IR 05000237/2019003

Integrated Inspection Report 05000237/2019003 and 05000249/2019003

ML19305B804
Person / Time
Site:	Dresden
Issue date:	11/01/2019
From:	Kenneth Riemer Division Reactor Projects III
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019003
Download: ML19305B804 (28)

Text

ber 1, 2019

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2019003 AND 05000249/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On October 8, 2019, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Dresden. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000237 and 05000249 License Numbers: DPR-19 and DPR-25 Report Numbers: 05000237/2019003 and 05000249/2019003 Enterprise Identifier: I-2019-003-0063 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Inspection Dates: July 01, 2019 to September 30, 2019 Inspectors: L. Alvarado Guilloty, Resident Inspector R. Elliott, Resident Inspector M. Garza, Emergency Preparedness Inspector J. Havertape, Resident Inspector A. Nguyen, Senior Resident Inspector C. Phillips, Project Engineer M. Porfirio, Illinois Emergency Management Agency Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Inadequate Work Instructions for Operationally Critical Work Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71152 FIN 05000249,05000237/2019003-01 Presence Open/Closed A self-revealed finding of very low safety significance was identified for the licensees failure to provide adequate work instructions for maintenance activities on multiple occasions in accordance with procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks. Specifically, between December 2018 and May 2019, two instances of inadequate work instructions were identified as being primary causes of improper maintenance performed on OPCC systems that caused operational transients.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000237/2019-002-00 LER 2019-002-00 for 71153 Closed Dresden Nuclear Power Station, Unit 2 Scram Due to Main Turbine Low Oil Pressure Trip.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On July 13, 2019, the unit was down powered to 70 percent for a control rod pattern adjustment. The unit returned to full power on July 14, 2019. On August 3, 2019, the unit was down powered to 68 percent for a control rod pattern adjustment. The unit returned to full power on August 4, 2019. Unit 2 began coast down for the upcoming scheduled refueling outage, D2R26, on August 14, 2019, and ended the inspection period in coast down.

Unit 3 began the inspection period at rated thermal power. On September 23, 2019, the unit performed an emergent down power and was taken off-line to repair an oil leak on the Unit 3 Main Power Transformer. During the forced outage (D3F52) for the transformer repairs, the unit maintained approximately 20 percent thermal power output without being connected to the grid.

The unit synchronized back to the grid on September 27, 2019, and returned to full power on September 29, 2019. The unit remained at rated thermal power for the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

===

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 isolation condenser alternate injection sources (primary out of service for maintenance) on September 3, 2019

(2) Unit 2 core spray system on September 17, 2019

(3) Unit 2 high pressure coolant injection system (HPCI) on September 19, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the cooling water systems on July 16 - 18, 2019.

==71111.05A - Fire Protection (Annual)

Annual Inspection (IP Section 03.02)==

===

(1) The inspectors evaluated fire brigade performance during a drill in the administration building on July 18, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Zone 8.2.1B, Unit 3 Condensate Pump Floor, Elevation 469 on July 9, 2019

(2) FZ 8.2.2B, Unit 3 CCSW Pump Floor, Elevation 495 on July 9, 2019

(3) FZ 1.1.2.3, Unit 2 Reactor Building General Area, Elevation 545 on July 31, 2019

(4) FZ 8.2.6A, Unit 2 Reactor Feed Pump Ventilation and Hydrogen Seal Oil Area, Elevation 538 on July 31, 2019

(5) FZ 8.2.5.C, Unit 2/3 EHC Reservoir and Condensate Demineralizer Areas, Elevation 517' on September 9, 2019

(6) FZ 8.2.6.C, Unit 2/3 Lube Oil Reservoir and Common Mezzanine Areas, Elevation 534' on September 9, 2019

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) 2A and 2C shutdown cooling heat exchangers

==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during an emergent down power on Unit 3 to take the turbine off-line for repairs to the Main Power Transformer on September 24, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02)==

(1) The inspectors observed and evaluated licensed operator requalification training with Emergency Preparedness requalification requirements in the control room simulator on August 29, 2019.

(2) The inspectors observed and evaluated licensed operator requalification training with Emergency Preparedness requalification requirements in the control room simulator on September 12, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Repetitive failures of the auxiliary electric equipment room (AEER) ventilation chiller compressors

(2) Unit 2 and 3 125V DC Power system and Batteries Quality Control (IP Section 02.02)===

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Unit 2 and 3 service water pump seal failures

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

===

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated plant risk and fire risk for emergent work on the service water (SW) and Unit 2 control rod drive (CRD) systems July 7 - 10, 2019

(2) Elevated plant risk due to emergent leak on the Unit 2 stator water cooling system on July 25, 2019

(3) Elevated plant risk due to emergent troubleshooting and repair of the Unit 2 channel

'B' fuel pool radiation monitor and the 3A service water pump on August 5, 2019

(4) Unit 2 on-line risk increase to Yellow due to trip of 345 kV Line 1202 and emergent work on Unit 3 to troubleshoot and repair the 3A fuel pool radiation monitor on September 3-5, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) 3A containment cooling service water (CCSW) keepfill system pressure below minimum limit

(2) Unit 3 125 VDC system level II ground

(3) 3B electromatic relief valve (ERV) flange torque low

(4) Potential vulnerability identified with torus vacuum breakers

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 and Unit 3 Fuel Pool Cooling pumps trip logic (permanent modifications)

(2) Defeating the Unit 2 'C' Moisture Separator High Level Switches Automatic Turbine Trip function (temporary modification)

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) DOS 1300-05, 2/3 B isolation condenser makeup pump capacity test, after preventive maintenance on August 21, 2019

(2) DFPS 4123-06, 2/3 diesel fire pump capacity test, after replacement on July 24 - 26, 2019

(3) DOS 6600-01, Unit 3 emergency diesel generator surveillance test, after work on the lubricating oil system on September 16, 2019

(4) DIS 1500-06, Unit 3 low pressure coolant injection recirculation loop select logic on September 3, 2019

(5) WO 4962865-13, Electrical Testing of Main Power Transformer 3, after bushing replacement on September 25, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated D3F52, Unit 3 forced outage to replace a leaking bushing on the Main Power Transformer, from September 23-27, 2019.

