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NRC Integrated Inspection Report 05000237/2016002; 05000249/2016002; 07200037/2016001
	ML16207A413
Person / Time
Site:	Dresden
Issue date:	07/25/2016
From:	Jamnes Cameron; Reactor Projects Region 3 Branch 4
To:	Bryan Hanson; Exelon Generation Co
References
	IR 2016001, IR 2016002
	Download: ML16207A413 (59)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 July 25, 2016

Mr. Bryan Senior VP, Exelon Generation Company LLC President and CNO, Exelon Nuclear 4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3-NRC INTEGRATED INSPECTION REPORT 05000237/2016002; 05000249/2016002; 07200037/2016001

Dear Mr. Hanson:

On June 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed report documents the results of this inspection, which were discussed on June 30, 2016, with Mr. P. Karaba, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The enclosed report documents the results of this inspection.

Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (green). The NRC has also determined that one violation is associated with this issue. Because the licensee initiated a condition report to address this issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. This NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, 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: (1) the Regional Administrator, Region III; (2) the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the NRC Resident Inspector at the Dresden Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the Dresden Nuclear Power Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"

of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes Cameron, Chief

Branch 4 Division of Reactor Projects Docket Nos. 50-237; 50-249;72-037 License Nos. DPR-19; DPR-25

Enclosure:

IR 05000237/2016002; 05000249/2016002; 07200037/2016001

REGION III Docket Nos: 05000237; 05000249; 07200037 License Nos: DPR-19; DPR-25 Report No: 05000237/2016002; 05000249/2016002; 07200037/2016001 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Dates: April 1, 2016 through June 30, 2016 Inspectors: G. Roach, Senior Resident Inspector R. Elliott, Resident Inspector

N. Fields, Health Physicist, MCID, DNMS T. Go, Health Physicist M. Learn, Reactor Engineer, MCID, DNMS R. Ruiz, Senior Resident Inspector, LaSalle County Nuclear Generating Station E. Sanchez-Santiago, Resident Inspector, Clinton Power Station J. Seymour, Operations Engineer C. Zoia, Operations Engineer (Lead) Approved by: J. Cameron, Chief Projects Branch 4 Division of Reactor Projects

SUMMARY

Inspection Report 05000237/2016002, 05000249/2016002, 07200037/2016001; 04/01/2016 - 06/30/2016; Dresden Nuclear Power Station, Units 2 & 3; In-Plant Airborne Radioactivity Control and Mitigation. This report covers a 3-month period of inspection by resident inspectors; announced baseline inspections by regional inspectors; and an inspection by regional inspectors of operational activities associated with an Independent Spent Fuel Storage Installation (ISFSI) at the Dresden Nuclear Power Station, Units 2 and 3. One Green finding was identified by the inspectors. The finding involved a Non-Cited Violation (NCV) of the U.S. Nuclear Regulatory Commission (NRC)requirements. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated February 2014.

Cornerstone: Occupational Radiation Safety

Green.

A finding of very-low safety significance and an associated NCV of Title 10 of the Code of Federal Regulations (CFR), Part 20.1703, was an NRC-identified finding for failure to implement and maintain written procedures regarding breathing air quality that resulted in the failure to perform a continuous in-line breathing air quality test during filling of self-contained breathing apparatus (SCBA) cylinders since 2009. Specifically, on May 4, 2016, during an inspection of the licensee's air compressor, the inspectors identified that the in-line carbon monoxide (CO) detector located at the compressor high-pressure filling station was inoperable since 2009, the procedure does not specify an alternative method of CO monitoring during the filling of the SCBA cylinders. Without specifying an alternative method of monitoring and only relying on the high-temperature safety shut-off, hazardous CO gas could be introduced into the SCBA cylinders, thus degrading the Grade-D air quality, during a compressor malfunction. The licensee's corrective actions included but were not limited to revising the applicable procedures, servicing or replacing the CO monitor by the manufacturer, and installing a new air compressor at the facility. The inspectors determined that that the finding was more than minor in accordance with Inspection Manual Chapter (IMC) 0612, in that the finding impacted the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation through the use of SCBAs during an emergency response use by maintaining certified air quality. Specifically, the licensee failed to implement and maintain written procedures regarding an alternative method of monitoring air quality testing to maintain the Grade-D air quality during filling of SCBA cylinders. The finding was determined to be of very-low safety significance in accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," because it was not an as-low-as-reasonably-achievable planning issue, there was no overexposure nor substantial potential for an overexposure, and the licensee's ability to assess dose was not compromised.

3 The inspectors concluded that the cause of the issue involved a cross-cutting component in the area of human performance, resources, in that, the license did not ensure the adequacy of the procedure describing the alternate methods of CO monitoring during filling of Grade D air into the SCBA cylinders. [H.1] (Section 2RS3).

