IR 05000237/2005013

IR 05000237-05-013; IR 05000249-05-013; 10/01/2005 - 12/31/2005; Exelon Generation Company, Dresden Nuclear Power Station, Units 2 and 3; Quarterly Integrated Inspection Report

ML060440671
Person / Time
Site:	Dresden
Issue date:	02/13/2006
From:	Ring M NRC/RGN-III/DRP/RPB1
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-05-013
Download: ML060440671 (47)

Text

February 13, 2006Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555SUBJECT:DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3NRC INTEGRATED INSPECTION REPORT 05000237/2005013; 05000249/2005013

Dear Mr. Crane:

On December 31, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed integratedinspection report documents the inspection findings, which were discussed on January 4, 2006, with Mr. D. Bost and other members of your staff. The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection no findings were identified. However, a licensee-identified violation which was determined to be of very low safety significance (Green) is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent withSection VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it was entered into your corrective action program.If you contest this NCV, you should provide a response within 30 days of the date of thisinspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director,Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001;

and the NRC Resident Inspector at the Dresden Nuclear Power Station.

C. Crane-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC'sdocument system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/Mark A. Ring, ChiefBranch 1 Division of Reactor ProjectsDocket Nos. 50-237; 50-249License Nos. DPR-19; DPR-25Enclosure:Inspection Report 05000237/2005013; 05000249/2005013 w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Dresden Nuclear Power StationDresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer Chairman, Illinois Commerce Commission

SUMMARY OF FINDINGS

IR 05000237/2005013; IR 05000249/2005013; 10/01/2005 - 12/31/2005; Exelon GenerationCompany, Dresden Nuclear Power Station, Units 2 and 3; Quarterly Integrated InspectionReport.The report covered a 3-month period of baseline resident inspection and announced baselineinspections in radiation protection and inservice inspection. The inspection was conducted by

Region III inspectors and the resident inspectors. No findings of significance were identified inany cornerstones. The NRC's program for overseeing the safe operation of commercialnuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3,dated July 2000.A.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B.Licensee-Identified Violations

A violation of very low safety significance which was identified by the licensee has beenreviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and its corrective actions are listed in Section 4OA7 of this report.

3

REPORT DETAILS

Summary of Plant StatusUnit 2 began the inspection period at 912 MWe (95 percent thermal power and 100 percent ofrated electrical capacity). *On October 16, 2005, power was reduced to 83 percent to perform control rod patternadjustment. The unit was returned to full power on the same day.*On October 22, 2005, power was reduced to 76 percent due to a trip of the 2C reactorfeedwater pump from an electrical fault. The unit returned to full power on October 24, 2005.*On October 31, 2005, the unit was taken offline for its scheduled refueling outage. Theunit was placed online on November 20, 2005, and the unit was returned to full power on November 23, 2005.*On December 10, 2005, load was reduced to 62 percent to perform control rod patternadjustment. The unit was returned to full power on the same day.*On December 17, 2005, load was reduced to 88 percent to perform control rod patternadjustment, and the unit was returned to full power on the same day.Unit 3 began the inspection period at 912 MWe (95 percent thermal power and 100 percent ofrated electrical capacity). *On November 5, 2005, the unit was taken offline to replace the 3B reactor recirculationsystem pump seal, replace the reserve auxiliary transformer #32, repair a leak in thecommon unit underground service water header piping, perform inspection/repairs on the reactor pressure vessel steam dryer, and various other activities. The unit was returned to full power on November 26, 2005.*On December 18, 2005, load was reduced to 89 percent to perform control rod patternadjustment, and the unit was returned to full power on the same day.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather (71111.01).1Two Risk Significant Systems

a. Inspection Scope

Winter Readiness: The inspectors reviewed the licensee's preparations for reliableoperation during winter conditions in accordance with corporate work control procedure WC-AA-107, "Seasonal Readiness," Revision 1. Also, the inspectors verified that of WC-AA-107, "System Engineering System Readiness Review," wascompleted and that any cold weather related adverse conditions that could affect thefollowing systems were identified: *Unit 2 and Unit 3 station blackout diesel generator system*Unit 2/3 emergency diesel generator cooling water systemThe inspectors walked down equipment and systems to identify any winter readinessissues and ensure t hat these systems would remain functional when challenged byinclement weather.This represented one inspection sample.

b. Findings

No findings of significance were identified..2Response to Inclement Weather

a. Inspection Scope

The inspectors reviewed the licensee's response to high wind conditions onNovember 14 and 15, 2005. The inspectors conducted followup reviews to assess the licensee's ability to ensure safety related and risk significant equipment remainedoperable and functional during inclement weather conditions. The inspectors evaluated the station's response to ensure equipment functionality as specified in the Updated Final Safety Analysis Report. Although the wind speed and duration did not meet the station's entry condition into their abnormal operating procedure, the licensee tookactions to check the condition of equipment by performing thermography inspections of the switchyard ring bus.This represented one inspection sample.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04Q and S).1Partial System Walkdowns

a. Inspection Scope

The inspectors selected a redundant or backup system to an out-of-service or degradedtrain to determine that the system met the design of the Updated Final Safety AnalysisReport. Piping and instrumentation diagrams were used to determine corre ct systemlineup and critical portions of the system configuration were verified. Instrumentation,valve configurations, and appropriate meter indications were also observed. The inspectors observed various support system parameters to determine the operational 5status of systems. Control room switch positions for the systems were observed. Otherconditions, such as adequacy of housekeeping, the absence of ignition sources, and proper labeling were also evaluated.The inspectors performed partial equipment alignment walkdowns of the:

• Unit 3 containment cooling service water system*Unit 3 isolati on condenser systemThis represented two inspection samples.