==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)==

(1) DIS 0260-12, U3 reactor core flow calibrated transmitter calibration on July 24, 2019

(2) DES 8300-58, Unit 2 125V main station battery technical specification surveillance test on September 10, 2019

(3) DOS 6600-08, Unit 3 EDG cooling water pump comprehensive test on September 16, 2019 Inservice Testing (IP Section 03.01)===

(1) Work Order 04936060-01, Unit 2 HPCI Inservice testing surveillance (IST) on September 18, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

===

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.

• Evaluation 18-45; Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30; February 7, 2019 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) 3rd Quarter Emergency Preparedness Full Team Drill on August 20,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 2, July 1, 2018 - June 30, 2019

(2) Unit 3, July 1, 2018 - June 30, 2019 MS08: Heat Removal Systems (IP Section 02.07) ===

(1) Unit 2, July 1, 2018 - June 30, 2019

(2) Unit 3, July 1, 2018 - June 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 2, July 1, 2018 - June 30, 2019

(2) Unit 3, July 1, 2018 - June 30, 2019 MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 2, July 1, 2018 - June 30, 2019

(2) Unit 3, July 1, 2018 - June 30, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

===

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Complete loss of power to security equipment due to failure of the UPS batteries

(2) Unit 2 turbine trip and reactor scram 71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)===

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000237/2019-002-00, Unit 2 Scram due to Main Turbine Low Oil Pressure Trip (ADAMS ML19189A087)

The circumstances surrounding this LER are documented in report Section 71152.

A Green finding related to this follow-up inspection is documented in the Results section.

INSPECTION RESULTS

Inadequate Work Instructions for Operationally Critical Work Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71152 FIN 05000249,05000237/2019003-01 Presence Open/Closed A self-revealed finding of very low safety significance was identified for the licensees failure to provide adequate work instructions for maintenance activities on multiple occasions in accordance with procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks. Specifically, between December 2018 and May 2019, two instances of inadequate work instructions were identified as being primary causes of improper maintenance performed on OPCC systems that caused operational transients.

Description:

On May 9, 2019, Dresden Unit 2 turbine tripped on low oil pressure which resulted in a reactor SCRAM. The turbine was inspected and found to have severe damage to the spline interface between the Main Gear Quill Shaft and the High Pressure turbine rotor. This led to a loss of power transfer between the main turbine and the Main Shaft Oil Pump (MSOP)which supplies bearing header pressure at rated speed, thus causing the low oil trip. The licensee performed a root cause analysis subsequent to this event and identified that the cause of the spline damage was due to oil starvation because of an improperly fabricated gasket that blocked oil lubrication feeding the Quill Shaft. The root cause was determined to be improper work order instructions that lacked detail needed to prevent human error during installation of the Quill Shaft Oil Nozzle. The work order instructions contained one step for the installation of the oil spray nozzle, which simply instructed workers to install the oil spray nozzleand verify the nozzle is centered. The actual work needed to complete this step involved identifying the proper gasket and fabricating it appropriately to fit the oil block, verifying proper oil flow after installation, and aligning the nozzle to ensure the oil lubrication traveled to all the correct components. Also, it was identified that a post-maintenance test (PMT) was never completed for the work (all work collectively) on the turbine front standard which could have included verifying proper lubrication of components. The contributing cause was determined to be inadequate supervision which failed to catch the missing work step details and provide intrusive observations during the work activity.

Exelon procedure, MA-AA-716-010, Maintenance Planning, Revisions 21-26, section 4.10 describes the level of detail required for work instructions. Level 1 work packages are for complex, infrequently performed work that presents high risk of single failure or errors that could cause a unit/generator trip or transient. These packages should contain minimal reliance on skill of the craft, must clearly provide acceptance criteria, such as clearances and torque values, and shall have technical human performance standards incorporated to prevent human performance errors, which include having steps to verify new parts satisfy fit, form, and functions and assuring appropriate detail to install components is provided. This procedure also provides the definition of a Critical Activity, which is an activity where the quality of the work cannot be fully assured through a PMT or the PMT can only be performed in a condition where the correction of any failure would cause a down power, dose impact, or impact outage critical path. Procedure MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks, Revisions 0-5, provide the definition of OPCCs and the categories of work for OPCC tasks. An Operational Critical Component (OPCC) is a critical component whose failure alone has or could have directly led to a significant (>20%) plant power transient. Operational Critical Component Work Requirement Standards are additional work controls administered through verification, oversight, technical review, or additional or more restrictive tolerances, that are incorporated into the work instructions for an OPCC that reduce the risk of introducing latent issues or operational failures because of improperly performed work.

For the turbine front standard work, as described above, the one large step of installing the oil spray nozzle did not meet the requirements of MA-AA-716-010 for a Level 1 package. Clear acceptance criteria were not provided, technical human performance standards were not adequately incorporated, and Critical Activities throughout the work package were not identified since no PMTs were required to validate the system configuration after maintenance. Also, the planning standards for OPCC work were not put into the work package, such as having additional verification, technical oversight, and supervisory oversight.

An additional example of a lack of adherence to proper work planning practices was identified that was similar in nature to the turbine front standard work. The inspectors determined that these items together (along with other equipment issues that did not have operational consequences) were indicative of programmatic issues with the licensee failing to follow the Maintenance Planning and Planning of OPCC Tasks procedures. The additional example is described below.