4

REPORT DETAILS

Summary of Plant Status Unit 2 Unit 2 began the inspection period at full power. On May 18, unit output was briefly reduced to 940 MWe (96 percent reactor power) to insert control rod P-08 for maintenance. A down power to 190 MWe (20 percent reactor power) occurred on May 21-22 in order to make a drywell entry for repairs to the Drywell Equipment Drain System (DWEDS). On June 16, a down power to 775 MWe (82 percent reactor power) was required to perform repairs to the 2B moisture separator drain tank. The unit was returned to full power the following day where it remained for the duration of the inspection period.

Unit 3 Unit 3 operated at or near full power for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Impending Adverse Weather Condition-Severe Thunderstorm Watch with High Wind Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for April 2

, 2016, the inspectors reviewed the licensee's overall preparations/protection for the expected weather conditions. The inspectors walked down the off-site power and reactor recirculation adjustable speed drive systems, in addition to the licensee's emergency alternating current (AC) power systems, because their safety-related functions could be affected or required as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the licensee staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors' evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. The inspectors also reviewed licensee thermography inspection results for the 345 KV switchyard following the high wind conditions to ensure no deficiencies were developed as a result of the extreme weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. The inspectors also reviewed a sample of corrective action program (CAP) items to verify that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report.

5 This inspection constituted one readiness for impending adverse weather condition sample as defined in IP 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate AC pow er systems during adverse weather were appropriate. The inspectors reviewed the licensee's procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors' review included:

coordination between the TSO and the plant during off-normal or emergency events;

explanations for the events;

estimates of when the offsite power system would be returned to a normal state; and

notifications from the TSO to the plant when the offsite power system was returned to normal. The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of bot h the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:

actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;

compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;

re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and

communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged. The inspectors performed a walkdown of the 345 KV, 138 KV, and 34.5 KV switchyards and performed a review of maintenance history for components associated with the off-site power system. Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at 6 an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

unit 3 Division I low pressure coolant in jection/containment cooling service water (LPCI/CCSW) upon return to service from a preventative maintenance outage;

2/3B standby gas treatment (SBGT) w/ 2/3A SBGT out-of-service (OOS);

unit 2 high pressure coolant injection (HPCI) upon return to service following a corrective maintenance outage;

unit 2 isolation condenser (IC) with HPCI Inoperable; and

unit 3 IC after HPCI auxiliary oil pump fire The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, TS requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. These activities constituted five partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Routine Resident Inspector Tours

Main article: IP 71111.05Q

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

Fire Zone 1.1.1.5A, unit 3 reactor building, elevation 589' (IC area);

unit 2 emergency diesel generator (EDG) carbon dioxide fire suppression system 2 year logic test;

Fire Zone 8.2.4, unit 3 cable tunnel, elevation 502';

Fire Zone 9.0.B, unit 3 diesel generator room, elevation 517'; and

Fire Zone 11.3, unit 2/3 crib house, elevations 509' and 517'. The inspectors reviewed areas and one fire protection suppression system test to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

Main article: IP 71111.06

.1 Underground Vaults

a. Inspection Scope

The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors verified the licensee was performing periodic (bi-monthly for station blackout (SBO)manhole 1 and quarterly for SBO manhole 3) inspections. The inspectors accompanied 8 the licensee during a periodic inspection of the SBO manholes and noted that cables in SBO manhole 1 were submerged. The inspectors observed the licensee pump out water from the affected cable vault and ensured that the affected cables' splices were intact, and that appropriate cable support structures were in place. In security manholes 1 and 2, the inspectors verified that level alarm circuits were set appropriately to ensure that the cables would not be submerged. The inspectors also reviewed the licensee's corrective action documents with respect to past submerged cable issues identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunkers/manholes subject to flooding:

SBO north and south manholes 1 and 3; and

security manholes 1 and 2.

Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one underground vaults sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

Main article: IP 71111.11Q

a. Inspection Scope

On June 8 and 10, 2016, the inspectors observed the licensees' training staff perform a pilot assessment of licensed operator training scenarios and on June 22, 2016, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

licensed operator performance;

crew's clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate Technical Specifications (TS) actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On May 21, 2016, the inspectors observed operators perform a unit 2 down power, de-inerting of containment, and containment entry for drywell equipment drain sump (DWEDS) repairs. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

licensed operator performance;

crew's clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms (if applicable);

correct use and implementation of procedures;

control board (or equipment) manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable). The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.3 Biennial Written and Annual Operating Test Results

Main article: IP 71111.11A

a. Inspection Scope

The inspectors reviewed the overall pass/fail results and quality of the Biennial Written Examination, administered by the licensee from April 13, 2015, through May 22, 2015, and the Annual Operating Test, administered by the licensee from April 18, 2016, through May 27, 2016, required by Title 10 Code of Federal Regulations (CFR), 55.59(a). The results were compared to the thresholds established in Inspection Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process (SDP)," to assess the overall adequacy of the licensee's Licensed Operator Requalification Training (LORT) Program to meet the requirements of 10 CFR 55.59. This inspection constituted one Annual Licensed Operator Requalification Examination results sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

.4 Biennial Review

Main article: IP 71111.11B

a. Inspection Scope

The following inspection activities were conducted during the weeks of May 9, 2016, and May 16, 2016, to assess:

(1) the effectiveness and adequacy of the facility licensee's implementation and maintenance of its systems approach to training based LORT Program, put into effect to satisfy the requirements of 10 CFR 55.59;

(2) conformance with the requirements of 10 CFR 55.46 for use of a plant referenced simulator to conduct operator licensing examinations and for satisfying experience requirements; and

(3) conformance with the operator license conditions specified in 10 CFR 55.53. The documents reviewed are listed in the Attachment to this report.

