated:
(1)
Focus area drill on January 30, 2025 (2)
Focus area drill on February 4, 2025 OTHER ACTIVITIES - BASELINE 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)
Evaluation and corrective actions for the discolored and contaminated oil, as documented in Action Request (AR) 4790335 and AR 4792117 OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation of An ISFSI Operation of An ISFSI (1 Sample)
(1)
The inspectors evaluated the licensee's independent spent fuel storage installation (ISFSI) cask loading activities from March 17 through March 21, 2025. Specifically, the inspectors observed the following activities during the loading of Multi-Purpose Canister (MPC) No. 840:
heavy load movement of loaded MPC out of the spent fuel pool canister blowdown forced helium dehydration closure welding and non-destructive evaluations radiological field surveys The inspectors performed walkdowns of the ISFSI pads and haul path, which also included performing independent radiation surveys.
7 The inspectors evaluated the following:
spent fuel selected for loading into dry cask storage during this loading campaign selected corrective action program documents selected 72.48 screenings and evaluations changes to the site's 10 CFR 72.212 report since the previous inspection INSPECTION RESULTS Licensee-Identified Non-Cited Violation 71152A This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Technical Specification Section 5.4.1.a. requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 9 addresses Procedures for Performing Maintenance and Section 9.a, addresses maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
The licensee established Procedure MA-AA-716-006, Control of Lubrication Program, Revision 16, to address instructions for the storage, control, use and disposal of lubricants, and provides guidance for oil sampling and analysis. Procedure MA-AA-716-006, Control of Lubrication Program, Revision 16, Step 4.4.3 requires "STORE radiologically clean waste oils/greases in designated containers in appropriate storage rooms, (or other area directed),
for proper disposal at some later date.
Contrary to the above, prior to May 14, 2024, to January 17, 2025, the licensee failed to implement Step 4.4.3 of procedure MA-AA-716-006, Control of Lubrication Program, Revision 16. Specifically, the licensee did not implement the proper storage of lubricants as outlined in MA-AA-716-006, allowing the drum of Mobil DTE 746 to become contaminated with a non-similar oil type and was later added to the upper reservoir for the 2D low pressure coolant injection (LPCI) motor, a safety related component.
Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors answered "NO" to questions A.1. through A.6, and determined that the finding was of very low safety significance (Green).
Corrective Action References: AR 4790335, Mobil DTE 746 Oil Drum - Discolored Oil AR 4792117, Mobil DTE 746 Oil Drum - Discolored Oil (F/U to IR 04790335 AR 4829285, 2D LPCI Motor-Abnormal Oil Samples (F/U to IR 04792117)
8 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 15, 2025, the inspectors presented the integrated inspection results to H. Patel, Plant Manager, and other members of the licensee staff.
On March 31, 2025, the inspectors presented the ISFSI cask loading inspection results to H. Patel, Plant Manager, and other members of the licensee staff.
