ML14204A755

Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000237/2014005; 05000249/2014005

ML14204A755
Person / Time
Site:	Dresden
Issue date:	07/21/2014
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
Nestor Felix Adorno
References
IR-14-005
Download: ML14204A755 (9)

See also: IR 05000237/2014005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

July 21, 2014

Mr. Michael J. Pacilio

Senior VP, Exelon Generation Co., LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NOTIFICATION

OF AN NRC TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND

REQUEST FOR INFORMATION INSPECTION REPORT 05000237/2014005;

05000249/2014005

Dear Mr. Pacilio:

On December 1, 2014, the U.S. Nuclear Regulatory Commission (NRC) will begin the on-site

portion of the Triennial Heat Sink Performance Inspection at your Dresden Nuclear Power

Station, Units 2 and 3. This inspection will be performed in accordance with NRC baseline

inspection procedure (IP) 71111.07, Heat Sink Performance.

In order to minimize the impact that the inspection has on the site and to ensure a productive

inspection, we have enclosed a request for documents needed for the inspection. The

documents have been divided into three groups.

• The first group lists information necessary for our initial inspection scoping activities. This

information should be available to the lead inspector no later than October 6, 2014. By

October 17, 2014, the inspector will communicate the initial selected set of approximately

2-3 risk significant heat exchangers.

• The second group is needed to support our in-office preparation activities. This set of

documents, including the calculations associated with the selected heat exchangers,

should be available at the Regional Office no later than November 17, 2014. This

information should be separated for each selected component, especially if provided

electronically (e.g., folder with component name that includes calculations, condition

reports, maintenance history, etc.). During the in-office preparation activities, the inspector

may identify additional information needed to support the inspection.

• The last group includes the additional information above as well as plant specific

reference material. This information should be available onsite to the inspector on

December 1, 2014. It is also requested that corrective action documents and/or questions

developed during the inspection be provided to the inspector as the documents are

generated.

M. Pacilio -2-

All requested documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink performance

inspection. If no activities were accomplished in that time period, then the request applies to

the last applicable document in the previous time period. It is important that these documents

be as complete as possible, in order to minimize the number of documents requested during

the preparation week or during the on-site inspection.

The lead inspector for this inspection is Néstor J. Féliz Adorno. We understand that our

regulatory contact for this inspection is G. Graff of your organization. If there are questions

about the material requested, or the inspection, please call Néstor J. Féliz Adorno at

(630) 829-9739. Please send the information to the following e-mail address

nestor.feliz-adorno@nrc.gov. A hard-copy or compact disc (CD) with the required information

is also an acceptable option.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget Control Number 3150-

0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting

document displays a currently valid Office of Management and Budget Control Number.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's

"Rules of Practice," a copy of this letter and its enclosure will be available electronically for public

inspection in the NRC Public Document Room or from the Publicly Available Records System

(PARS) component of NRC's Agencywide Documents Access and Management System

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA Stuart Sheldon Acting For/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Triennial Heat Sink Performance

Inspection Document Request

cc w/encl: Distribution via LISTSERV

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

Inspection Report: 05000237/2014005; 05000249/2014005

Inspection Dates: December 1 - 5, 2014

Inspection Procedure: Inspection Procedure 71111.07, Heat Sink Performance

Lead Inspector: Néstor J. Féliz Adorno

(630) 829-9739

nestor.feliz-adorno@nrc.gov

I. Information Requested By October 6, 2014

1. List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

2. Copy of heat exchanger performance trending data tracked for each GL 89-13 heat

exchanger.

3. List of Corrective Action Program documents (with a short description) associated

with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, heat

exchanger testing, ultimate heat sink (UHS), and safety-related service and closed

cooling water systems for the previous three years or since the last Corrective Action

Program document list was sent to the NRC for the previous heat sink performance

inspection. The list should include all Corrective Action Program documents not on

the last Corrective Action Program document list.

4. Copy of any self-assessment done on any of GL 89-13 heat exchangers, UHS, and

safety-related service and closed cooling water systems since the last heat sink

performance inspection.

5. Last two System Health Report(s) and maintenance rule system notebooks for all the

GL 89-13 heat exchangers, UHS, and safety-related service and closed cooling

water systems.

6. List of engineering-related operator workarounds (with a short description)

associated with GL 89-13 heat exchangers, UHS, and safety-related service and

closed cooling water systems. The requested documents are to be for the time

period from the onsite inspection period back to the documents that were provided in

response to the previous heat sink performance inspection.