Licensee Requalification Examinations (10 CFR 55.59(c); Systems Approach to Training element 4 as defined in 10 CFR 55.4): The inspectors reviewed the licensee's program for development and administration of the LORT biennial written examination and annual operating tests to assess the licensee's ability to develop and administer examinations that are acceptable for meeting the requirements of 10 CFR 55.59(a).

- The inspectors conducted a detailed review of one biennial requalification written examination version to assess content, level of difficulty, and quality of the written examination materials. (02.03)

- The inspectors conducted a detailed review of 13 Job Performance Measures and 4 simulator scenarios to assess content, level of difficulty, and quality of the operating test materials. (02.04)

- The inspectors observed the administration of the annual operating test to assess the licensee's effectiveness in conducting the examination, including the conduct of pre-examination briefings, evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios, and evaluated various licensed crew members concurrently with facility evaluators during the administration of several Job Performance Measures. (02.05)

- The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans. (02.07)

Conformance with Examination Security Requirements (10 CFR 55.49): The inspectors conducted an assessment of the licensee's processes related to examination physical security and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, "Integrity of Examinations and Tests."

11 The inspectors reviewed the facility licensee's examination security procedure, and observed the implementation of physical security controls (e.g., access restrictions and simulator I/O controls) and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the inspection period. (02.06)

Conformance with Operator License Conditions (10 CFR 55.53): The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators, and which control room positions were granted watch-standing credit for maintaining active operator licenses.

Additionally, medical records for ten operators were reviewed for compliance

with 10 CFR 55.53(I). (02.08)

Conformance with Simulator Requirements Specified in 10 CFR 55.46: The inspectors assessed the adequacy of the licensee's simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements. The inspectors reviewed a sample of simulator performance test records (e.g., transient tests, malfunction tests, scenario based tests, post-event tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy corrective action process to ensure that simulator fidelity was being maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. (02.09)

Problem Identification and Resolution (10 CFR 55.59(c); Systems Approach to Training element 5 as defined in 10 CFR 55.4): The inspectors assessed the licensee's ability to identify, evaluate, and resolve problems associated with licensed operator performance (a measure of the effectiveness of its LORT Program and their ability to implement appropriate corrective actions to maintain

its LORT Program up-to-date). The inspectors reviewed documents related to licensed operator performance issues (e.g., recent examination and inspection reports including cited and non-cited violations; U.S. Nuclear Regulatory Commission End of Cycle and Mid-Cycle reports; U.S. Nuclear Regulatory Commission plant issue matrix; licensee event reports; licensee condition/ problem identification reports including documentation of plant events and review of industry operating experience). The inspectors also sampled the licensee's quality assurance oversight activities, including licensee training department self-assessment reports. (02.10) This inspection constituted one Biennial Licensed Operator Requalification Program inspection sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

EDG 10 CFR 50.65(a)(1) action plan and quality control audit; and

unit 2 and 3 feed water systems. The inspectors reviewed events such as where ineffective equipment maintenance had resulted in or could have resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

implementing appropriate work practices;

identifying and addressing common cause failures;

scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

characterizing system reliability issues for performance;

charging unavailability for performance;

trending key parameters for condition monitoring;

ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors performed a quality control audit by ensuring the control of quality parts during the maintenance process, specifically the control and segregation of safety-related parts that were being used in the replacement of the starting air system associated with the 2/3 EDG. The inspectors verified the integrity of safety-related parts lay down areas in the mechanical maintenance shop as well as in the field, ensuring quality parts including consumable items (lubricants, sealants, etc.) were properly labeled, segregated, and installed. The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly maintenance effectiveness sample and one quality control sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

unit 3 emergent repairs to main generator stator water cooling temperature and pressure control instrument air piping;

unit 3 YELLOW risk with Division 1 LPCI/CCSW OOS;

emergent repairs to the 2/3 EDG due to a speed board control circuit failure;

unit 2 HPCI unavailable due to a steam leak with U2 LPCI previously unavailable; and

unit 3 HPCI inoperable due to auxiliary oil pump fire. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

Main article: IP 71111.15

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

historical operability of reactor protection system condenser low vacuum scram function with two channels out of technical specification tolerance;

breaker contact deficiency for MOV 2-2301-14 HPCI main pump recirculation to torus isolation valve;

impact of exceeding snubber alignment criteria on 2A reactor recirculation pump seismic support lug; and 14

reactor protection system (RPS) contacts latent failure with the potential to energize back-up scram valves. The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensee's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report. This operability inspection constituted four samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

.2 Annual Sample:

Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensee's implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of operator workarounds (OWAs)on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents. The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP, and proposed or implemented appropriate and timely corrective actions which addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.