b. Findings

No findings of significance were identified..2Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete semi-annual walkdown of the Unit 3 containmentcooling service water (CCSW) system. The inspectors reviewed the electrical and mechanical system checklists and drawings to ensure all vital components in thissystem were properly aligned. The inspectors reviewed work orders associated with thesystem to determine whether there were any deficiencies that could affect the ability of the system to perform its safety-related function. The inspectors also reviewed all temporary modifications to verify the operational impact on the system. The inspectorsreviewed licensee issue reports (IRs) to review past issues that had been identified and their corrective actions. This represented one inspection sample.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05Q and A).1Routine Inspection (Quarterly)

a. Inspection Scope

The inspectors toured plant areas important to safety to assess the material condition,operating lineup, and operational effectiveness of the fire protection system andfeatures to ensure compliance with the station's Fire Hazard Analysis Report. The review included control of transient combustibles and ignition sources, fire suppression 6systems, manual fire fighting equipment and capability, passive fire protection features,including fire doors, and compensatory measures. The following areas were walked down: *Unit 2 Reactor building, 517' elevation, ground floor, Fire Zone 1.1.2.2*Unit 3 Reactor building, 476' elevation, southwest low pressure coolant injectionroom, Fire Zone 11.1.1*Unit 2 Reactor building 589' elevation, stand-by liquid control area, FireZone 1.1.2.5.D*Unit 3 Reactor building, 589' elevation, stand-by liquid control area, FireZone 1.1.1.5.D*Unit 3 Turbine building, 517' elevation, diesel generator room, Fire Zone 9.0B

• Unit 3 Reactor building, 517' elevation, shutdown cooling pump room, FireZone 1.3.1*Unit 3 Reactor building, 570' elevation, isolation condenser pipe chase (92 valveroom), Fire Zone 1.1.1.5B*Unit 2 Turbine building, 517' elevation, reactor feed pump room, FireZone 8.2.5A*Unit 2 Reactor building, 570' elevation, isolation condenser pipe chase (2 valveroom), Fire Zone 1.1.2.5.B*Unit 2 Reactor building, 517'-6" elevation, shutdown cooling pump room, FireZone 1.3.2This represented ten inspection samples.

b. Findings

No findings of significance were identified..2Fire Drill (Annual)

a. Inspection Scope

On October 4, 2005, the inspectors observed the fire brigade response to a simulatedfire in the Unit 3 station blackout diesel generator day tank room. The inspectors reviewed the licensee's drill procedure and assessed the licensee's critique of the firebrigade's performance. The inspectors reviewed the licensee's activities to determine if the licensee was in compliance with 10 CFR, Part 50, Appendix R,Section III.I.1.a. This represented one inspection sample.

b. Findings

No findings of significance were identified.

71R07Heat Sink Performance (71111.07A)

a. Inspection Scope

The inspectors reviewed the results of the maintenance performed on the 2Bcontainment cooling service water system heat exchanger during the Unit 2 refuelingoutage in November 2005 to determine if there was acceptable heat exchanger performance per generic letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the inspectors verified that maintenance was performed in accordance with the licensee's maintenance program for heat exchangers and reviewed issue reports to verify that deficiencies were identified and incorporated into the licensee's corrective action program. This represented one inspection sample.

b. Findings

No findings of significance were identified.

1R08 Inservice Inspection Activities (71111.08).1Piping Systems Inservice Inspection

a. Inspection Scope

From November 7, 2004, through November 12, 2005, the inspectors conducted areview of the implementation of the licensee's inservice inspection (ISI) program for monitoring degradation of the reactor coolant system boundary and the risk significantUnit 2 piping system boundaries. The inspectors selected the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI required examinations and Code components in order of risk priority as identified in Section 71111.08-03 of the inspection procedure, based upon the ISI activities available for review during the onsite inspection period.The inspectors observed the following two types of nondestructive examination activitiesto evaluate compliance with the ASME Boiler and Pressure Vessel Code requirements and to verify that indications and defects were dispositioned in accordance with the ASME Code. The inspector observed the following three ultrasonic nondestructive examinationactivities:*Ultrasonic examination of a Unit 2 Reactor Recirculation System tee to pipeweld # L5/L4*Ultrasonic examination of a Unit 2 Reactor Recirculation System tee to pipeweld # L5-D6A*Ultrasonic examination of a Unit 2 Shutdown Cooling elbow to elbow weld # 16-K6 8In addition, the inspectors performed a record review of the following examination: *Magnetic Particle Examination of Unit 2 Low Pressure Coolant Injection SystemIntegrally Welded Attachment # 2/2/1534-18/M3214-42The inspectors reviewed an examination from the previous outage with recordableindications that was accepted by the licensee for continued service to verify that thelicensee's acceptance for continued service was in accordance with the ASME Code.

Specifically, the inspectors reviewed the magnetic particle examination of an integrally welded support, M1164D-578, on the B Low Pressure Coolant Injection Heat Exchanger. A 2 5/8 inch linear indication was found and repaired as documented on corrective action report # 174575.The inspector reviewed a pressure boundary weld repair on Code Class 1 portions ofthe Unit 2 Reactor Coolant System to determine if the welding acceptance and preservice examinations (e.g., pressure testing, visual, dye penetrant, and weld procedure qualification tensile tests and bend tests) were performed in accordance with ASME Code Sections III, V, IX, and XI requirements. Specifically, the inspectorsreviewed the Class 1 pressure boundary weld repair conducted last outage on the Reactor Vessel Head Spray Line that was found leaking during the system hydrostatictest.The inspectors performed a review of ISI related problems that were identified by thelicensee and entered into the corrective action program, conducted interviews with licensee staff, and reviewed licensee corrective action records to determine if:*the licensee had described the scope of the ISI related problems*the licensee had established an appropriate threshold for identifying issues

• the licensee had evaluated industry generic issues related to ISI and pressureboundary integrity*the licensee implemented appropriate corrective actionsThe inspectors performed these reviews to ensure compliance with 10 CFR Part 50,Appendix B, Criterion XVI, "Corrective Action," requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment to this report.The reviews, as discussed above, counted as one inspection sample.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11Q)

a. Inspection Scope

The inspectors observed an evaluation of operating crew # 3 on October 3, 2005, andon December 12, 2005, the inspectors observed operating crew #5. The scenario for both days consisted of loss of the reactor protection system, loss of reactor building 9closed cooling water, anticipated transient without scram, stuck control rods, and steamleak in the drywell. The inspectors evaluated the licensee's performance against the requirements of 10 CFR 55.59 by verifying that the operators were able to complete the tasks in accordance with applicable plant procedures. The inspectors observed thelicensee's evaluators to ensure that no inappropriate cues were provided by the evaluators while assessing the operators' performance. In addition, the inspectors verified that issue reports written regarding licensed operator requalification training were entered into the licensee's corrective action program with the appropriate significance characterization.This represented two inspection samples.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q)

a. Inspection Scope

The inspectors assessed the implementation of the licensee's maintenance ruleprogram to evaluate maintenance effectiveness for the selected systems in accordancewith 10 CFR 50.65, Maintenance Rule. The following systems were selected based onbeing designated as risk significant under the Maintenance Rule, being in the increased monitoring (Maintenance Rule Category a(1)) group, or due to an inspector's identified issue or problem that potentially impacted system work practices, reliability, or common cause failures:*Core spray system*Source range monitor system*Station blackout diesel generator system*High pressure coolant injection systemThe inspectors verified the licensee's categorization of specific issues, includingevaluation of the performance criteria, appropriate work practices, identification of common cause errors, extent of condition, and trending of key parameters. Additionally, the inspectors reviewed the licensee's implementation of the Maintenance Rulerequirements, including a review of scoping, goal-setting, performance monitoring, short-term and long-term corrective actions, functional failure determinations associated with the condition and issue reports reviewed, and current equipment performance status.This represented four inspection samples.

b. Findings

No findings of significance were identified.