7. List of permanent and temporary modifications (with a short description) associated

with GL 89-13 heat exchangers, UHS, and safety-related service and closed cooling

water systems. The requested documents are to be for the time period from the

onsite inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

8. List of risk significant non-safety-related functions (with a short description) of the

service water system and UHS.

Enclosure

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

II. Information Requested By November 17, 2014

1. Copies of the GL 89-13 responses and commitments.

2. Copies of procedures developed to implement the recommendations of GL 89-13

(e.g., the GL 89-13 Heat Exchanger Program description).

3. Copies of the selected Corrective Action Program documents.

4. For the specific heat exchangers selected:

a. Copy of system description and design basis document for the heat exchangers

(as applicable).

b. Provide a list of calculations (with a short description), which currently apply to

each heat exchanger.

c. Provide the calculations or evaluations that:

i. establish the limiting design basis heat load required to be removed by each

of these heat exchangers;

ii. demonstrate the heat exchangers capacity to remove the limiting heat load;

iii. correlate surveillance testing and/or inspection results from these heat

exchangers with design basis heat removal capability (e.g., basis for

surveillance test and/or inspection acceptance criteria);

iv. evaluate the potential for water hammer in each heat exchanger or

associated piping; and

v. evaluate excessive tube vibration in each heat exchanger.

d. Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the operation

for the selected heat exchangers.

e. Copy of the design specification, heat exchanger data sheets, and vendor

documents including component drawings applicable for the selected heat

exchangers.

f. Copies of normal, abnormal, and emergency operating procedures associated

with the selected heat exchangers.

5. For the UHS and the safety-related service and closed cooling water systems (or

equivalent):

a. Copy of system description and design basis document (as applicable).

2

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

a. Copy of any operability determinations or other documentation of degradation

associated with the UHS and the safety-related service and closed cooling water

systems.

b. Copy of the document (e.g., UFSAR or Technical Requirements Manual) that

states the maximum cooling water system inlet temperature limit that still allows

full licensed power operation of the nuclear reactor.

c. Copy of the construction code and Design Specification.

d. Copies of normal, abnormal, and emergency operating procedures associated

with the UHS and safety-related service water systems including procedures for

loss of these systems.

e. Copies of the procedures associated with in-service test of the safety-related

service and closed cooling water pumps.

f. Copies of corrective action documents associated with waterhammer or hydraulic

transients in the service water system since the last heat sink inspection.

g. If available, provide an electronic copy of piping and instrumentation diagrams

(P&IDs) for the service and closed cooling water systems, including the intake

structure.

h. Provide a list of calculations (with a short description), which currently apply to

UHS, service and closed cooling water systems.

i. Copies of calculations and surveillances that determine the UHS reservoir

capacity and heat transfer capability.

j. Copy of calculation addressing safety-related service and closed cooling water

systems flow balance.

k. Provide a list of instruments (with a short description) associated with automatic

or alarm functions for the safety-related service and closed cooling water

systems and/or UHS.

6. A schedule of all inspections, cleanings, maintenance, or testing of any

safety-related heat exchanger to be performed during the on-site portion of the

inspection.

7. Electronic copies of the current Final Safety Analysis Report, Technical

Specifications, Technical Specifications Basis, and Technical Report Manual.

III. Information Requested to be Available on First Day of Inspection, December 1, 2014

1. For the specific heat exchangers selected:

a. Copies of the two most recent completed tests and evaluation data confirming

thermal performance for those heat exchangers, which are performance tested.

b. Documentation and procedures that identify the types, accuracy, and location of

any special instrumentation used for the two most recently completed thermal

3

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

performance tests for the heat exchangers (e.g., high accuracy ultrasonic flow

instruments or temperature instruments). Include calibration records for the

instruments used during these tests.

c. Information regarding any alarms, which monitor on-line performance.

d. Copy of the document describing the inspection results of each heat exchanger.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

e. The cleaning and inspection maintenance schedule for each heat exchanger for

the next 5 years.

f. Copy of the operating procedure that ensures that the maximum cooling water

system inlet temperature limit is not exceeded.

g. Copy of the periodic flow testing at or near maximum design flow. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

h. Copy of the document which identifies the current number of tubes in service for

each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

i. Copy of the document establishing the repair criteria (plugging limit) for degraded

tubes which are identified in each heat exchanger.

j. Copies of the documents that verify the structural integrity of the heat exchanger

(e.g., eddy current summary sheets, ultrasonic testing results, and visual

inspection results).

k. Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers.