15 This review constituted one operator workaround annual inspection sample as defined in IP 71115-02.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

2/3A SBGT;

2/3 reactor building closed cooling water (RBCCW) pump;

unit 3 EDG;

unit 2/3 EDG;

unit 2 LPCI logic relays; and

main control room ventilation and air conditioning system, train A. These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as

written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test

documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

WO 01893370, "Dresden 3 Quarterly TS Core Spray Pump Test With Torus Available for IST Data Surveillance" (in-service testing);

WO 01889454, "Dresden 2 Quarterly TS Anticipated Transient Without Scram Recirculation Pump Trip/Alternate Rod Insertion Master Trip Unit/Slave Trip Unit Channel Functional Test" (routine);

WO 01730845, "Reactor High Steam Dome Pressure Scram Channel Calibration" (routine);

WO 01884181, "Dresden 2 Semi-Annual Preventative Maintenance Verification of Motor Operated Valve 2-1301-3 Stroke Length" (routine); and

WO 01916057, "Dresden 2/3 Quarterly Common 'B' Isolation Condenser Make-Up Pump Operability" (routine). The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

did preconditioning occur;

the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;

plant equipment calibration was correct, accurate, and properly documented;

as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the UFSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current;

test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

test data and results were accurate, complete, within limits, and valid;

test equipment was removed after testing;

where applicable for in-service testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; 17

where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its safety functions; and

all problems identified during the testing were appropriately documented and dispositioned in the CAP.

RADIATION SAFETY

Cornerstones: Public Radiation Safety, Occupational Radiation Safety

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 71124.03

.1 Engineering Controls (02.02)

a. Inspection Scope

The inspectors reviewed procedural guidance for use of ventilation systems, and assessed whether the systems were used, to the extent practicable, during high-risk activities to control airborne radioactivity and minimize the use of respiratory protection.

The inspectors assessed whether installed ventilation airflow capacity, flow path, and filter/charcoal unit efficiencies for selected systems were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable. The inspectors also evaluated whether selected temporary ventilation systems used to support work in contaminated areas were consistent with licensee procedural guidance and as-low-as-reasonably-achievable (ALARA). The inspectors reviewed select airborne monitoring protocols to assess whether alarms and set points were sufficient to prompt worker action. The inspectors assessed whether the licensee established trigger points for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides. These inspection activities constituted one sample as defined in Inspection Procedure (IP) 71124.03-05 19

b. Findings

No findings were identified.

.2 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

The inspectors assessed whether the licensee provided respiratory protection devices for those situations where it was impractical to employ engineering controls such that occupational doses were ALARA. For select instances where respiratory protection devices were used, the inspectors assessed whether the licensee concluded that further engineering controls were not practical. The inspectors also assessed whether the licensee had established means to verify that the level of protection provided by the respiratory protection devices was at least as good as that assumed in the work controls and dose assessment. The inspectors assessed whether the respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational

Safety and Health/Mine Safety and Health Administration or have been approved by the U.S. Nuclear Regulatory Commission (NRC). The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or any conditions of their NRC

approval. The inspectors reviewed records of air testing for supplied-air devices and self-contained breathing apparatus (SCBA) bottles to assess whether the air used met or exceeded Grade D quality. The inspectors evaluated whether plant breathing air supply systems satisfied the minimum pressure and airflow requirements for the devices. The inspectors evaluated whether selected individuals qualified to use respiratory protection devices had been deemed fit to use the devices by a physician. The inspectors observed selected individuals donning, doffing, and functionally checking respiratory protection devices as appropriate and assessed whether these individuals knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence. The inspectors observed the physical condition of respiratory protection devices ready for issuance and reviewed records of routine inspection for selected devices. The inspectors reviewed records of maintenance on the vital components for selected devices and assessed whether onsite personnel assigned to repair vital components received vendor-provided training. These inspection activities constituted one sample as defined in IP 71124.03-05

b. Findings

Introduction:

The inspectors identified a finding of very-low safety significance (Green) and an associated NCV of Title 10 CFR, Part 20.1703, for failure to implement and maintain written procedures regarding breathing air quality which resulted in the failure to perform a continuous in-line breathing air quality test during filling of SCBA cylinders.

20 On May 4, 2016, the inspectors identified that the in-line carbon monoxide (CO) monitor located at the air compressor high-pressure fill station was not operational since 2009.

The procedure did not specify alternative methods of CO monitoring during filling of SCBA cylinders. Specifically, the licensee failed to adequately implement effective CO monitoring of the air used to fill SCBA cylinders.

Description:

On May 4, 2016, during a routine inspection of the Eagle Air compressor used to fill SCBA cylinders at the Dresden Nuclear Power Station, the inspectors identified that the in-line CO monitor located at the high pressure side of the filling station was out of service since 2009. This in-line CO gas monitor was installed by the manufacturer to monitor the oiled based lubricant air compressor, in the event of compressor failure. The licensee did perform periodic Grade D air testing of the air compressor (including CO). Station procedure RP-DR-827 specified alternate sampling must be performed when the installed in-li ne CO was out of service, however, this procedure does not adequately specify how this sampling was to be performed. The inspectors observed this sampling was performed on the inlet of the air compressor.