101R13Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors evaluated the implementation of the licensee's maintenance riskprogram with respect to the effectiveness of the risk assessments performed before maintenance activities were conducted on structures, systems, and components andverified how the licensee managed the risk in accordance with 10 CFR 50.65, Maintenance Rule. The inspectors evaluated whether the licensee had taken the necessary steps to plan and control emergent work activities. The inspectors also verified that equipment necessary to complete planned contingency actions was staged and available. The inspectors completed evaluations of maintenance activities on the:*2A Reactor protection system motor-generator-set flywheel bearing replacement*4KV Bus 23-1 to 33-1 cross tie and work on control rod drive pumps

• Low pressure coolant injection system swing bus protective relays and autotransfer functional test*Unit 2 Division 1 containment cooling service water piping replacement

• Unit 3 high pressure coolant injection system maintenance*U2 Bus 24-1 preventive maintenance with the 2B and 2/3 service water pumpsand the 2B reactor building closed cooling water pump out-of-service*Unit 2 Service water outage and control rod drive exercising

• Unit 3 Control rod drive cycling and 2/3 reactor building containment coolingwater pump out-of-service*Unit 2 Steam dryer replacement outage activities

• Unit 2/3 "B" Standby gas treatment system charcoal filter replacement and traininspection*Unit 2 High pressure coolant injection system maintenance*Unit 2 Low pressure coolant injection mechanical seal pump replacement

• Train 3B standby liquid control pump oil change and accumulator bladderreplacement*Unit 2 Isolation condenser safe shutdown valve operability testingThis represented fourteen inspection samples.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed operability evaluations (OE) to ensure that operability wasproperly justified and the component or system remained available, such that anynon-conformance conditions were in compliance with Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of 11Degraded and Nonconforming Conditions and on Operability." The review incl udedissues involving the operability of:*OE 05-002, "Main Steam Line Break Outside Containment is No LongerBounding," Revision 1*Engineering Change (EC) 355479, "On Line High Pressure Coolant InjectionRoom Cooler Maintenance and High Pressure Coolant Injection System Availability"*EC 356681, "Dresden Diesel Generator Loading with Two Low Pressure CoolantInjection Pumps" *EC 357894, "Cumulative Effects of Foreign Material (FM) on Reactor Vessel andConnecting Systems Dresden U2&U3," Revision 2* EC 354963, "Reactor Water Clean-up Line Break Dose Evaluation"This represented five inspection samples.

b. Findings

Determination of the site's bounding steam line break analysisIntroduction: The inspectors identified an unresolved item regarding whether the mainsteam line (MSL) break outside containment remained the bounding steam line break with respect to mass release and radiological dose consequences after adjusting the analysis to reflect main steam isolation valve closure time.Description: On April 11, 2005, a licensee design engineer initiated issue report(IR) #323533 which identified that the main steam line (MSL) break outside containmentwas no longer the bounding steam line break with respect to mass release and radiological dose. This determination was based on using a main steam isolation valve (MSIV) closure time of 5.5 seconds instead of the 10.5 second time period used in the original MSL break design basis analysis. The MSL break mass release for a 10.5 second MSIV closure time was 66,000 pounds mass. However, using a 5.5 second MSIV closure time, the mass release from the main steam line break analysis was reduced to 30,000 pounds mass. Using the 30,000 pounds mass release amount for the MSL break analysis, a reactor water clean up (RWCU) line break at 75,000 pounds mass release appeared to be a larger break than the MSL break and therefore may have resulted in control room and offsite doses which were higher than the doses from the MSL break outside containment. In previous license submittals for alternate source term on August 22, 2005, andextended power uprate on December 27, 2000, the licensee had submitted documentation indicating that the MSL break was the bounding break analysis. Theinspectors were concerned that this information may no longer be correct and that the RWCU system line break may no longer be bounded by the MSL break. In response toIR #323533, the licensee prepared an operability evaluation, OE #05-002. The licenseeutilized the application of alternate source term, an NRC approved dose calculationalmethod, in determining whether the radiological conditions to control room operatorsand at the site boundary from a RWCU system line break was bounded by licenseconditions. The inspectors reviewed the OE, had questions concerning the acceptability 12of analysis, and requested assistance from the Office of Nuclear Reactor Regulation(NRR). NRR determined that the licensee had incorrectly applied the use of the doseconversion factor for Total Effective Dose Equivalent (TEDE) in calculating thyroid dose.

The licensee subsequently revised the OE, using the correct dose conversion factor, proper RWCU system piping diameter sizes, and the appropriate activity amount fromthe portion of coolant that flashes. As a result of the changes, the licensee concluded that the RWCU system line break would result in not exceeding 20.2 REM which waswell below the regulatory limit of 30 REM thyroid dose. The NRC agreed with thelicensee's conclusion in the revised OE.The inspectors were also concerned whether Technical Specification (TS) 3.4.6,"Reactor Coolant System Specific Activity," should be changed. The TS directs the isolation of the MSIVs, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, based on coolant activity exceeding 4.0 uci/gm DOSE EQUIVALENT I-131, or place the unit in Mode 3 and 4 in 12 and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively. These actions were based on the assumption that the MSL break was the bounding break. Since the RWCU system line break appeared to have larger massrelease and dose consequences, the inspectors were concerned that the TS may no longer provide conservative actions in this area.At the end of the inspection, the licensee acknowledged errors in the OE calculations,but responded that the actual MSIV closure time had never changed, that the original IRwas unnecessary, that the RWCU line break doses were less than the regulatory limits, that closing of the MSIVs by the TS would put the plant in a shutdown condition suchthat evaluation of the TS for RWCU was unnecessary, and that all of the analyses werebounded by the alternate source term submittal which used a MSL break value of 140,000 pounds mass release.