9 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date DR-0-25-00205 Combined ALARA Plan/Micro-ALARA Plan 02/06/2025 ALARA Plans RP-AA-401 ALARA Work-In-Progress Review 03/21/2025 4500105 NOS ID: HI-Storm Move Sheet for 2020 05/16/2022 4500125 2022 ISFSI NRC Inspection-HI-STAR Cask Degraded Areas 05/16/2022 4501575 2022 Dry Cask Cask #2 Completion 05/23/2022 4777107 Soft Deposits on HI-Storm 100-010 05/29/2024 Corrective Action Documents 4810843 Work Request for Leak Test of HI-TRAC 10/21/2024 Corrective Action Documents Resulting from Inspection 4846657 NRC ID: 2025 Dresden FSP Typographical Error 03/18/2025 Engineering Changes DRE25-0001 Dresden Unit 2 Fuel Selection Packages and Alternate Assembly List for the 2025 SFLC - ISFSI 1
72.48-755 Radiological and Licensing DCR for South ISFSI Expansion Pad 0
72.48-775 Dry Cask Storage/ISFSI Inspection Surveillance Program 0
72.48-777 Implementation of Holtec ECO No. 5014-312 R0 for Storage of Select Foreign Materials in the HI-STORM 100 System via 72.212 Change Requests 22-01 R0 and 22-02 R0 0
72.48-792 Holtec Independent Spent Fuel Storage Installation (ISFSI)
Radiation Survey 0
Miscellaneous 72.48-801 Spent Fuel Casks for the 2025 Loading Campaign (Dresden ISFSI) 0 921227-840-04 Canister Lid to Shell 03/21/2025 921227-840-05 Canister Lid to Drain Port Cover with Setscrews 03/21/2025 921227-840-06 Canister Lid to Vent Port Cover with Setscrews 03/21/2025 NDE Reports 921227-840-07 Canister Shell and Lid to Closure Rings 03/21/2025 Quality Assurance Manual 1
GQP-9.6 Visual Examination of Welds 5
60855 Procedures LS-AA-114 Constellation 72.48 Review Process 5
10 MA-DR-MM 58904 Dry Cask Storage Special Lifting Device Inspection/Testing 11 MA-DR-MM 58003 Visual Inspection and Preventive Maintenance of Unit 1, Unit 2, Unit 3, and Unit 2-3 Overhead and Gantry Cranes 22 NF-AA-622-1000 Fuel Characterization for Dry Storage 11 NO-AA-10 Quality Assurance Topical Report 98 Procedures OU-MW-671-200 MPC Processing Forced Helium Dehydration (FHD) for BWRs 14 2024-215149 Radiological Survey of East ISFSI Pad 04/10/2024 2024-218725 Radiological Survey of West ISFSI Pad 06/04/2024 Radiation Surveys 2025-236614 Radiological Survey of Cask Pad 03/17/2025 Self-Assessments NOSA-DRE 03 Independent Spent Fuel Storage Installation Audit Report 05/25/2022 4946090-01 D2/3 3Y COM ISFSI Integrity Surveillance 08/02/2022 5524566-01 EWP EM D2/3 1Y COM OSHA Insp Crane - Rx Bldg Overhead 02/14/2025 5524566-02 EWP EM D2/3 1Y COM OSHA Insp Crane - Festoon Inspection 02/14/2025 60855 Work Orders 5524567-01 MM D2/3 1Y COM Reactor Building Overhead Crane Inspctn 02/15/2025 4826954 SBLC 3B Relief Valve Line Heat Trace Not Completely on Pipe 01/07/2025 4828014 NRC Questions from Plant Walkdown 01/07/2025 Corrective Action Documents Resulting from Inspection 4845456 NRC Identified Missile Hazards 03/14/2025 Miscellaneous Certification of 2024-25 Winter Readiness 11/15/2024 DOA 0010-02 Tornado Warning/Severe Winds 29 DOA5700-01 Loss of Heating Boilers 29 DOS 0010-22 Preparation for Cold Weather Operations for Unit 2 27 DOS 0010-25 Preparation for Cold Weather Operations for Unit 3 24 OP-AA-108-111-1001 Severe Weather and Natural Disaster Guidelines 30 OP-DR-108-111-1004 Cold Weather Strategy 2
71111.01 Procedures OP-DR-108-111-1006 Intake Blockage Station Response 1
71111.04 Drawings M-173 Diagram of Corrosion Test Diesel Start-up Air Piping BJ
11 M-22 Diagram of Service Water Piping FA M-28 Diagram of Isolation Condenser Piping LS M-33 Diagram of Standby Liquid Control Piping IB M-359 Diagram of Isolation Condenser Piping BR M-40 Diagram of Turbine Building Equipment Drains and Diesel Air Intake And Exhaust ZN M-41 Diagram of Turbine and Diesel Oil Piping AI M-478 Diagram of Diesel Generator Lube Oil Piping J
M-517 Diesel Generator Engine Cooling Water System I
M-518 Diesel Generator Fuel Oil System F
M-974 Diagram of Diesel Generator Room Ventilation L