This practice did not adequately ensure the air quality on the outlet of the air compressor was acceptable. Specifically, there was no specific instruction where to place the monitor, and without a specific instruction, the licensee's technicians routinely placed this portable air monitor on the air intake section of the air compressor rather than the high pressure side of the compressor in-line with the cylinder filling station where the inoperative in-line CO monitor was located. The licensee determined that the alternative method as described on the procedure was adequate because the air compressor has a built-in a high temperature cut-off switch on the compressor side and at quarterly intervals, the compressor air quality was tested by an independent laboratory testing company to meet Grade-D air quality. Nevertheless, the inspectors determined that the compressor (Eagle-Air Breathing System) was an oil-lubricated compressor that has an installed in-line air filtration system that was capable of removing oil, water, particulates, objectionable taste and odors to meet Grade-D air standard for SCBA cylinders. However, it does not remove CO gas from the system caused by a malfunctioning air compressor. The high temperature sensor installed on the compressor detects ignition of lubricant by shutting off the compressor, the in-line CO monitor functioned as a redundancy system thus ensuring Grade D air quality was maintained by detecting a trace amount of CO gas in parts per million range. When the CO monitor was unavailable, the air compressor relied only on one single point of failure detection through the temperature sensor and a trace amount of CO may have been generated without any detection. The alternate method of detection stated in the procedure doesn't constitute a redundancy system because the alternate CO detector was routinely placed on the intake side of the compressor. Therefore, the alternate gas monitoring was incapable of detecting CO gas

during refilling of the SCBA cylinders when the air compressor/temperature sensor malfunctioned. As corrective actions, the licensee called the manufacturer, and a manufacturer representative was currently repairing the unit. Additionally, the licensee was also in the process of installing a new air Raven Eagle SCBA compressor system. The licensee indicated that in the interim, the licensee will perform sampling of current SCBA cylinders for carbon monoxide gas from past fillings.

Analysis:

The inspectors determined that this issue of concern was a performance deficiency because the licensee failed to effectively implement and maintain written procedures regarding breathing air quality which resulted in the failure to perform a continuous in-line breathing air quality test during filling of SCBA cylinders since 2009. Specifically, the in-line CO monitor was defective and out of service and the licensee did not implement an alternative method approved by the manufacturer to sample the air quality that was necessary to demonstrate compliance with the requirements of 10 CFR 20.1703. The inspectors determined that the cause of the performance deficiency was reasonably within the licensee's ability to foresee and correct and should

have been prevented. The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRC's ability to perform its regulatory function, and was not willful. The inspectors also determined that that the finding was more than minor in accordance with Inspection Manual Chapter (IMC) 0612, in that the finding impacted the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Specifically, the less than adequate procedures to determine the air quality could result in unplanned and unintended contamination of the SCBA cylinders with CO gas originating from the air compressor. The inspectors also concluded that the potential consequence of CO contamination could cause an immediate danger to life or health condition for the SCBA wearer during a plant emergency response. The finding was assessed using IMC 0609, Appendix C, and Occupational Radiation Safety Significance Determination Process and was determined to be of very-low safety significance because it was not an ALARA planning issue, there was no overexposure nor substantial potential for an overexposure, and the licensee's ability to assess dose was not compromised. Consequently, the inspectors concluded that the cause of the issue involved a cross-cutting component in the area of human performance, resources in that, the licensee did not ensure the adequacy of the procedure describing the alternate methods of CO monitoring during the filling of Grade D air into the SCBA cylinders. [H.1]

Enforcement:

Title 10 CFR 20.1703 states, in part, that the licensee shall make use of individual respiratory protection equipment and to the extent practical shall implement and maintain a Respiratory Protection Program that includes written procedures regarding breathing air quality to be maintained at Grade-D air quality criteria (CO content to less than ten part per million). Contrary to the above, on May 4, 2016, the licensee failed to implement and maintain written procedures regarding breathing air quality which resulted in the failure to perform a continuous in-line breathing air quality test during filling of SCBA cylinders since 2009. Specifically, the in-line CO monitor was defective and out-of-service and the licensee did not implement an alternative method approved by the manufacturer to sample the air quality that was necessary to demonstrate compliance with the requirements of 10 CFR 20.1703. Since the failure to adequately implement and maintain a Respiratory Protection Program that includes written procedures regarding the breathing air quality to maintain Grade-D air quality criteria was of very-low safety significance, corrective actions were established as described above, and the issue was entered into the 22 licensee's Corrective Action Program as Issue Report (IR) 2666210, the violation is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000237/2016002-01; 05000249/2016002-01; "Failure to Implement and Maintain Written Procedures Regarding Breathing Air Quality Testing").