Since this issue involved the adequacy and accuracy of licensee submittals, bounding break analyses, and TSs, the inspectors needed further assistance from NRR todetermine acceptability of the licensee's actions. This issue was considered anunresolved item pending further review with NRR. (URI 05000237/2005013-01;05000249/2005013-01)1R16Operator Workarounds (71111.16).1Quarterly Review

a. Inspection Scope

The inspectors assessed the following operator workaround issue to determine thepotential effects on the functionality of the corresponding mitigati ng system:*Unit 2 control rod drive During this inspection, the inspectors reviewed the technical adequacy of theworkaround documentation against the Updated Final Safety Analysis Report and other design information to assess whether the workaround conflicted with any design basis information. The inspectors compared the information in abnormal or emergency 13operating procedures to the workaround information to ensure that the operatorsmaintained the ability to implement important procedures when needed. Multiple entriesinto the corrective action program were also reviewed to ensure that the operator workarounds had been entered into this process.This represented one inspection sample.

b. Findings

No findings of significance were identified..2Semi-annual Review of the Cumulative Effects of Operator Workarounds

a. Inspection Scope

The inspectors reviewed all operator workarounds and challenges to assess anycumulative effect on the:*reliability, availability, and potential for misoperation of a system*multiple mitigating systems

• ability of operators to respond in a correct and timely manner to plant transientsand accidentsThe inspectors utilized the Updated Final Safety Analysis Report and the TechnicalSpecifications to determine the function of each system impacted by an operatorworkaround. The inspectors also interviewed licensee personnel and reviewed normal and abnormal operating procedures to determine the potential effects of the operatorworkaround.This represented one inspection sample.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed post-maintenance test results to confirm that the tests wereadequate for the scope of the maintenance completed and that the test data met theacceptance criteria in Technical Specifications or other design documents. The inspectors also reviewed the tests to determine if the systems were restored to the operational readiness status consistent with the design and licensing basis documents. The inspectors reviewed post-maintenance testing activities associated with the following:*WO 00836014, Replace 2A reactor protection system motor-generator-setflywheel bearings 14*WO 00834897, Unit 2/3 2 year inservice testing verification remote access valveposition indicator*WO 00693122, Unit 2 reactor pressure vessel ASME Code 1000 PSI systemleakage test*WO 00610673, Replace electric heating coil in 2/3-9400-101 air filtration unit

• WO 00774544, Overhaul and flow scan of control room heating, ventilation andair conditioning refrigeration condensing unit service water inlet valve, 2/3-5741-48B, actuator*WO 00785291-05, Post maintenance test on Unit 2 main steam line lowpressure relays after design modification*WO 00779136-01; Post maintenance tests on Unit 2 low pressure coolantinjection system after D2R19 work*WO 00580266, Unit 3 internal inspection containment cooling service watersystem loop II keep fill check valve post repair test*WO 00863350, Unit 2 utilized parts from D3 source range monitor 21 to repairD2 source range monitor 21*WO 99019500, Unit 3 environmental qualification containment cooling servicewater flow transmitter replacementThis represented ten inspection samples.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20).1Unit 2 Refueling Outage

a. Inspection Scope

The licensee conducted a refueling outage on Unit 2 from October 31, 2005, throughNovember 23, 2005. During the outage the licensee replaced the electromatic reliefvalve flanges, the 2A reactor recirculati on system pump motor, the Unit 2/3 dieselgenerator governor, all source range monitor under-vessel connectors, repaired an underground service water system piping leak common to both Unit 2 and Unit 3,overhauled numerous control rod drive hydraulic control units, and repaired and modified the steam dryer. The inspectors routinely reviewed the outage schedule and outage risk assessment toverify the licensee was correctly maintaining required equipment in service in accordance with the overall outage safety assessment. During the planned outage, the inspectors performed the following activities: *attended control room operator and outage management turnover meetings toverify that the current shutdown risk status was well understood and communicated*performed walkdowns of containment to identify any indications of unidentifiedleakage 15*ensured that the control room operators adhered to the licensee's TSs*performed walkdowns of the main control room to observe the alignment ofsystems important to shutdown risk*reviewed selected issues that the licensee entered into the corrective actionprogram to verify that identified problems were being entered into the program with the appropriate characterization and significance*ensured that the licensee appropriately considered risk factors during thedevelopment and execution of planned activities*monitored the licensee's troubleshooting efforts for emergent plant equipmentissues*performed plant walkdowns to observe ongoing work activities

• observed control rod withdrawals and initial transition to criticality

• performed walkdown of containment prior to closure to ensure that debris hadnot been left that could affect the performance of the containment sumps*monitored mode switch changes and observed portions of power ascensionThis represented one inspection sample.

b. Findings

Inadequate Work Order Package Caused Temporary Loss of Shutdown CoolingIntroduction: The inspectors identified an unresolved item regarding the adequacy ofwork order instructions to address a single point vulnerability with the 4160 Volt buses.Description: On November 6, 2005, electricians were using work order(WO) #843308-2, Electrical Maintenance Rewire Over Current Relays on Bus 23 Cub 12 per engineering change (EC) 356612. The EC had the unit and reserve auxiliarytransformers overcurrent relays rewired to these buses to address a single point vulnerability (SPV) associated with the relays to 4160 Volt Buses 23 and 24. This SPVissue was discovered in February 2005 and resulted in locking out all power sources to these buses. This EC was for both buses on each unit, and a work order package was generated for each bus to each transformer. The same drawing was included in each work order package. The electricians noted during the work on Bus 23 that two jumpers designated to be de-terminated in accordance with the drawing were not included in the work package. Subsequent discussions between the electricians' supervisor and design engineering personnel indicated that the jumpers should be removed as indicated by the drawing, and that the WO package would be revised to reflect this change. However, design engineering personnel and the work planner did not discuss the proposed WO change. Subsequently, the work planner revised the WO package to remove the jumpers without a review from engineering personnel. As a result, when the first jumper was removed from the unit auxiliary transformer, which was energized throughbackfeeding from the switchyard, Buses 23 and 24 (4160 Volts) were de-energized, followed by the loss of Buses 23-1 (4160 Volts) and Bus 28 (480 Volts) and the initiation of a Group II and Group III isolations. Prior to the loss of the buses, the 'A' shutdown cooling system pump was aligned to thereactor vessel, the 'C' shutdown cooling system pump was aligned to the spent fuel pooland the 'B' shutdown cooling system pump was in standby. As a result of the event, a 16loss of shutdown cooling occurred due to the tripping of the 'A' shutdown cooli ng syst empump which had been aligned to the reactor vessel. The 'B' shutdown cooling systempump was started approximately 35 minutes after the 'A' shutdown cooli ng system pumptripped. The reactor vessel temperature increased from 92 degrees Fahrenheit to 94 degrees Fahrenheit during this time. The inspectors reviewed IR 395280, control room logs, and the prompt investigation report, and discussed the sequent of events with the onshift shift manager. The licensee's preliminary investigation determined that removing the jumper from the unit auxiliary transformer was beyond the scope of theout-of-service which had been placed to allow work on the reserve auxiliary transformerwhich was de-energized. Additionally, an apparent cause evaluation was assigned for this event to understand what barriers failed and identify the appropriate corrective actions. During the event, the Unit 3 Division I power was an available power source to provide power to the 'B' and 'C' shutdown cooling system pumps through the Unit 3cross-tie breakers and both fuel pool pumps were available. Therefore, the licensee determined that the overall risk remained Green despite the temporary loss of shutdowncooling for approximately 35 minutes. This issue will be an unresolved item pending theinspectors review and assessment of the licensee's apparent cause evaluation.(URI 05000237/2005013-02).2Unit 3 Planned Maintenance Outage