On December 20, 2018, it was identified that a leak on the Unit 3 electro-hydraulic control (EHC) skid had degraded significantly to a steady stream of approximately 10 gallons per day (from 2 gallons per day). At this time, the decision was made to emergently down power the unit to affect repairs to a leaking fitting on the suction line that leads to the accumulators on the EHC skid. An equipment cause evaluation was performed and determined that one of the causes of the event was maintenance leadership missed an opportunity for proper work order instruction challenge and oversight to support execution. During the prior refueling outage (October 2018), the EHC system had maintenance performed on it by supplemental employees which included replacing this fitting. The work package for this work was not considered a Level 1 work package and the EHC system was not flagged as an operationally critical system or component. However, further investigation revealed that the EHC system was, in fact, classified as an OPCC back in 2009 but the information for the system was not updated appropriately to account for this. Due to those facts, the package did not receive extensive reviews or challenges during the work planning process. Another cause identified for the leak was that the wrong material was selected for the fitting due to a lack of procedural guidance. There was operating experience available for proper material selection that was not incorporated into the work planning process. If the work package had been categorized differently, the more robust work planning standards of ensuring proper parts that satisfy form, fit, and function and work packages that contain minimal reliance on skill of the craft, would have been included in the work planning process. Also, additional supervisor oversight and reviews would have been required prior to and during the work.

Corrective Actions: For the turbine trip root cause, the licensee implemented corrective actions to prevent recurrence (CAPRs) which included updating the model work orders for maintenance on turbine front standards to ensure all steps had proper level of detail for work execution with minimal reliance on skill of the craft and added PMT steps for verifying proper oil flow for the front standard components. Another corrective action for this issue included developing a Key Steps process where all OPCC work orders, as a minimum, will have steps identified that require supervisor sign-offs and oversight, because of the execution significant or risk significant nature of the step.

For the EHC leak issue, the licensee implemented a Supplemental Worker Oversight Plan to improve work order challenges and increase the level of oversight at the time of work execution. Another corrective action for this issue included developing procedural guidance, including material selection and appropriate tightening methods, for flared fittings used in the EHC system.

Corrective Action References: ARs 4204937 and 4247636

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to follow procedures MA-AA-716-010, Maintenance Planning, and MA-AA-716-010-1015, Planning Operational Critical Component (OPCC) Tasks, was a performance deficiency. Specifically, on two separate occasions, equipment failures on OPCC systems occurred that caused operational transients (either needed emergent down powers for repair or caused a plant trip). The causes of the equipment failures were determined to be inadequate work instructions. The aforementioned procedures delineate the requirements for the level of detail needed in Level 1 work packages and also needed for OPCC work activities.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, on two separate occasions, equipment failures on OPCC systems, caused by inadequate work instructions, occurred that caused operational transients (either needed emergent down powers for repair or caused a plant trip).

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance (Green) because even though one of the events caused a reactor trip, mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition was not lost.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, for the events related to this finding, it was identified that management oversight of the work planning and execution processes was lacking and contributed to the events that occurred. It was determined that oversight of supplemental workers was lacking as a whole, including reviewing work packages and performing supervision of field activities. The licensee generated corrective actions from these events, as well as others, to address the intrusiveness, standards, and expectations of supervisors going forward and clearly defining their roles and responsibilities in the work planning process.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: Loss of Power to all Security Equipment due to UPS Battery 71152 Failure On November 4, 2018, power for critical security equipment was being transferred from the security diesel generator back to its normal power supply. As part of this evolution, an uninterruptible power supply (UPS) carries the loads for a certain period of time. It was during this time on the UPS system that a loss of power occurred to all the loads being carried by the UPS. Appropriate compensatory measures were put into place, power was restored after the initial inspection of equipment, and an equipment cause analysis was performed after the event. Two causes were identified during the causal review: 1) the licensee failed to properly monitor the UPS battery conditions which prevented identification of the degraded battery and 2) improper technical rigor was used during the engineering change that replaced the batteries after a similar failure occurred in 2014. The inspectors reviewed the supporting information for these cause determinations and concluded the most likely causes were failure to properly monitor the UPS battery conditions and inappropriate corrective actions taken for previously identified conditions (i.e. battery environment) from the 2014 failure. The licensee also had operating experience available in the 2014 and subsequent time frames to be able to identify that the batteries were not being maintained properly from both environmental conditions and from monitoring and control perspectives.

The licensee agreed with the inspectors that their actions taken from previous events could have mitigated, if not prevented, this failure and are taking appropriate actions to incorporate the lessons learned into their CAP process. The inspectors reviewed the licensee's corrective actions for this event and determined that they were written to address the identified causes properly and were executed in a timely manner in accordance with their safety significance. There was a performance deficiency identified by the inspectors for this event. It will be documented in Inspection Report 2019-0411.

Observation: Review of Root Cause for Unit 2 Turbine Trip 71152 On Thursday, May 9, 2019, Dresden Unit 2 turbine tripped on low oil pressure which resulted in a reactor SCRAM. The turbine was inspected and found to have severe damage to the spline interface between the Main Gear Quill Shaft and the High Pressure turbine rotor. This led to a loss of power transfer between the main turbine and the Main Shaft Oil Pump (MSOP) which supplies bearing header pressure at rated speed, thus causing the low oil trip.

The licensee performed a root cause analysis subsequent to this event to review the turbine inspection information, prior work history for the main turbine, and relevant operating experience. It was identified that the cause of the spline damage was due to oil starvation because of an improperly fabricated gasket that blocked oil lubrication feeding the Quill Shaft.

The root cause was determined to be improper work order instructions that lacked detail needed to prevent human error during installation of the Quill Shaft Oil Nozzle. The contributing cause was determined to be inadequate supervision which failed to catch the missing work step details and provide intrusive observations during the work activity. The inspectors reviewed the work order and the licensees procedures for work and maintenance planning and determined that the root cause was reasonable. The work order instructions contained one step for the installation of the oil spray nozzle, which simply instructed workers to install the oil spray nozzleand verify the nozzle is centered. The actual work needed to complete this step involved identifying the proper gasket and fabricating it appropriately to fit the oil block, verifying proper oil flow after installation, and aligning the nozzle to ensure the oil lubrication travels to all the correct components. Also, it was identified that a post-maintenance test (PMT) was never completed for the work (all work collectively) on the turbine front standard which could have included verifying proper lubrication of components.