.3 Self-Contained Breathing Apparatus for Emergency Use (02.04)

a. Inspection Scope

The inspectors reviewed the status and surveillance records for select SCBAs. The inspectors evaluated the licensee's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency

conditions. The inspectors assessed whether control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBAs and evaluated whether personnel assigned to refill bottles were trained and qualified for that task. The inspectors assessed whether appropriate mask sizes and types were available for use. The inspectors evaluated whether on-shift operators had no facial hair that would interfere with the sealing of the mask and that appropriate vision correction was available. The inspectors reviewed the past two years of maintenance records for selected in-service SCBA units used to support operator activities during accident conditions. The inspectors assessed whether maintenance or repairs on an SCBA unit's vital components were performed by an individual certified by the manufacturer of the device to perform the work. The inspectors evaluated the onsite maintenance procedures governing vital component work to determine whether there was any inconsistencies with the SCBA

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Mitigating Systems Performance Index-Emergency AC Power System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power Syst em (MS06) performance indicator for Dresden Nuclear Power Station, Units 2 and 3, covering the period from the 2nd quarter 2015 through 1st quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance, were used. The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule

records, maintenance work orders, issue reports, event reports and NRC Integrated Inspection Reports for the period of April 2015 through March 2016 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI emergency AC power system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index-High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems (MS07) performance indicator for Dresden Nuclear Power Station, Units 2 and 3, covering the period from the 2nd quarter 2015 through 1st quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance, were used. The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports and NRC Integrated Inspection 27 Reports for the period of April 2015 through March 2016 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific activity Performance Indicator (PI) for Dresden Nuclear Power Station, Units 2 and 3, for the period from the first quarter 2015 through the first quarter 2016. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods.

The inspectors reviewed the licensee's reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report. This inspection constituted two reactor coolant system specific activity samples as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Main article: IP 71152

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensee's CAP at an 28 appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensee's CAP as a result of the inspectors' observations are included in the Attachment to this report. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished through inspection of the station's daily condition report packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensee's CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors' review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors' review nominally considered the 6-month period of January 2016 through June 2016, although some examples expanded beyond those dates where the scope of the trend

warranted. The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental 29 problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensee's CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensee's trending reports were reviewed for adequacy. The inspectors and the licensee noted similar trends in program effectiveness and human performance standards. Although these deficiencies did not always result in any immediate adverse consequences, a potential trend in these areas is apparent and suggests that additional licensee attention to effect corrective actions may be appropriate. The licensee entered the following potential adverse trend into their CAP during this time period: Operations fundamental focus area self-assessment (FASA) deficiency (IR 2635948). Specific examples associated with degraded program effectiveness and human performance standards trends included, but were not limited to:

Not properly utilizing the CAP to capture, identify, and properly resolve degraded plant equipment in a timely manner (IR 2673322) as well instances where IRs and WOs were closed prematurely without correction of the identified problem (IR 2675223).

Failure to properly report MSPI EDG reliability failures (IR 2676458), but as no threshold was crossed, this issue was considered a minor violation of NRC requirements.

Failure to adequately document the completion of snubber inspections associated with the unit 2 core spray and isolation condenser systems (IR 2681869).

Inability to locate completion records for periodic radiation surveys on HI-STAR spent fuel dry storage casks. This issue was considered a minor violation of NRC requirements because the licensee successfully completed the surveillances when they were notified of the oversight by the inspectors (IR 2677592).

On April 17, 2016, while performing the Unit 2 quarterly average power range monitor (APRM) rod block and scram function surveillance, the operators received an unexpected alarm (Channel B Reactor Scram). This unexpected half scram (condition in which half of the necessary logic to achieve a scram actuated) was generated when the incorrect APRM mode switch was manipulated during routine testing. The APRM was returned to operate and the Channel B half scram was reset (IR 2656804).

On April 30, 2016, the licensee exceeded the drywell floor drain sumps (DWFDS) surveillance frequency for SR 3.4.4.1. The licensee immediately performed the surveillance and all unidentified drywell leakage was within TS required limits. The DWFDS are normally pumped every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and DWFDS were last pumped at 8:00 a.m. and would not be available for the next scheduled pumping at 4:00 p.m. due to scheduled maintenance. After review of TS limiting condition for operations (LCOs) the licensee made the assumption that pumping the sumps at 12:00 a.m.

(the next scheduled pumping) would be sufficient to meet a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LCO. They did not verify their assumption and validate the Technical Specification Surveillance 30 Requirement per TRM Appendix I "Surveillance Frequency Control Program" which is a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO (IR 2663515). This issue was considered a minor violation of NRC requirements because the licensee successfully completed the surveillances when they identified the issue.

On May 17, 2016, the licensee inadvertently initiated the fire suppression deluge system when a maintenance technician took unauthorized resistance readings while attempting to troubleshoot an alarming condition with the fire detection system in the unit 2/3 crib house (IR 2670555). This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 (Closed) Licensee Event Report (LER) 05000237/2016-001-00, "Secondary Containment Differential Pressure Transient" On February 9, 2016, at 7:00 p.m. the operating heating boiler tripped offline.