a. Inspection Scope

The licensee conducted a planned maintenance outage on Unit 3 fromNovember 5, 2005, through November 24, 2005, to replace the 3B reactor recirculation system pump seal. During the outage the licensee also repaired and modified thesteam dryer, replaced the reserve auxiliary transformer, and overhauled 16 control roddrive system hydraulic control units.The inspectors verified that the licensee effectively conducted the shutdown, managedelements of risk pertaining to reactivity control during and after the shutdown, and implemented decay heat removal system procedure requirements in accordance withtechnical specifications and other plant procedures.The inspectors performed the following activities:

• conducted drywell walkdown to identify any reactor cool ant system leakage*attended control room operator turnover meetings to verify that the currentshutdown risk status was well understood and communicated*performed walkdowns of the main control room to observe the alignment ofsystems important to shutdown risk*reviewed selected issues that the licensee entered into its corrective actionprogram to verify that identified problems were being entered into the program with the appropriate characterization and significance*ensured that the licensee appropriately considered risk factors during thedevelopment and execution of planned activities*monitored licensee's troubleshooting efforts for emergent plant equipment issues

• performed plant walkdowns to observe ongoing work activities 17*conducted in-office reviews of selected issues that the licensee entered into itscorrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance*observed control rod withdrawals and initial transition to criticality

• monitored mode switch changes and observed portions of power ascensionThis represented one inspection sample.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed surveillance testing on risk-significant equipment and reviewedtest results. The inspectors assessed whether the selected plant equipment could perform its intended safety function and satisfy the requirements contained in Technical Specifications. Following the completion of each test, the inspectors determined that the test equipment was removed and the equipment returned to a condition in which it could perform its intended safety function.The inspectors observed surveillance testing activities and/or reviewed completedpackages for the tests, listed below, related to systems in the initiating event, mitigatingsystems, and barrier integrity cornerstones:*Unit 2 DOS 0250-03, Main Steam Isolation Valve Fail-Safe Closure Test,Revision 18*Unit 2 Reactor Coolant System Leakage Appendix A, Revision 99, Unit NSODaily Surveillance Log*DIS 1500-15, 2 Year Dresden 2 Low Pressure Coolant Injection Heat ExchangerDifferential Pressure Transmitter Calibration/Maintenance and Inspection, Revision 8*Unit 2 DOS 6600-07, Test Low Pressure Coolant Injection Swing Bus RelaysSetpoint Calibration, Revision 19*Unit 2 DOS 7100-10, High Pressure Seat Leakage Testing of Core SprayInjection Check Valves (IST), Revision 01*DOS 7000-21, Local Leak Rate Testing of Unit 2 Drywell Equipment Drain Sump(DWEDS) & Drywell Floor Drain Sump (DWFDS) Discharge Valves, Revision 2This represented six inspection samples.

b. Findings

No findings of significance were identified.

181R23Temporary Plant Modifications (71111.23)

a. Inspection Scope

The inspectors screened two active temporary modifications and assessed the effect ofthe temporary modifications on safety-related system functions as specified in the Updated Final Safety Analysis Report and Technical Specifications. The inspectors also determined if the installations were consistent with system design:*EC 357144, Revision 0, "Provide Alternate Flow Path from Containment CoolingService Water to Reactor Building Containment Cooling Water Heat ExchangerThis represented one inspection sample.

b. Findings

No findings of significance were identified.1EP4Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspectors performed a screening review of Revision 19 of the Dresden NuclearPower Station Annex to the Exelon Standardized Emergency Plan to determine whetherthe changes made in Revision 19 decreased the effectiveness of the licensee's emergency planning. The screening review of this revision did not constitute an approval of the changes and, as such, the changes are subject to future NRC inspectionto ensure that the emergency plan continues to meet NRC regulations.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.1EP6Drill and Training Evaluations (71114.06)December 6, 2005, Emergency Preparedness Performance Indicator Drill Exercise

a. Inspection Scope

The inspectors observed station personnel during a licensee-only-participationemergency preparedness drill exercise on December 6, 2005. The dr ill scenarioinvolved vehicle fire inside the protected area, fork truck collision through Unit 3emergency diesel generator louvers, reactor scram anticipated transient without scram, steam leak in the steam tunnel from a 'B' main steam line break, and 'B' main steam isolation valve failed to isolate. This observation was compared against the emergency plan requirements to determine the effectiveness of drill participants and the adequacyof the licensee's critique in identifying weaknesses and failures.