DOP 1100-01 Standby Operation of Standby Liquid Control System 26 DOP 1100-M1 Unit 2 Standby Liquid Control System Checklist 14 DOP 1300-M1/E1 Unit 3 Isolation Condenser System Checklist 26 DOP 1300-M1/E1 Unit 2 Isolation Condenser System Checklist 22 DOP 6600-01 Diesel Generator 2 Preparation for Standby Operation 34 Procedures DOP 6600-M1 Unit 2 Standby Diesel Generator 30 Calculations DRE97-0105 Determination of Combustible Loading 11 Corrective Action Documents 4835485 4.0 Critique Crew 5 Q1 Announced Fire Drill 02/07/2025 100 Prefire Plan Master Legend Dresden Generating Station Pre-Fire Plan 3
102 U2RB-2 FZ 11.2.1 Unit 2 Southwest Corner Room Eleve. 476' 4
143 U2TB-46 FZ 6.2 Unit 2/3 Comp Room & Auxiliary Electrical Room Elev. 517 4
169 U3TB-79 FZ 7.0 B Unit 3 Battery Room Elev. 551' 5
Fire Plans 169 U3TB-80 FZ 6.1 Unit 3 250V Battery Charger Room Elev. 538' 6
DR-PSA-021.11 Dresden Fire PRA Summary & Quantification Notebook 3
71111.05 Miscellaneous Fire Drill Scenario 25-01 U3 RB 3B Pump Back Compressor Fire 02/04/2025 NDE Reports 3B RBCCW EDDY CURRENT EXAMINATION FINAL REPORT 01/2025 Procedures DTP 75 Heat Exchanger Inspection Program 1
71111.07A Work Orders 5420289 D3 QTR COM REVIEW OF RBCCW OPERATIONAL TREND DATA 02/21/2024
12 5499196 D3 QTR COM REVIEW OF RBCCW OPERATIONAL TREND DATA 05/29/2024 5544001 D3 QTR COM REVIEW OF RBCCW OPERATIONAL TREND DATA 08/21/2024 OBE 25-01A LORT Scenario 0
Miscellaneous OP-AB-300-1003 ReMA Plan D329-005 Unit 3 Shutdown 1
71111.11Q Procedures TQ-AA-155 Conduct of Simulator Training and Evaluation 14 4540536 MRULE A1 Determinations Performed Incorrectly 12/02/2022 4793017 U2 Drywell CAM Inoperable 08/09/2024 4796424 Unit 2 Drywell CAM Low Flow Issue 08/23/2024 4796772 Potential Trend IR: Unit 2 Drywell CAM Equipment Failure 08/26/2024 4812159 Trend IR for U2 DW CAM 10/25/2024 4819082 TRM 3.4.d - 30d Clock Exceeded for U2 DW CAM INOP 11/21/2024 4819869 U2 Drywell CAM Flow Indicator Light is Red 11/26/2024 4824283 U2 Drywell CAM Deemed Inoperable due to Flow Issue 12/17/2024 Corrective Action Documents 4830977 Unit 2 CAM is OOS due to High Flow 01/19/2025 Maintenance Rule Periodic Assessment #15 (10CFR50.65 (a)(3) Assessment) 10/01/2022-09/30/2024 Miscellaneous Maintenance Rule (a)(1) Status Report 02/06/2025 ER-AA-320 Maintenance Rule Implementation Per NEI 18-10 0
Procedures ER-AA-320-1007 Maintenance Rule 18 Periodic (a)(3) Assessment 1
71111.12 Work Orders 5084827-01 NMC Drywell Continuous Air Monitor Preventive Maintenance and Calibration 11/24/2024 OP-AA-108-117 Protected Equipment List 03/25/2025 OP-DR-108-117-1001 Protected Equipment and Pathway Policy 6
71111.13 Procedures WC-AA-101-1006 On-line Risk Management and Assessment 5
71111.24 Procedures DOS 1100-04 Standby Liquid Control System Quarterly/Comprehensive Pump Test for the Inservice Testing Program 55
13 0607027-03 EM EWP Perform Receipt Inspection on 4KV Bkr UTC 0000873998 01/07/2025 4598872 D3 8Y PM 4KV CUB INSP BUS 34-1 CUB 14; 3C SDC PMP 01/14/2025 5396420 TS MSL Lo Press Including Time Delay Relay Cal 01/17/2025 71111.24 Work Orders 5598901 EM Swap 4KV Bkr Bus 34-1, Cubicle 14 (UTC 0000873998) 01/16/2025 1Q2025 FAD Focus Area Drill 02/04/2025 71114.06 Miscellaneous 1Q2025FAD Focus Area Drill 01/30/2025 4790335 Mobile DTE 746 Oil Drum - Discolored Oil 07/29/2024 4792117 Mobil DTE 746 Oil Drum - Contaminated (F/U to IR 04790335) 08/06/2024 Corrective Action Documents 4829285 2D LPCI Motor - Abnormal Oil Samples (F/U to IR 04792117) 01/13/2025 Miscellaneous VETIP Binder #:
D1995 General Electric Tri-Clad Vertical Induction Motors 1
DOS 0040-02 Operator Oil Sampling for Offsite Laboratory Analysis 160 MA-AA-716-006 Control of Lubricants Program 16 MA-AA-716-230-1001 Oil Analysis Interpretation Guideline 23 Procedures MA-AA-716-230-1004 Lubricant Sampling Guideline 5
71152A Work Orders 5160690-01 EM EWP 4Q EQ 2D LPCI PMP MOTOR E.Q. SURV 05/14/2024