The licensee determined that a PMT was not standard practice for this type of work activity. .

The licensee implemented corrective actions to prevent recurrence (CAPRs) which included updating the model work orders for maintenance on turbine front standards to ensure all steps had proper level of detail for work execution with minimal reliance on skill of the craft and added PMT steps for verifying proper oil flow for the front standard components. The inspectors concluded that these CAPRs seemed appropriately focused to address the root cause and preclude repetition. The CAPRs were also being implemented in a timely fashion prior to start of the next refueling outage when turbine front standard work will be conducted.

Another corrective action included developing a Key Steps process where all operationally critical (OPCC) work orders, as a minimum, will have steps identified that require supervisor sign-offs and oversight, because of the execution significant or risk significant nature of the step. This action addressed both the root cause and the contributing cause. The inspectors will ensure the effectiveness of this corrective action when reviewing work orders for the next refueling outage to ensure the process is utilized appropriately.

The licensee also performed an extent of cause and extent of condition review for this event.

It was determined that the work order for the turbine front standard work was classified as a Level 1 work package on an OPCC component. Per the licensees work and maintenance planning processes, Level 1 package should include sufficient detail with minimal reliance on skill of the craft and can include Critical Activities to ensure a high level of maintenance work execution. As corrective actions to address this, the licensee reinforced the standards for planning and reviewing Level 1 OPCC work packages and performed a comprehensive review of other work on the turbine and generator systems prior to the next refueling outage to ensure Critical Activities were identified for component work that had the potential to impact the proper operation of the systems once returned to service (i.e. ensuring design features that could block or resist flow were properly fabricated and assembled). The licensee also shared this operating experience with the other sites within the fleet that could be impacted by work on GE turbines done by supplemental workers. The inspectors determined that the licensee appropriately performed the extent of condition and cause assessments, although it was noted that other systems, not just the turbine and generator systems, could be considered Level 1 OPCC activities that could be completed by supplemental workers and should be considered when reviewing work packages for identifying Critical Activities and Key Steps. This was discussed with the licensee and these work packages are currently under review prior to the next refueling outage. The inspectors determined that the corrective actions for the extent of cause and condition seemed reasonable, were being implemented in a timely manner, and were appropriately shared within the fleet as operating experience to address any potential generic implications when conducting this type of maintenance.

This event and cause evaluation was reviewed by the inspectors for a potential performance deficiency. A finding was identified for failure to provide adequate work instructions to perform the work, as described by the identified root cause above. This finding is documented in the results section.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 8, 2019, the inspectors presented the integrated inspection results to Mr. P. Karaba and other members of the licensee staff.

• On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per IP 71114, Attachment 4 inspection results to Mr. L. Baker, EP Fleet Programs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04Q Corrective Action 2509721 Water Leaking Out of Capped End of 2/3-4399-41B 06/02/2015

Documents 4144225 Isolation Condenser 2-1301-3 Valve Troubleshooting 06/04/2018

231262 Solenoid Buzzing on 2-1301-20 Valve 03/19/2019

277181 OPS Services Crew Clock Reset - Tagout Special 09/03/2019

Instructions

Drawings M-27 Diagram of Core Spray Piping AAN

M-28 Diagram of Isolation Condenser Piping LR

M-51 Diagram of High Pressure Coolant Injection Piping CV

M-51 High Pressure Coolant Injection System and Instrumentation 05

Miscellaneous Tagout: 02-43- Disassemble & Inspect 2-4399-73, Iso Fill Check Valve 09/03/2019

2019043-001

Procedures DOP 1300-M1/E1 Unit 2 Isolation Condenser System Checklist 22

DOP 1400-E1 Unit 2 Core Spray System Electrical Checklist 04

DOP 1400-M1 Unit 2 Core Spray System 24

DOP 2300-M1/E1 Unit 2 HPCI System Checklist 39

DOS 1300-02 Isolation Condenser Valve Operability Check 21

71111.04S Corrective Action 1671923 TBCCW HX SW Inlet Vlv Leaking 06/17/2014

Documents 2603789 U2 TBCCW TCV Tube Track Support for Air Lines Not 12/22/2015

Secured

2647884 Degraded Flex Hose for 3A CB Casing Eqz ISO Valves 03/30/2016

29005 MO 2-3903-B Will Not Close From Remote Control Switch 10/17/2016

4059747 TBCCW Piping at 3B Cond Pump in Contact - Needs 10/02/2017

Support

4165056 U3 EHC TBCCW TCV has Corrosion 08/17/2018

4190724 3-3903-A Did Not Operate From the Control Room 11/01/2018

4191332 3A TBCCW HX Tube Side Vent Plugged 11/02/2018

4191334 3B TBCCW HX Vent Line Plugged 11/02/2018

4193329 Packing Leak Noted on 3-3903-B 11/09/2018

216616 Packing Leak on U2 'B' TBCCW HX SW Inlet Valve 02/02/2019

231347 3B TBCCW Heat Exchanger Tube Plugging 03/20/2019

231399 3B TBCCW Heat Exchanger Flange Corrosion 03/20/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

249402 3-3399-451B 3B TBCCW HX Tube Side Drn Vlv Leaking By 05/15/2019

264483 2A TBCCW Pump Seal Leak 07/16/2019

265165 3B RBCCW HC TCV is Full Open and Bouncing 07/18/2019

Engineering 622648 RBCCW/TBCCW Tube Plugging Evaluation 01/2018

Changes

Procedures DOP 3700-M2/E2 Unit 2 RBCCW System Checklist 17

DOP 3800-1 Unit 3 Turbine Building Closed Cooling Water System 14

Checklist

DOP 3800-M1 Unit 2 Turbine Building Closed Cooling Water System 15

Checklist

71111.05A Fire Plans FZ N/A Administration Building, 1st Floor 2

Procedures OP-AA-201-003 Fire Drill Performance 17

71111.05Q Corrective Action 4277837 Work Not Performed Due to Leaky Isolation 09/09/2019