19This represented one inspection sample.

b. Findings

No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control To Radiologically Significant Areas (71121.01).1Plant Walkdowns and Radiation Work Permit (RWP) Reviews

a. Inspection Scope

The inspectors selectively reviewed the licensee's access controls and survey data for avariety of outage work areas located within radiation areas, high radiation areas and locked high radiation areas in the plant to determine if the radiological controls, postings and barricades were adequate. These areas included the Unit 2 and Unit 3 drywells, the Unit 2 traversing-in-core room, and general areas throughout the Unit 2/3 Reactor Buildings including the refuel floor. The inspectors also walked down and surveyed (using an NRC survey meter) selected areas in the Unit 2/3 Reactor, Turbine and Radwaste Buildings to verify that radiological conditions were consistent with area postings and controls. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.2OS2As Low As Is Reasonably Achievable (ALARA) Planning and Controls (71121.02).1

a. Inspection Scope

The inspectors reviewed plant collective refueling outage exposure history, currentexposure trends for the Unit 2 refueling outage (D2R19) and ongoing outage activities in order to assess current dose performance and exposure challenges. This included determining the plant's current 3-year rolling average for collective exposure in order to provide a perspective of significance for any resulting inspection finding assessment.The inspectors reviewed D2R19 work and the associated exposure (dose) projections,time/labor estimates and historical dose data for the following six work activities which were likely to result in the highest personnel collective exposures or were otherwise radiologically significant activities:

20*Drywell control rod drive system maintenance activities*Drywell steam dryer modification diving activities

• Main condenser maintenance

• Drywell nuclear instrumentation maintenance

• Drywell in-service inspection activities

• Drywell permanent shielding installationThe inspectors determined site specific trends in collective dose based on planthistorical exposure and source term data including historical Boiling Water ReactorAssessment and Control dose rate data. The inspectors reviewed procedures associated with maintaining occupational exposures ALARA and evaluated those processes used for D2R19 to develop dose projections including time/labor estimates, and to track work activity specific exposures. These reviews represented four inspection samples.

b. Findings

No findings of significance were identified..2Radiological Work Planning

a. Inspection Scope

The inspectors obtained the licensee's list of D2R19 refueling outage work ranked byestimated exposure and reviewed the following radiologically significant D2R19 work activities:*Reactor disassembly/reassembly and related activities (RWP 10005204)*Reactor steam dryer modification diving activities (RWP 10005205)

• Drywell nuclear instrumentation maintenance (RWP 10005230)

• Drywell control rod drive system maintenance (RWP 10005240)*Drywell reactor water cleanup system maintenance (RWP 10005241)*Hotwell maintenance/inspection (RWP 10005202)For each of the activities listed above, the inspectors reviewed the RWP, the ALARAPlan including specific task plan time/labor estimates and associated total effective dose equivalent (TEDE) ALARA evaluations (i.e., respirator evaluations), as applicable. The reviews were performed in order to verify that the licensee had established radiological engineering controls and dose mitigation criteria that were based on sound radiation protection principles in order to achieve occupational exposures that were ALARA. This also involved determining that the licensee had reasonably grouped the radiological work into activities that were based on historical precedence, industry norms, and/or special circumstances.The inspectors compared the exposure results achieved throughout most of theapproximate 20-day refueling outage including the dose rate reductions and person-rem expended with the doses projected in the licensee's ALARA planning for the above listed work activities and for other selected outage activities. Reasons for 21inconsistencies between intended (projected) and actual work activity doses as well astime/labor differences were examined to determine if the activities were planned reasonably well and to ensure the licensee was cognizant of and evaluated any work planning deficiencies.The interfaces between radiation protection, maintenance and scheduling groups werereviewed to varying degrees to identify potential interface problems. The integration of ALARA requirements into work procedures and RWP documents was evaluated to verify that the licensee's radiological job planning would reduce dose.The inspectors compared the person-hour estimates provided by maintenance planningand craft groups to the radiation protection ALARA staff with the actual work activity time expenditures in order to evaluate the accuracy of these time estimates.Work-In-Progress ALARA Reports were reviewed by the inspectors for those outagejobs that approached their respective dose estimates or that were otherwise generatedto document problems, to identify changes in work scope or to document variances in estimated versus actual doses. These reports were reviewed to verify that the licensee could identify problems and address them as work progressed. Additionally, the post outage radiation protection department report for the licensee's Unit 3 October -

November 2004 outage (D3R18) was reviewed to determine if corrective actions were taken for previous ALARA issues and if lessons learned were applied to D2R19 activities, as applicable.These reviews represented seven inspection samples.

b. Findings

No findings of significance were identified..3Verification of Dose Estimates and Exposure Tracking Systems

a. Inspection Scope

The inspectors reviewed the licensee's assumptions and basis for its collective refuelingoutage exposure estimate and for individual outage job estimates, and evaluated the methodology and practices for projecting work activity specific exposures. This included evaluating both dose rate and time/labor estimates for adequacy compared to historical station specific or industry data.The inspectors reviewed the licensee's process for adjusting outage exposure estimateswhen unexpected changes in scope, emergent work or other unanticipated problemswere encountered which could significantly impact worker exposures. This included determining that adjustments to estimated exposure (intended dose) were based on sound radiation protection and ALARA principles and not adjusted to account for failures to effectively plan or control the work. The frequency and scope of these adjustments was also reviewed to evaluate the adequacy of the original ALARA planning.

22The licensee's exposure tracki ng system was examined to determine whether the levelof exposure tracking detail, exposure report timeliness, and exposure report distribution was sufficient to support control of outage work exposures. Radiation work permits were reviewed to determine if they covered an excessive number of work activities to ensure they allowed work activity specific exposure trends to be detected and controlled.

During the conduct of exposure significant work, the inspectors evaluated if licensee management was aware of the exposure status of the work and would intervene if exposure trends increased significantly beyond exposure estimates. These reviews represented three inspection samples.

b. Findings

No findings of significance were identified..4Job Site Inspections and ALARA Controls

a. Inspection Scope

The inspectors observed Unit 2 reactor cavity decontamination, the initial stages ofreactor disassembly for Unit 3 in preparation for steam dryer inspections and observed hydro-testing and closeout inspection activities in the Unit 2 drywell using the licensee's closed circuit television system. The inspectors discussed dose reduction initiatives andresults with members of the radiation protection staff for dose significant activities completed earlier in the outage to assess the effectiveness of the ALARA program. The licensee's use of ALARA controls for these work activities was evaluated todetermine whether:*The licensee developed and effectively used engineering controls to achievedose reductions and to verify that the controls were consistent with the licensee'sALARA reviews*Workers were cognizant of work area radiological conditions, utilized low dosewaiting areas and that radiological oversight of work was adequateThese reviews represented three inspection samples.

b. Findings

No findings of significance were identified..5Monitoring of Declared Pregnant Women and Dose to Embryo/Fetus

a. Inspection Scope

The inspectors reviewed the licensee's monitoring methods and procedures, radiationexposure controls, and the information provided to declared pregnant women to determine if an adequate program had been implemented to limit embryo/fetal dose.

The inspectors also reviewed the pregnancy declaration and radiation exposure results 23for several individuals that declared their pregnancy to the licensee betweenNovember 2003 and October 2005, to verify compliance with the requirements of 10 CFR 20.1208 and 20.2106.These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.6 Radiation Worker and Radiation Protection Technician Performance

a. Inspection Scope

Radiation worker and radiation protection technician performance was observed by theinspectors during work activities being performed in radiation areas and high radiation areas focusing on work activities on the refuel floor and the Unit 2 drywell. The inspectors determined whether workers demonstrated the ALARA philosophy in practice by being familiar with the work activity scope, the tools to be used for the job by utilizinglow dose waiting areas and had knowledge of the radiological conditions and adhered to the ALARA requirements for the work activity. Job support and the communications provided by the radiation protection staff were also evaluated by the inspectors. This review represented one inspection sample.

b. Findings

No findings of significance were identified..7Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed the results of an outage readiness self-assessment and theresults of Nuclear Oversight Department field observations and audits of the radiation protection program to assess the licensee's ability to identify and correct problems.The inspectors verified that identified problems were entered into the corrective actionprogram for resolution, and that they had been properly characterized, prioritized, and were being addressed. This included ALARA program critique items and lessons learned from the licensee's previous Unit 3 refueling outage completed in October - November 2004.Corrective action reports (ARs) generated over the five month period that preceded theinspection that were related to the radiation protection program were selectively reviewed by the inspectors and licensee staff members were interviewed to verify that follow-up activities were being conducted in a timely manner commensurate with their importance to safety and risk using the following criteria:

24*Initial problem identification, characterization, and tracking*Disposition of operability/reportability issues*Evaluation of safety significance/risk and priority for resolution

• Identification of repetitive problems

• Identification of contributing causes

• Identification and implementation of effective corrective actionsThe licensee's corrective action program was also reviewed to determine if repetitivedeficiencies in problem identification and resolution had been addressed, as applicable. These reviews represented three inspection samples.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

.1Routine Quarterly Review

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issuesduring baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action system at an appropriate threshold,that adequate attention was being given to timely corrective actions, and that adversetrends were identified and addressed. In addition, in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. This review was accomplished by reviewing daily issue reports and attending daily issue report review meetings.

b. Findings

No findings of significance were identified..2Semiannual Review for Trends

a. Inspection Scope

The inspectors performed a review of plant deficiencies as documented in IRs,corrective action backlog lists and all of the nuclear oversight assessments, rework maintenance list, trend reports, engineering change backlog, the open temporary modification backlog, the deferred preventive maintenance backlog, and the change inthe number of Maintenance Rule a(1) systems over the last two quarters conductedduring the second, third, and part of the fourth quarter of 2005. This review was evaluated against the licensee's corrective action program and 10 CFR 50, Appendix B 25to determine if the licensee was effective at identifying trends that could indicate theexistence of a more significant safety issue. The inspector's review consisted of a 6 month period from June 2005 through December 2005, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectorsreviewed IRs generated during the time period of mid-June through mid-December 2005, in an attempt to identify potential trends. The screening was accomplished as follows:1.IRs dealing with company policies, administrative issues, and other minor issueswere eliminated as being outside the scope of this inspection.2.The IRs were sorted into categories involving same equipment problems,repetitive issues, reoccurring departmental problem/challenges and repeated entries into Technical Specifications. The IRs were then screened for potential common cause issues and considered for potential trends.3.The inspectors removed groups of IRs that discussed strictly programmaticproblems because the inspection requirement was primarily for equipment problems and human performance issues.4.The inspectors removed groups of IRs that discussed security issues becausethey will be reviewed and documented as necessary in a separate report duringa future inspection by a security specialist.5.The inspectors also removed groups of IRs where their review indicated thatduplicate IRs had been written for the same event or failure.6.The inspectors reviewed the IRs in which the title indicated a trend or potentialadverse trend were considered licensee-identified trends.7.The remaining groups, considered potential unidentified trends, were provided tothe licensee for discussion in case there was extenuating information that the inspectors were not aware of.8.Groups of IRs remaining after all of the above screening were considered trendswhich the licensee had failed to identify.9.The inspectors then were able to make an assessment by comparing the trendsidentified by the licensee to those trends identified by the NRC.This represented one inspection sample.

b. Findings

There were no findings of significance identified. The inspectors determined thatlicensee employees were writing IRs at an appropriate threshold, and that employees at all levels of the organization were writing IRs. The inspectors determined that the licensee had identified the same specific trends as the inspectors. Overall, the licensee identified issues adequately and entered them into their corrective action program.

264OA3Event Followup (71153)

a. Inspection Scope

The inspectors reviewed one licensee event report (LER) to ensure that the issuedocumented in the report was adequately addressed in the licensee's corrective action program. The inspectors interviewed plant personnel and reviewed operating and maintenance procedures to ensure that generic issues were captured appropriately.

The inspectors reviewed operator logs, the Updated Final Analysis Report, and other documents to verify the statements contained in the LER. The inspectors also reviewed one Unresolved Item to determine if the licensee was in violation of any regulatory requirements.

b. Findings

.1(Closed) LER 05000237;05000249/2005-003-00, Units 2 and 3 Offsite Power SourcesDeclared Inoperable Due to Low VoltageOn June 23, 2005, the station declared the offsite power sources for both unitsinoperable but available. The declaration was made based upon the predicted switchyard voltages provided by the load dispatcher, not meeting the licensee's minimum undervoltage requirements. This low voltage condition resulted in the licensee declaring the offsite power sources inoperable and entering TS 3.8.1, "AC Sources-Operating," for both units. Also, the licensee entered the appropriate abnormaloperating procedure in response to the predicted undervoltage conditions.

Subsequently, the licensee exited the TS and abnormal procedure when the load dispatcher provided a predicted voltage value which exceeded the minimum voltage requirements. As part of the corrective actions, the licensee installed two new transformers with load tap changers to compensate for the low voltage conditions. The LER was reviewed by the inspectors and no findings of significance were identified, and no violation of NRC requirements occurred. This condition was documented inIR 212836. This LER is closed.