2. For the review of the safety-related service and closed cooling water systems and

UHS:

a. Copies of calculations and surveillances that determine the UHS reservoir

capacity and heat transfer capability.

b. Copies of surveillance procedures and testing results performed on the

instrumentation relied upon to determine UHS reservoir capability. The

requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

c. Copies of the last two performance tests, such as the ASME in-service test, for

the pumps, valves, and, if applicable, the towers fans in the safety-related service

water system. If the components are not performance tested, please provide

documentation verifying performance by the methods actually used.

4

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

d. Copies of the documents that demonstrate that flow balance testing of the

safety-related service water system was performed during the last three years.

If the last flow test was performed longer than three years, then provide the last

test.

e. Copies of the documents that demonstrate that flow balance testing will continue

to be periodically done in the future.

f. Copies of procedures used to monitor interface valves between the

safety-related sections of the service and closed cooling water systems, the

non-safety-related sections, and the associated results. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

g. Copies of the procedures that verify the performance of risk significant non-safety

functions of the safety-related service water system and the associated results.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

h. Copies of the testing, inspection, or monitoring program procedures for buried or

inaccessible piping of the service and closed cooling water systems and the

associated results. The requested documents are to be for the time period from

the onsite inspection period back to the documents that were provided in

response to the previous heat sink performance inspection.

i. Copies of the ultrasonic test results and/or visual inspections that verify the

structural integrity of the service and closed cooling water systems piping.

j. Copies of the procedures to monitor, assess, and disposition active thru wall pipe

leaks of the service and closed cooling water systems, including structural

evaluations and/or planned corrective actions.

k. History of any thru wall pipe leak on the service and closed cooling water

systems. The requested documents are to be for the time period from the onsite

inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

l. Copies of the documents associated with the periodic inspection program used to

detect protective coating failure, corrosion, and erosion of the service and closed

cooling water systems.

m. Copies of the IST vibration monitoring results and operational history for deep

draft vertical pumps, if applicable. The requested documents are to be for the

time period from the onsite inspection period back to the documents that were

provided in response to the previous heat sink performance inspection.

If the information requested above will not be available, please contact Néstor J. Féliz Adorno

as soon as possible at (630) 829-9739 or email nestor.feliz-adorno@nrc.gov.

5

M. Pacilio -2-

All requested documents are to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous heat sink performance inspection. If no

activities were accomplished in that time period, then the request applies to the last applicable document

in the previous time period. It is important that these documents be as complete as possible, in order to

minimize the number of documents requested during the preparation week or during the on-site

inspection.

The lead inspector for this inspection is Néstor J. Féliz Adorno. We understand that our regulatory

contact for this inspection is G. Graff of your organization. If there are questions about the material

requested, or the inspection, please call Néstor J. Féliz Adorno at (630) 829-9739. Please send the

information to the following e-mail address nestor.feliz-adorno@nrc.gov. A hard-copy or compact disc

(CD) with the required information is also an acceptable option.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements

were approved by the Office of Management and Budget Control Number 3150-0011. The NRC may not

conduct or sponsor, and a person is not required to respond to, a request for information or an

information collection requirement unless the requesting document displays a currently valid Office of

Management and Budget Control Number.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's "Rules of

Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's

Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at

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

Sincerely,

/RA Stuart Sheldon Acting For/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

TRIENNIAL HEAT SINK PERFORMANCE

INSPECTION DOCUMENT REQUEST

cc w/encl: Distribution via LISTSERV

DISTRIBUTION:

See next Page

DOCUMENT NAME: G:\DRSIII\DRS\Work in Progress\Ltr 072114 Dresden 2014 UHS RFI NFA.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII

NAME SSheldon for NAdorno:ls SSheldon for AMStone

DATE 07/11/14 07/21/14

OFFICIAL RECORD COPY

Letter to Michael J. Pacilio from Ann Marie Stone dated July 21, 2014.

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NOTIFICATION

OF AN NRC TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND

REQUEST FOR INFORMATION INSPECTION REPORT 05000237/2014005;

05000249/2014005

DISTRIBUTION:

Anthony Bowers

RidsNrrDorlLpl3-2 Resource

RidsNrrPMDresden Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Darrell Roberts

Steven Orth

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Patricia Buckley

Carmen Olteanu