At 7:15 p.m., main control room (MCR) operators received a reactor building differential pressure low alarm. Equipment operators were dispatched into the field and locally determined reactor building to outside environment differential pressure to be -0.35 inches water column. This is a low value as compared to the normal -0.65 inches water column but greater than the -0.25 inches water column required for Secondary Containment operability by the TS. Abnormal Operating Procedure DOA 5700-01, "Loss of Heating Boilers" was entered by the operators and reactor building ventilation supply plenum doors were opened in accordance with step D.8 of the procedure in order to prevent freezing of the reactor building ventilation supply plenum filters and cooling coils by allowing warm turbine building air to mix with the extremely cold outside air entering the system. In addition to the loss of the operating heating boiler, plant staff had previously identified that the unit 3 area differential pressure controller (3-5703-15B) was operating low out of tolerance which had the effect of not permitting the reactor building exhaust dampers from opening as far as would be expected based on supply air flow conditions. At 9:42 p.m., reactor building to outside environment differential pressure degraded to -0.24 inches water column. The combination of the colder, denser intake air and the open supply plenum doors lead to a greater quantity of air entering the reactor building ventilation supply system. This, along with the degraded exhaust differential pressure controller, resulted in reduced secondary containment vacuum conditions and an unplanned entry into secondary containment TS 3.6.4.1.A for not maintaining the required -0.25 inches water column vacuum inside the secondary containment boundary. Operators shutdown the degraded unit 3 reactor building ventilation system at 10:05 p.m. and vacuum conditions quickly recovered on the unit 2 reactor building ventilation system to in excess of -0.25 inches water column and TS 3.6.4.1.A was exited at 10:07 p.m. Corrective actions for this event included repairs to the affected differential pressure controller; implementation of a component monitoring strategy for the reactor building ventilation differential pressure controllers that focuses on controller output versus 31 secondary containment differential pressure in order to uncover masked performance issues; a revision to operations procedure DOA 5700-01 to incorporate lessons learned for a loss of heating boiler coincident with a degraded reactor building ventilation system; and a review of the differential pressure controller design and surveillance frequency. The licensee reported this event in accordance with 10 CFR 50.73(a)(2)(v)(C), any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. No findings or violations of NRC requirements were identified. This LER is closed.

This event follow up review constituted one sample as defined in IP 71153-05.

.2 Alert Declared Due to Fire in Unit 3 HPCI Auxiliary Oil Pump Motor

a. Inspection Scope

The inspectors reviewed the plant's response to the following: On June 27, 2016 during an operability surveillance, the Unit 3 HPCI system auxiliary oil pump (AOP) was discovered on fire. The fire was extinguished and the breaker for the AOP motor was turned off. Based on initial assessment of the event and meeting the Emergency Action Level (EAL) threshold criteria an Alert, MA5, was declared at 10:50 a.m. The Alert was terminated at 1:19 p.m. The HPCI system was declared inoperable and Technical Specification 3.5.1 condition G was entered, requiring HPCI to be operable within 14 days. The Licensee will submit a LER within 60 days per

10 CFR 50.73 and the inspectors will perform an event follow-up review in a future

report. Documents reviewed are listed in the Attachment to this report. This event follow-up review does not constitute a sample as defined in IP 71153-05.

4OA5 Other Activities

.1 Operation of an ISFSI at Operating Plants (60855.1)

a. Inspection Scope

The inspectors observed and evaluated select licensee loading, processing, and transfer operations of the fourth canister during the licensee's 2016 dry fuel storage campaign to verify compliance with the applicable Certificate of Compliance (CoC) conditions, the associated Technical Specifications, and approved Independent Spent Fuel Storage Installation (ISFSI) procedures. Specifically, the inspectors observed: placement of the multi-purpose canister (MPC) within the transfer cask (HI-TRAC) into the spent fuel pool, loading of fuel assemblies into the MPC; decontamination and surveying; welding and non-destructive testing of the MPC lid-to-shell weld; draining of water from the MPC;

vacuum drying of the MPC; welding and non-destructive testing of the MPC closure rings; and transfer of the MPC from the HI-TRAC to storage cask (HI-STORM). The licensee used the Holtec International HI-STORM 100 Cask System for this campaign.

32 The inspectors reviewed procedures used to perform ISFSI preparation, loading, sealing, transfer, monitoring, and storage activities. The inspectors also reviewed applicable heavy loads procedures and inspection documentation to determine compliance with the site's heavy loads program. Select documents, in part, were reviewed after the licensee completed certain loading activities. The inspectors reviewed the licensee's evaluations associated with fuel characterization and selection for storage. The licensee did not plan to load any damaged fuel assemblies or fuel debris during this campaign. The inspectors reviewed the canister fuel selection packages for the 2016 campaign to verify that the licensee was loading fuel in accordance with the CoC-approved contents. The inspectors reviewed a number of condition reports and the associated corrective actions since the last ISFSI inspection. The inspectors also reviewed 72.48 screenings and changes to the licensee's 10 CFR 72.212 evaluations since the last ISFSI inspection. The inspectors performed a walk-down of the East and West ISFSI pads to assess the material condition of the pad and the loaded Holtec International Storage, Transport and Repository (HI-STAR) casks and HI-STORM 100 storage casks. The inspectors reviewed the licensee's ISFSI radiation monitoring program. Additionally, the inspectors performed independent radiation surveys around the ISFSI pads and storage casks.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary On June 30, 2016, the inspectors presented the inspection results to Mr. P. Karaba, and other members of the licensee staff.