This represented one inspection sample..2(Closed) URI 05000237/2003011-02, Unit 2 Potential Consequences of the LostFeedwater Sample ProbeDuring the 2001 Unit 2 refueling outage the licensee initiated actions to verify that thein-line feedwater sample probes, a total of three, were still intact after reviewing anoperating experience report (OPEX SEN 204, "Water Induced Fuel Leaks)." General Electric had previously issued SIL 257 on the same topic. The licensee's inspection identified that one of the three probes was missing. Therefore, the licensee installed anew probe which was designed differently to address the concerns in the OPEX and SIL. Also, the licensee performed a lost parts evaluation in November 2001 which concluded that there were no adverse consequences on the reactor vessel internals from the missing feedwater probe. At that time, the licensee did not note any damage to 27the feedwater spargers and did not attempt to locate the missing probe. However,during the Unit 2 November 2003 refueling outage the licensee identified damage to one of the four feedwater spargers. Subsequently, the licensee performed a boroscope inspection of the damaged sparger and identified the feedwater probe that was identifiedas missing in 2001 in that particular sparger. The sparger was repaired and the remaining three other spargers were not inspected. During a shut down of Unit 2 in December 2003, the licensee identified that the modified feedwater probe was missingand suspected inside one of the four spargers. The licensee generated an operabilityevaluation for the missing probe which was reviewed by the inspectors and determined acceptable.During the Fall 2005 refueling outage, the licensee inspected all four feedwater spargersand did not locate the missing probe. In addition, the licensee did not note any damageto any of the spargers which would have indicated that the probe had been inside the sparger. The inspectors reviewed the video tape of the sparger inspection and agreed with the licensee that the probe was not inside any sparger. The licensee initiated additional efforts in searching for the probe by disassembling and inspecting the feedwater inboard and outboard primary containment check valves and inspecting the lines downstream of the inboard check valves up to the elbow. The licensee documented the station's efforts in locating the missing feedwater sample probe in EC #358313, Revision 0, which concluded that the probe was most likely removed during replacement of the feedwater sparger to address design deficiencies with the sparger in the early 1980s. The licensee's efforts to search for and retrieve the missing probe met the licensee's commitment to the NRC in a letter, dated May 13, 2005. This URI is closed.

This represented one inspection sample.4OA5Other Activities.1Review of Institute of Nuclear Power Operations ReportsThe inspectors completed a review of the interim report for the Institute of NuclearPower Operations, December 2005 Evaluation, dated December 1, 2005. The onsiteinspections were conducted September 26 - 30, 2005, and October 3 - 7, 2005. Duringthe review the inspectors did not identify any new safety significant issues.The inspectors completed a review of the Dresden Accreditation Final Report, datedDecember 2005. The onsite inspection was September 12 - 16, 2005. The training programs evaluated included the Instrument and Control Technician and Supervisor, Electrical Maintenance Personnel and Supervisor, Mechanical Maintenance Personnel and Supervisor, Chemistry Technician, Radiological Protection Technician, and Engineering Personnel.

284OA6Meetings.1Exit MeetingThe inspectors presented the inspection results to the Site Vice President, Mr. D. Bost,and other members of licensee management on January 4, 2006. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Proprietary information was identified..2Interim Exit MeetingsInterim exit meetings were conducted for:

• Inservice Inspection (IP 71111.08), with Mr. D. Bost and other members oflicensee management at the conclusion of the inspection on November 9, 2005. The inspectors returned proprietary information reviewed during the inspection and the licensee confirmed that none of the potential report input discussed wasconsidered proprietary.*Occupational Radiation Safety ALARA program inspection during the licensee'sUnit 2 refueling outage with Mr. D. Wozniak on November 18, 2005.*Emergency Preparedness Inspection (IP 71114.04) with Mr. R. Ford onDecember 1, 2005 via telephone.4OA7Licensee-Identified ViolationsThe following violation of very low safety significance (Green) was identified by thelicensee and is a violation of NRC requirements which meets the criteria of Section VI ofthe NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV. Technical Specification 5.7 requires, in part, that individuals entering a high radiationarea be knowledgeable of the dose rate levels in the area. Technical Specification 5.4 requires that written procedures be established and implemented for activities provided in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Proceduresspecified in Regulatory Guide 1.33 include radiation protection procedures for access control to radiological areas, which are provided by licensee procedure RP-AA-460, "Controls for High and Very High Radiation Areas." The procedure requires that workers receive a high radiation brief from radiation protection prior to entry into a high radiation area. Contrary to these requirements, on September 1, 2005, three individualsentered a posted high radiation area in the Radwaste Building without knowledge of the dose rate levels in the area and had not received a high radiation area briefing from the radiation protection staff. This incident is documented in the licensee's corrective action program as CR 369795. This issue represents a finding of very low safety significance 29because it did not involve ALARA planning or work controls, there was no overexposureor substantial potential for an overexposure to the workers that entered the highradiation area, nor was the licensee's ability to assess worker dose compromised.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

D. Bost, Site Vice President

D. Wozniak, Plant Manager

H. Bush, Radiation Protection, Radiological Engineering Manager

R. Conklin, Radiation Protection Supervisor

R. Ford, Emergency Preparedness Manager

J. Fox, Design Engineer

R. Gadbois, Operations Director

D. Galanis, Design Engineering Manager

V. Gengler, Dresden Site Security Director

J. Griffin, Regulatory Assurance - NRC Coordinator

P. Salas, Regulatory Assurance Manager

M. Kanavos, Site Engineering Director

A. Khanifar, Nuclear Oversight Director

J. Kish, ISI Coordinator

S. Kroma, Reactor Services Project Manager

T. Loch, Supervisor, Design Engineering

M. McGivern, System Engineer

M. Mikota, Dry Cask Project Manager, Dresden

M. Overstreet, Lead Radiation Protection Supervisor

J. Strmec, Chemistry Manager

B. Surges, Operations Requalification Training Supervisor

G. Bockholdt, Maintenance Director

S. Taylor, Radiation Protection ManagerNRC pers onnel

M. Ring, Chief, Division of Reactor Projects, Branch 1IEMA personnel

R. Schulz, Illinois Emergency Management Agency

R. Zuffa, Resident Inspector Section Head, Illinois Emergency Management Agency

2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000237/2005013-01URIDetermination of the Site Bounding Steam Line05000249/2005013-01Break Analysis05000237/2005013-02URIInadequate Work Order Package Caused Loss ofShutdown CoolingClosed05000237/2003011-02URIUnit 2 Potential Consequences of the LostFeedwater Sample Probe05000237;05000249/2005-003LERUnits 2 and 3 Offsite Power Sources DeclaredInoperable Due to Low VoltageDiscussedNone

3

LIST OF DOCUMENTS REVIEWED

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

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that