Documents

Drawings M-23 Diagram of Fire Protection Piping AJ

Fire Plans FZ 1.1.2.3 Unit 2 Reactor Building General Area, Elevation 545 5

FZ 8.2.1B Unit 3 Condensate Pumps Floor, Elevation 469 3

FZ 8.2.2B Unit 3 CCSW Pumps Floor, Elevation 495 3

FZ 8.2.5.C Unit 2/3 EHC Reservoir Area Elevation 517' 3

FZ 8.2.5.C Unit 2/3 Cond. Demin. Area Elevation 517' 2

FZ 8.2.6.C Unit 2/3 Lube Oil Reservoir Area Elev. 534' 3

FZ 8.2.6.C Unit 2/3 Heat Exchanger Area Elevation 534' 5

FZ 8.2.6A Unit 2 Reactor Feed Pump Ventilation and Hydrogen Seal 6

Oil Area, Elevation 538

Miscellaneous Tagout: 00-41- 2/3 Cable Tunnel Fire Protection Strainer Inspection and 09/09/2019

2019041-005 Misc. Work

Procedures OP-AA-201-007 Fire Protection System Impairment Control 0

OP-AA-201-009 Control of Transient Combustible Material 23

71111.07A Corrective Action 4268275 FME in 2A SDC HX 2-1003-A 07/31/2019

Documents 4274841 FM Retrieved From 2C SDC Heat Exchanger 08/27/2019

282295 Results of SPC 4268275-04 07/31/2019

Miscellaneous Eddy Current Examination Final Report for 2A Shutdown July 2019

Cooling Heat Exchanger

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures DTP 75 Heat Exchanger Inspection Program 00

ER-AA-310-1002 Service Water Heat Exchanger Inspection Guide 8

Work Orders 00847755 Eddy Current Test on 2A SDC HX 08/20/2011

01477606 Eddy Current Test 2A SDC HX 07/30/2019

71111.11Q Corrective Action 4281544 Steam Leak From 3B1 FW Heater Upstream of 3-3607A 09/23/2019

Documents 4281563 Unexpected Alarm 903-3 F-1, Area Rad Monitor Downscale 09/23/2019

281573 U3 CRD H-06 Failure to Settle During Downpower 09/23/2019

Miscellaneous LORT Simulator Guide with DEP Opportunity 19-01A 08/29/2019

Procedures DGP 01-01 Unit Startup 197

71111.12 Corrective Action 4082328 AEER Thermostat Not Controlling Proper AEER Temp 12/08/2017

Documents 4140956 U1 125 VDC Battery Terminal Corrosion 05/24/2018

4166399 U2/3 BOP 250 VDC Batt Sys Trouble 08/22/2018

4172858 U2 250VDC Charger DC Voltmeter 09/13/2018

4175775 U1 125 VDC Battery Discrepancy Found During Quarterly 09/22/2018

Surveillance

4183312 250 V Voltmeter at 903-8 Requires Calibration 10/13/2018

4183443 Compressor Trip Leads to DOA Entry (DOA 5750-01) 10/14/2018

4184691 AEER Condensing Unit Trip 10/17/2018

4186708 Aux Electric Equipment Room A/C Unit Keeps Tripping 10/23/2018

4187463 U3 250 VDC Battery Surveillance Descrepancies 10/25/2018

4189223 'B' AEER Compressor Not Running 10/30/2018

4193837 U2 250 VDC Batt Ground With U3 HPCI AOP Running 11/11/2018

4196472 U3 Alt Batt Elevated Intercell Resistance Reading 11/20/2018

4197461 U3 250VDC Cell 110 Voltage Low 11/25/2018

4197708 ETB Vent Performance Challenging U2 TS Battery 11/26/2018

Temperatures

4199704 TR-86 System Battery Has a Degraded Intercell Plate 12/03/2018

202901 MRule Function 5714-1 Needs (a)(1) Determination 12/13/2018

203895 TR-86 Relay House Battery Issues 12/17/2008

204924 Corrosion on U1 Batteries 12/20/2018

204986 U1 125 VDC Has 1 Cell With Voltage Low 12/20/2018

205733 'B' AEER Compressor Found Tripped 12/25/2018

206067 AEER HVAC B Compressor Needs Eval Due To Trip On 05/27/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Low Oil

207078 U2 125 VDC Battery Ground - Unexpected Alarm 12/31/2018

207290 U3 250V Battery System Cable Insulation Cracked 01/01/2019

207616 Battery Cell Specific Gravities Found High 01/02/2019

209140 U3 125 VDC Ground 01/08/2019

209145 U3 24/28V A Negative Cell 4 Low Volts 01/08/2019

209605 Entered DOA 5750-01 for AEER Ventilation Failure 01/10/2019

212946 U2 125 VDC Battery Ground 01/22/2019

22849 Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground 02/23/2019

24966 Unexpected Alarm: U2 125 VDC Ground 02/28/2019

25117 U2 125 VDC Ground Alarm, 902-8 C-9 03/01/2019

25524 Unexpected Alarm: Unit 2 125 VDC Ground Alarm 03/01/2019

26960 Unexpected Alarm 9902-8 C-9, U2 125 VDC Batt Ground 03/06/2019

234155 Unknown Substance Found Floating in Cell of Battery 03/29/2019

234682 U1 B 125VDC Charger 03/30/2019

236853 P-105B 1B Battery Charger Could Not Maintain Correct 04/05/2019

Voltage

247556 DOA 5750-01 Entry for AEER Temp Hi 05/08/2019

250039 Corrosion Found on U1 125VDC Batteries 05/18/2019

252768 U3 125VDC Discharge Rate High Alarm 05/30/2019

254008 Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground 06/03/2019

255478 U3 125 VDC Batt Ground 06/08/2019

259821 Corrosion Identified During Battery Surveillance 06/27/2019

262209 U3 125 VDC Battery Ground 07/06/2019

262260 2/3 Service Water Pump Packing Degraded 07/06/2019

262914 Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground 07/09/2019

264658 U1 125 VDC Battery Terminal Corrosion 07/17/2019

266014 U2 125 VDC Ground Alarm 07/22/2019

267550 Unexpected Alarm: U3 125 VDC Batt Ground 07/28/2019

268532 2A LPCI Room Cooler Inspection and Testing 07/31/2019

272610 2B Service Water Pump Mechanical Seal Leakage 08/16/2019

Excessive

273689 Quality Issue from EagleBurgmann Repair Facility 08/22/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Drawings DR-PSA-005.16 Figure 2-6, ECCS Room Cooling Water/Diesel Generator 7

Cooling Water

Miscellaneous Maintenance Rule System Basis Document for Dresden 08/12/2019

Unit 2, 39-1; Unit 0, 39-2; Unit 3, 39-2

Maintenance Rule System Basis Document for Dresden 08/12/2019

Unit 3, OOS-39-3

Maintenance Rule System Basis Document for Dresden 08/13/2019

Unit 2, 15-8

Maintenance Rule System Basis Document for Dresden 07/31/2019

Unit 2, Systems 83-1, 83-2, and 83-3

U0 Auxiliary Electric Equipment Room HVAC Maintenance 0

Rule a(1) Action Plan

Maintenance Rule System Basis Document for Dresden 07/31/2019

Unit 3, Systems 83-1, 83-2, and 83-3

DCR EC 618991 Design Consideration Summary: Service Water Pump 000

Mechanical Seal VTIP D1171 Revision

DCR EC 628838 Design Considerations Summary: Addition of Eagle 000

Bergman Seals to the VTIP D1171 for Usage on Service

Water Pumps

DCS EC 401788 Install 2/3 Service Water Pump Open Line Shaft Design with 000

Greene Tweed

Eagle Burgmann Manufacturer Operating Manual 7.0

Mechanical Seal

(M.S.)

Flowserve Installation Instructions from Manufacturer

Durametallic PSS

III, Split Seal

Procedures ER-AA-320 Maintenance Rule Implementation Per NEI 18-10 00

ER-AA-320 Maintenance Rule Implementation per NEI 18-10 00

ER-AA-320-1001 Maintenance Rule 18-10 - Scoping 00

ER-AA-320-1003 Maintenance Rule 18-10 - Failure Definition 00

ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 00

Dispositioning Between (a)(1) and (a)(2)

ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 01

Inspection Type Designation Description or Title Revision or

Procedure Date

Dispositioning Between (a)(1) and (a)(2)

ER-AA-320-1006 Maintenance Rule 18-10 - Expert Panel Roles and 00

Responsibilities

OP-AA-108-112 Plant Status and Configuration 11

OP-AA-108-112- Response to Identified Component Mispositionings 5

1001

71111.13 Corrective Action 4246346 3-1705-16B Spiked Causing RBV Trip and SBGT Auto-Start 05/04/2019

Documents 4255645 Water Leak Between 2A Stator Pump and Head Tank 06/10/2019

261968 3A SW Pump Packing Leak 07/05/2019

262149 2B Service Water Pump Mechanical Seal Leakage 07/05/2019

Excessive

262637 2A CRD Pump Inboard Seal Leak 07/08/2019

262824 Water Inside 2A CRD Feed Pump Breaker Cubicle 07/09/2019

263043 2/3 SW Pump Breaker Closing Springs Did Not Discharge 07/10/2019

on R/O

263049 Breaker does not Indicate Disconnected when Disconnected 07/10/2019

263271 2/3 Service Water Pump Overcurrent Relay 07/11/2019

263438 3B Service Water Pump Seal Leak 07/11/2019

266695 U2 SWC Leak Upstream of 2-7400-Y-85 and 2-7400-Y-87 07/24/2019

267145 Extent of Condition for U2 SWC Leak. PI 2-7400-YGA9 07/26/2019

267145 Extent of Condition for U2 SWC Leak. Remove PI 2-7400- 07/26/2019

YGA9

267147 Extent of Condition for U2 SWC Leak. Remove PI 3-7400- 07/26/2019

YGA8

267158 Extent of Condition for U2 SWC Leak. Remove PI 3-7400- 07/26/2019

YGA9

267161 Extent of Condition for U2 SWC Leak. PI 2-7400-YGA8 07/26/2019

268629 Excessive Packing Leakage on 3A SWP 08/01/2019

269595 Unexpected Alarm - U2 Fuel Pool CH B Rad Hi 08/05/2019

269658 Corp Eng Evaluate Fleet Fuel Pool Rad Monitor Trip Logic 08/05/2019

269675 902(3)-3 E-16, RX Building Fuel Pool CH B Rad Hi DAN 08/05/2019

Enhancement

276469 Unexpected Alarm - U3 Fuel Pool CH A Rad Hi 09/03/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

276578 RB Vent Stack System Flow Rate Monitor INOP 09/03/2019

276626 Unexpected Alarm 903-3 C-16, RX Bldg Fuel Pool Ch A Rad 09/03/2019

Hi

277614 L1202 Trip Post-Job Critique 09/03/2019

Drawings Schematic Diagram 345KV Switchyard Annunciator Panel Y

23-2

M-22A P&ID Stator Cooling System I

Miscellaneous Protected Equipment Lists for Unit 2 and Unit 3 Risk

Significant Systems

Procedures DAN 902(3)-7 B- Stator Clg PP Trip 12

DAN 903-3 C-16 RX Bldg Fuel Pool Ch A Rad Hi 16

DAN 923-2 A-2 GCB 3-4 Trip 9

DAN 923-2 A-3 GCB 4-5 Trip 9

DAN 923-2, A-5 Line 1202 Transfer Trip 8

DOA 7400-01 Failure of the Stator Coolant System 38

OP-AA-108-117 Protected Equipment Program 5

OP-DR-201-012- Dresden On-line Fire Risk Management 6

1001

WC-DR-104-1001 Dresden 345KV Switchyard Configuration Risk Assessment 8

Work Orders 04946790 Excessive Packing Leakage on 3A SWP 08/05/2019

04947812 Troubleshoot and Repair U2 Fuel Pool CH B Radiation High 08/05/2019

Alarm

04956357 Unexpected Alarm - U3 Fuel Pool CH A Rad Hi 09/03/2019

71111.15 Corrective Action 4209140 U3 125 VDC Ground 01/08/2019

Documents 4212946 U2 125 VDC Battery Ground 01/22/2019

217329 Unexpected Alarm, U3 125 VDC Ground, Annunciator 903-8 02/05/2019

C-9

218106 903-8 C-9 U3 125 VDC Battery Ground During DES 0700-03 02/07/2019

24966 Unexpected Alarm: U2 125 VDC Ground 02/28/2019

25117 U2 125 VDC Ground Alarm, 902-8 C-9 03/01/2019

25524 Unexpected Alarm: Unit 2 125 VDC Ground Alarm 03/01/2019

25524 Unexpected Alarm: Unit 2 125 VDC Ground Alarm 03/01/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

26960 Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground 03/06/2019

29076 Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground 03/13/2019

249714 Unexpected Alarm 902-8 C-9, U2 125 VDC Batt Ground 05/16/2019

252768 U3 125 VDC Discharge Rate High Alarm 05/30/2019

254008 Unexpected Alarm 903-8 C-9, 125 VDC Batt Ground 06/03/2019

256427 Low Pressure at Valve 3-151-77A (PI 3-1501-61A) CCSW to 06/12/2019

HX

261991 Follow-up Investigation on IR 4256427 06/12/2019

262209 U3 125 VDC Battery Ground 07/06/2019

263744 EP Exercise Identifies Unanalyzed Condition 07/12/2019

267550 Unexpected Alarm: U3 125 VDC Batt Ground 07/28/2019

270286 Pressure Gauge Out of Tolerance During Power Labs 08/07/2019

Calibration

270818 Unexpected Alarm 902-8 C-9 U2 125 VDC Battery Ground 08/09/2019

Engineering 345321 Evaluate the Impact of Additional Weight due to Replacing 0

Changes Hex Nuts with Hydraulic Nuts and Perform the Owner

Acceptance Review of the Vendor Report

Operability 00064004345 Containment Cooling Service Water (CCSW) System Water 03/21/2001

Evaluations Hammer/Loss of Keep-Fill Analysis

Procedures DAN 902(3)-8 C- U2/3 125 VDC Battery Ground 09

DOP 6900-07 125 VDC Ground Detection - Unit 3 40

71111.18 Corrective Action 4273402 3B FPC Pump Trip During Train Swap 08/21/2019

Documents 4283066 Unexpected Alarm 902-7 B-5 DEHC and 902-6 A-3 Level 09/28/2019

High

Drawings 12E-3548 Schematic Diagram Fuel Pool Cooling Pump Alarm Circuit S

and Indication

M-362 Diagram of Fuel Pool Cooling Piping BG

M-373 Diagram of Fuel Pool Filter & Demineralizing Piping AG

Engineering 627310 Modify U3 A&B Fuel Pool Cooling Pump Trips 01

Changes 627311 Modify U2 A&B Fuel Pool Cooling Pump Trips 1

29532 Defeat the Automatic Turbine Trip From the 2C Moisture 000

Separator High Level

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures CC-AA-112 Temporary Configuration Changes 27

DAN 902(3)-5 B-8 Moisture Separator Lvl Hi-Hi 14

DAN 902(3)-7 B-5 Turbine Control Minor Trouble 13

DAN 9902(3)-6 A- Unit 3 Moist Separator Lvl Hi 06 and 07

Work Orders 04889934 Modify U2B Fuel Pool Cooling Pump Trips 08/26/2019

04889935 Modify U3A Fuel Pool Cooling Pump Trips 08/21/2019

04889936 Modify U3B Fuel Pool Cooling Pump Trips EC 627310 08/20/2019

04964530 Defeat the Automatic Turbine Trip From the 2C Moisture 09/28/2019

Separator High Level Switches

71111.19 Corrective Action 4250799 U3 EDG Lube Oil Gallery Sightglass 05/21/2019

Documents 4257556 U3 EDG Lower Lube Sightglass Still Empty 2 Shifts After 06/17/2019

267142 Incorrect Gaskets Installed on 2/3 DFP Oil Cooler 06/26/2019

268385 4.0 Critique - 2/3 DFP Capacity Run 07/27/2019

272885 2/3B Iso Cond M/U Pump Failed to Start Initially 08/19/2019

273328 Crack on Valve Cover 08/19/2019

273472 Increased Fuel Leakage Past 2/3B IC MU PP Inj Vent Valve 08/21/2019

273517 Overfilling of 2/3B ISO Condenser Coolant 08/21/2019

273842 Fuel Leak from Casing Vent on B ISCO Cond. Diesel Engine 08/21/2019

276621 dPIS 3-0261-34A Found OOT 09/04/2019

279832 U3 EDG Exhaust Manifold Cylinder #8 Temp High 09/16/2019

279835 U3 EDG Exhaust Manifold Cylinder #17 Temp Low 09/16/2019

280590 4.0 Critique on U3 EDG Work 09/19/2019

285704 Documentation of SFRA Testing of H3 Winding 09/26/2019

Drawings 203LN001-001 Low Pressure Coolant Injection System and Instrumentation 02

203LN001-002 LPCI Initiation Logic 01

203LN001-003 LPCI LOOP Select Logic 02

20700LN001-001 Unit 2 Isolation Condenser System 03

20700LN001-011 Isolation Condenser Makeup Pump System 01

233LN001-001 Fuel Pool Cooling System 04

233LN006-001 Primary Containment Atmosphere Monitoring 02

M-478 Diagram of Diesel Generator Lube Oil Piping 1

Procedures DIS 1500-06 LPCI System Recirculation Loop Break Detection 19

Inspection Type Designation Description or Title Revision or

Procedure Date

DOS 1300-05 2/3 A(B) Isolation Condenser Makeup Pump Capacity Test 10

MA-MW-773-035 Nuclear Operational Analysis Department Testing of Power 3

Transformers

Work Orders 01032433-01 D3 10Y PM Recirc Loop Brk LPCI Injection DPIS 34A 09/04/2019

Replacement

01930470 D2/3 2Y Com 'B' Iso Cond Make-up Pump Capacity Test 08/21/2019

04811173 PMT Replaced Pump 07/27/2019

04915930-01 Diesel Generator Fast Start Operability Surv. 09/17/2019

04924706 D2/3 Qtr Com 'B' Iso Con Make-up Pump Operability 08/21/2019

04933408-03 Replace U3 D/G Lube Oil Cooler Outlet Check Valve 09/17/2019

04933409-02 WR to install Ultrasonic Flowmeter U2 EDG Pre-Lube Oil 09/16/2019

Line

04962865-13 Elec Testing of Main Power Transformer 3 09/25/2019

71111.20 Corrective Action 4281463 MPT 3 Oil Leak Identified 09/23/2019

Documents 4281514 U2 and U3 Main Generator Output Spikes 09/23/2019

281858 D3F52 LL - Storage Requirements for MPT Transformer 09/24/2019

Bushings

282111 U3 MPT TR 3 Neutral H0 Bushing as Found 09/25/2019

282233 U3 Main Turbine Turning Gear Will Not Engage 09/25/2019

282235 U3 Turbine Bearing Lift Pump Trip Alarm 09/25/2019

282614 903-7 B-5 Turbine Control Minor Trouble 09/26/2019

282910 U3 Main Turbine Bearing #1 Thermocouple 3-5600-T1 09/27/2019

Degraded

283118 3B RFP Discharge Valve Failed to Open During Pump Start 09/28/2019

283235 Unexpected Alarm 903-3 A-2, MN Steam Line Rad Hi 09/28/2019

283285 Furmanite Box Leaking in U3 RFP Room 09/29/2019

Engineering 443003 Fabricate Expansion Plate for Dresden U3 MPT

Changes

Miscellaneous OP-AA-10-117 Protected Equipment List for Unit 3 TR32 09/24/2019

Work Orders 04938495 Replace VSVA Card 3-5650-31-5-S1-10 09/25/2019

04962865 Repair/Replace U3 MPT High Side Neutral Bushing 09/25/2019

71111.22 Corrective Action 4175530 SJAE Anomalies Noted during HPCI Surveillance on Unit 2 09/20/2018

Documents 4177295 Unit 2 HPCI Oil 09/26/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

4179417 U3 HPCI Surveillance 4.0 Critique 09/12/2018

278206 U2 1125VDC Ground Alarm 09/10/2019

281159 Crew 4 Clock Reset - U2 HPCI IST Run 4.0 Critique 09/18/2019

Procedures DES 8300-58 Unit 2 125 Volt Main Battery Modified Performance Test 21

DIS 0260-12 Reactor Core Flow Calibrated Transmitter Calibration 04

DOS 6600-08 Diesel Generator Cooling Water Pump Quarterly and 64

Comprehensive/Preservice Test for Operational Readiness

and In-Service Test (IST) Program

Work Orders 04678506-01 D3 24M TS RX Core Flow Calibrated Transmitter CAL 07/24/2019

04706728 D3 2Yr Diesel Generator Cooling Water Pump 09/16/2019

Comprehensive Test for IST Program

04936060-01 D2 Qtr TS HPCI Pump Oper Test and IST Surv 09/18/2019

71114.04 Miscellaneous Evaluation Exelon Nuclear Standardized Radiological Emergency Plan, 02/14/2019

Number 18-45 Revision 30

71114.06 Corrective Action 4273314 3rd Quarter 2019 Drill Issue 08/20/2019

Documents 4283661 3Q19 EP Drill Unsatisfactory Demonstration Criteria 09/30/2019

Miscellaneous 3rd Quarter 2019 Emergency Preparedness Full Drill Manual

71151 Miscellaneous Unit 2 and Unit 3 MSPI Validation Packages for HPCI, ISO, July 1, 2018

LPCI, Emergency AC Power, EDG and SDC - June 30,

2019

NEI 99-02 Regulatory Assessment PI Guidance 7

71152 Corrective Action 4204937 EHC Leakage Has Degraded Further 12/20/2018

Documents 4247636 Blocked Quill Oil Passage Causes Turbine Trip and RX 05/09/2019

Scram

249933 Adverse Trend in Equipment Performance Since D3R25 05/17/2019

270769 Trend in Maintenance Work Planning Deficiencies 08/09/2019

Procedures ER-AA-200-1001 Equipment Classification 4

ER-AA-2004 System Vulnerability Review Process 5 and 10

MA-AA-716-010 Maintenance Planning 21 and 26

MA-AA-716-010- Operational Critical Component Work (OPCCW) Process 0, 5, and 6

1015

Work Orders 01081964 Turbine Front Standard Mechanical Inspect/Maint 11/11/2013

01799328 Stem/Insp Overhaul Intern Overhaul ACT for FW Reg B 11/01/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

04606118 3B EHC Discharge Pipe Leaking at Tee to Accumulator 10/29/2018

Rack

25