The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings Interim exits were conducted for:

The inspection results for the areas of the licensed operator program Biennial Review (71111.11B) with Mr. A. Pullam, Training Director, on May 20, 2016.

The results of the ISFSI operational inspection on June 6, 2016, with Mr. J Washko, Plant Manager, and other members of the licensee's staff.

The inspection results for the areas of in-plant airborne radioactivity control and mitigation; occupational dose assessment; and RCS specific activity performance indicator verification with Mr. B. Franzen, Regulatory Assurance Manager, on June 16, 2016.

The inspection results for the areas of the Biennial Written and Annual Operating Test Results (71111.11A) with Mr. G. Morrow, Operations Director, on June 23, 2016.

33 The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Karaba, Site Vice President

J. Washko, Station Plant Manager

L. Antos, Manager Site Security

M. Budelier, Senior Engineering Manager

S. Butala, Senior Radiation Protection Technical Specialist

G. Chavez; Dry Cask Storage Senior Program Manager M. Cichon; Dresden Dry Cask Storage Project Manager J. Connelly, Engineering Manager

T. Ditchfield, Shift Operations Superintendent

P. DiSalvo, GL 89-13 Program Owner

D. Doggett, Emergency Preparedness Manager

B. Franzen, Regulatory Assurance Manager

D. Glick, Radioactive Material Shipping Specialist

F. Gogliotti, Director, Site Engineering

M. Hosain, Site EQ Engineer

R. Johnson, Chemistry

D. Ketchledge, Engineering

J. Kish, Site ISI

G. Morrow, Operations Director

S. Matzke, Corrective Action Program Coordinator

M. Overstreet, Radiation Protection Manager

M. Pavey, Health Physicist

A. Pullam, Director, Site Training

J. Quinn, Director, Site Maintenance

D. Schiavoni, Engineering

R. Schmidt, Manager Site Chemistry, Environment & Radwaste

R. Sisk, Buried Pipe Program Owner

D. Siuda, Operations Training Instructor

D. Thomas, Training Manager

D. Walker, Regulatory Assurance - NRC Coordinator

U.S. Nuclear Regulatory Commission J. Cameron, Chief, Division of Reactor Projects, Branch 4

IEMA

M. Porfirio, Resident Inspector, Illinois Emergency Management Agency

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000237/2016002-01

05000249/2016002-01 NCV Failure to Implement and Maintain Written Procedures Regarding Breathing Air Quality Testing (Section 2RS3)

Closed

05000237/2016002-01

05000249/2016002-01

NCV Failure to Implement and Maintain Written Procedures Regarding Breathing Air Quality Testing (Section 2RS3)

05000237/2016-001-00

05000249/2016-001-00 LER Secondary Containment Differential Pressure Transient

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that

@@ Line 18: / Line 18: @@
 =Text=
-{{#Wiki_filter:July 25, 2016
+{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 July 25, 2016
-==SUBJECT:==
+Mr. Bryan Senior VP, Exelon Generation Company LLC President and CNO, Exelon Nuclear 4300 Winfield Road
-DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3-NRC INTEGRATED INSPECTION REPORT 05000237/2016002; 05000249/2016002; 07200037/2016001
+Warrenville, IL 60555
+SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3-NRC INTEGRATED INSPECTION REPORT 05000237/2016002; 05000249/2016002; 07200037/2016001
 ==Dear Mr. Hanson:==

IR 05000237/2016002: Difference between revisions

Revision as of 20:22, 13 July 2019

Text

Dear Mr. Hanson:

Enclosure:

SUMMARY

Cornerstone: Occupational Radiation Safety

REPORT DETAILS

REACTOR SAFETY

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition-Severe Thunderstorm Watch with High Wind Conditions

a. Inspection Scope

b. Findings

.2 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

b. Findings

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

b. Findings

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

b. Findings

1R06 Flooding

.1 Underground Vaults

a. Inspection Scope

b. Findings

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

b. Findings

.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

a. Inspection Scope

b. Findings

.3 Biennial Written and Annual Operating Test Results

a. Inspection Scope

b. Findings

.4 Biennial Review

a. Inspection Scope

b. Findings

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

b. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

b. Findings

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

b. Findings

.2 Annual Sample:

a. Inspection Scope

b. Findings

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

b. Findings

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

b. Findings

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

b. Findings

.2 Emergency Preparedness Drill Observation

a. Inspection Scope

b. Findings

RADIATION SAFETY

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

.1 Engineering Controls (02.02)

a. Inspection Scope

b. Findings

.2 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

b. Findings

Introduction: