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| author name = Szwarc D
| author name = Szwarc D
| author affiliation = NRC/RGN-III/DRS/EB3
| author affiliation = NRC/RGN-III/DRS/EB3
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000237, 05000249, 07200037
| docket = 05000237, 05000249, 07200037
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUIT E 210 LISLE, IL 60532
{{#Wiki_filter:UNITED STATES uly 1, 2015
-4352 July 1, 2015 Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555


SUBJECT: DRESDEN NUCLEAR POWER STATION - EVALUATION S OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 0500 0 237/201 5 00 7; 05000 249/201500 7
==SUBJECT:==
DRESDEN NUCLEAR POWER STATION - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000237/2015007; 05000249/2015007


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
On Ma y 2 9, 201 5 , the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Dresden Nuclear Power Station. The enclosed inspection report documents the inspection results , which were discussed on Ma y 2 9, 201 5, with Mr. Shane Marik , and other members of your staff.
On May 29, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Dresden Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on May 29, 2015, with Mr. Shane Marik, and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


NRC inspectors documented t wo NRC-identified finding s of very-low safety significance (Green) in this report
NRC inspectors documented two NRC-identified findings of very-low safety significance (Green)
. Th e s e finding s were determined to involve violation s of NRC requirements.
in this report. These findings were determined to involve violations of NRC requirements.


However, because of the ir very-low safety significance
However, because of their very-low safety significance, and because these issues were entered into your Corrective Action Program, the NRC is treating these issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2, of the NRC Enforcement Policy.
, and because the se issue s were entered into your Corrective Action Program, the NRC is treating the se issue s as Non-Cited Violation s (NCV s) in accordance with Section 2.3.2 , of the NRC Enforcement Policy.


If you contest the subject or severity of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
If you contest the subject or severity of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S.
Document Control Desk, Washington, DC 20555
-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555
-0001; and the NRC Resident Inspector at Dresden Nuclear Power Station
. In addition, if you disagree with the cross
-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Dresden Nuclear Power Station
. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Dresden Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Dresden Nuclear Power Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
Darius z Szwarc , Acting Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
-237, 50-249; 72-037 License Nos. DPR
 
-19; DPR-25  
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,
/RA/
Dariusz Szwarc, Acting Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-237, 50-249; 72-037 License Nos. DPR-19; DPR-25


===Enclosure:===
===Enclosure:===
Inspection Report 0500 0 237/20 1 5 007; 05000249/2015007 cc w/encl:
Inspection Report 05000237/2015007; 05000249/2015007
Distribution via LISTSERV Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No s: 50-237; 50-249 License No s: DPR-19; DPR-25 Report No:
 
05000 237/20 1 5 007; 05000249/20 15 00 7 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station Location: Morris , IL Dates: Ma y 11 - 2 9, 2015 Inspectors:
REGION III==
George M. Hausman, Senior Engineering Inspector (Lead)
Docket Nos: 50-237; 50-249 License Nos: DPR-19; DPR-25 Report No: 05000237/2015007; 05000249/2015007 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station Location: Morris, IL Dates: May 11 - 29, 2015 Inspectors: George M. Hausman, Senior Engineering Inspector (Lead)
Jorge J. Corujo-Sandin , Engineering Inspector Mark T. Jeffers , Engineering Inspector Observer: Christopher A. Hunt, Reactor Engineer Approved by:
Jorge J. Corujo-Sandin, Engineering Inspector Mark T. Jeffers, Engineering Inspector Observer: Christopher A. Hunt, Reactor Engineer Approved by: Dariusz Szwarc, Acting Chief Engineering Branch 3 Division of Reactor Safety Enclosure
Dariusz Szwarc, Acting Chief Engineering Branch 3 Division of Reactor Safety 2


=SUMMARY=
=SUMMARY=
Inspection  
Inspection Report 05000237/2015007; 05000249/2015007; 05/11/2015 - 05/29/2015; Dresden


Report 05000 237/20 1 5 00 7; 05000249/20 1 5 00 7; 0 5/11/2015 - 05/2 9/2015; Dresden Nuclear Power Station
Nuclear Power Station; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.
; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.


This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments
This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments, and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. Two findings of very-low safety significance were identified by the inspectors. The findings were considered Non-Cited Violations of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were determined using IMC 0310, Aspects within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
, and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors.


Two finding s of very-low safety significance were identified by the inspectors. The finding s were considered Non-Cited Violation s of U.S. Nuclear Regulatory Commission (NRC)regulations. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, "Significance Determination Process (SDP).
===Cornerstone: Mitigating Systems===
: '''Green.'''
The inspectors identified a finding of very-low safety significance, and an associated Non-Cited Violation (NCV) of Title 10, Code of Federal Regulations (CFR),
Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that applicable regulatory requirements and the isolation condensers (ICs) design bases were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases. The licensee entered the issue into their Corrective Action Program (CAP) as Action Request 02506445, NRC MOD/5059 Inspection: ISCO [Isolation Condenser] Operating Procedures, dated May 28, 2015.


"  Cross-cutting aspects were determined using IMC 0310, "Aspect s within the Cross-Cutting Areas."  Findings for which the SDP does not apply may be Green
The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality, and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
, or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated J ul y 9, 201 3. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
 
-1649, "Reactor Oversight Process," Revision 5, dated February 2014
Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC from performing its design function of removing decay heat from the reactor. The finding has a cross-cutting aspect in the area of Human Performance; Teamwork, because the licensee did not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes.
. Cornerstone
 
:  Mitigating Systems
        [H.4] (Section 1R17.1b)
: '''Green.'''
: '''Green.'''
The inspectors identified a finding of very-low safety significance
The inspectors identified a finding of very-low safety significance, and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG) Calculation 10553-CALC-07, Dresden Station
, and an associated Non-Cited Violation (NCV) of Title 10, Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion III, "Design Control
," for the licensee's failure to ensure that applicable regulatory requirements and the isolation condenser
's (IC's) design bas e s were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the IC's design bases. The licensee entered th e issue into their Corrective Action Program (CAP) as Action Request 02506445, "NRC MOD/5059 Inspection:
ISC O [Isolation Condenser]
Operating Procedures," dated May 28, 2015. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality
, and affected the cornerstone
's objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC from performing its design function of removing decay heat from the reactor.


The finding ha s a cross-cutting aspect in the area of Human Performance; Teamwork, because the licensee di d not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes.
Emergency Diesel Generators Endurance Calculations, Revision 2, which resulted in non-conservative Technical Specifications (TS). Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz),
and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour. The licensee entered the issue into their CAP as Action Request 02506869,
NRC MOD/5059 Inspection: Emergency Diesel Generator Fuel Consumption, dated May 28, 2015.


  [H.4]  (Section 1R17.1b)
The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency. Therefore, the licensee did not ensure that the minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution; Identification, because the licensee did not did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation. Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS.
: '''Green.'''
The inspectors identified a finding of very-low safety significance
, and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG)
Calculation 10553-CALC-07, "Dresden Station 3 Emergency Diesel Generators Endurance Calculations," Revision 2, which resulted in non-conservative Technical Specifications (TS). Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz), and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour. The licensee entered the issue into their CAP as Action Request 02506869 , "NRC MOD/5059 Inspection:
Emergency Diesel Generator Fuel Consumption," dated May 28, 2015. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone's objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency. Therefore, the licensee did not ensure that th e minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour. This finding ha s a cross-cutting aspect in the area of Problem Identification and Resolution
; Identification
, because the licensee did not did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation.


Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS.  [P.1] (Section 1R17.2 b)4
[P.1] (Section 1R17.2b)


=REPORT DETAILS=
=REPORT DETAILS=


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstone s: Initiating Events, Mitigating Systems, and Barrier Integrity 1R17 Evaluation s of Changes, Tests, and Experiments and Permanent Plant Modifications (71111.17 T)
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R17}}
==1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications==
{{IP sample|IP=IP 71111.17T}}
===.1 Evaluation of Changes, Tests, and Experiments===
 
====a. Inspection Scope====
The inspectors reviewed 7 evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine if the evaluations were adequate, and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 15 screenings, where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:
* the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59, and that sufficient documentation existed to confirm that a license amendment was not required;
* the safety issue requiring the change, tests or experiment was resolved;
* the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and
* the design and licensing basis documentation was updated to reflect the change.
 
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide (RG) 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.


===.1 Evaluation===
This inspection constituted 7 samples of evaluations, and 15 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP) 71111.17-04.


of Changes, Tests, and Experiments
====b. Findings====
Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis     


====a. Inspection Scope====
=====Introduction:=====
The inspectors reviewed 7 evaluations performed pursuant to Title 10 , Code of Federal Regulations (CFR), Part 50, Section 59 , to determine if the evaluations were adequate , and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 1 5 screenings , where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary
The inspectors identified a finding of very-low safety significance (Green),and an associated Non-Cited Violation (NCV) of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that applicable regulatory requirements and the isolation condensers (ICs) design bases were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases.
. The inspectors reviewed these documents to determine if:
 
the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 , and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change
=====Description:=====
. The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide (RG) 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."
The safety-related IC system functions as a heat sink for decay heat removal from the reactor vessel following a reactor scram, and isolation from the main condenser. Each IC (one per unit) consists of two tube bundles immersed in a large water storage tank. The IC system operates by natural circulation. During operation, the IC tube side will contain reactor coolant water, and the shell side will contain clean demineralized water.


This inspection constituted 7 samples of evaluations
The inspectors observed that the licensee made changes to three IC control procedures.
, and 1 5 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP)


==71111.17 - 04.==
The procedure changes directed operators to secure the IC on a low-shell side level condition. Specifically, the IC would be secured if the shell side level could not be maintained above 3.5 feet. At this height, the water level in the shell is just above the top of the tube bundles. The purpose of the procedure change was to prevent uncovering of the tube bundles in order to protect the IC for future availability (i.e., when the shell side level could be restored to ensure the IC would be available to respond to a Beyond Design Basis External Event). The procedures affected were as follows:
* DOP 1300-02, Automatic Operation of Isolation Condenser, Revision 25, Step G.4.a;
* DOP 1300-03, Manual Operation of the Isolation Condenser, Revision 34, Step G.9.a; and
* DAN 902(3)-3D-4, Isolation Condenser Level Hi/Low Annunciator Respond Procedure, Revision 12, Step B.2.a.


====b. Findings====
In the Updated Final Safety Analysis Report (UFSAR), Section 5.4.6 and the Technical Specifications (TS) Bases 3.5.3, the IC design basis was described as:
Procedure Revisions Result ed in Isolation Condenser Unable to Meet Design Basi s Introduction
: (1) remove 252.5 Million British thermal units (MBtu)/hour, which is equivalent to the decay heat rate 8.8 minutes after the scram; and
:  The inspectors identified a finding of very
: (2) provide sufficient decay heat removal capability for 20 minutes of operation without makeup water to the shell. The TS requires a number of surveillance requirements (SRs) be performed to ensure these bases are met, including the following:
-low safety significance (Green)
* SR 3.5.3.1: Verify the IC system shellside water level  6 feet, and shellside water temperature  210°F; and
, and an associated Non-Cited Violation (NCV) of 10 CFR , Part 50, Appendix B, Criterion III, "Design Control
* SR 3.5.3.4: Verify the IC system heat removal capability to remove design heat load [i.e., 252.5MBtu/hour].
," for the licensee's failure to ensure that applicable regulatory requirements and the isolation condenser's (IC's) design bas es were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the IC's design bases
The licensee maintains the shell water level above 7 feet via administrative controls and monitors the temperature in an effort to remain well below the temperature limits.
.
5 Description
: The safety
-related IC system functions as a heat sink for decay heat removal from the reactor vessel following a reactor scram
, and isolation from the main condenser. Each IC (one per unit) consists of two tube bundles immersed in a large water storage tank.


The IC system operates by natural circulation. During operation
However, the licensing bases of the isolation condenser states that water level of the shell is expected to go below 3.5 feet in order to mitigate a credited event under design bases conditions. As a result, procedural guidance, which would prevent the isolation condenser shell water level from going below 3.5 feet, would preclude the component from performing its design function under design bases conditions.
, the IC tube side will contain reactor coolant water
, and the shell side will contain clean demineralized water. The inspector s observe d that the licensee made changes to three IC control procedures. The procedure change s direct ed operators to secure the IC on a low
-shell side level condition. Specifically, the IC would be secured if the shell side level c ould not be maintained above 3.5 feet. At this height, the water level in the shell is just above the top of the tube bundles. The purpose of the procedure change was to prevent uncovering of the tube bundles in order to protect the IC for future availability (i.e., when the shell side level could be restored to ensure the IC would be available to respond to a Beyond Design Basis External Event
). The procedures affected were as follows
:  DOP 1300-02, "Automatic Operation of Isolation Condenser," Revision 2 5 , Step G.4.a;  DOP 1300-03, "Manual Operation of the Isolation Condenser," Revision 34 , Step G.9.a; and  DAN 902(3)-3 D-4, "Isolation Condenser Level Hi/Low Annunciator Respond Procedure ," Revision 12 , Step B.2.a. In the Updated Final Safety Analysis Report (UFSAR), Section 5.4.6 and the Technical Specification s (TS) Bases 3.5.3 , the IC design basi s was describe d as:
: (1) remove 252.5  Million British thermal units (MBtu)/h ou r, which is equivalent to the decay heat rate 8.8 minutes after the scram; and
: (2) provide sufficient decay heat removal capability for 20 minutes of operation without makeup water to the shell. The TS require s a number of surveillance requirements (SR s) be performed to ensure these bases are met, including the following:
SR 3.5.3.1:  Verify the IC 6 feet , and shellside water  210°F; and SR 3.5.3.4:  Verify the IC system heat removal capability to remove design heat load [i.e., 252.5MBtu/h our]. The licensee maintains the shell water level abov e 7 feet via administrative controls and monitors the temperature in an effort to remain well below the temperature limits. However, the licensing bases of the isolation condense r states that water level of the shell is expected to go below 3.5 feet in order to mitigate a credited event under design bases conditions.


As a result, procedural guidance
As part of immediate corrective actions the licensee marked the procedures for review in order to determine required changes. In addition, the licensee demonstrated the shell water temperature was monitored in order to maintain it well below TS requirements and the water level was administratively maintained at or above 7 feet. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 foot limit.
, which would prevent the isolation condenser shell water level from going below 3.5 feet , would preclude the component from performing its design function under design bases conditions.


As part of immediate corrective actions the licensee marked the procedures for review in order to determine required changes. In addition, the licensee demonstrated the shell water temperature was monitored in order to maintain it well below TS requirements and the water level was administratively maintained at or above 7 feet. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 f oo t limit.
The licensee documented the inspectors concern under AR 02506445, NRC Mod/5059 Inspection: ISCO [Isolation Condenser] Operating Procedures, dated May 28, 2015.


6 The licensee documented the inspectors' concern under AR 02506445, "NRC Mod/5059 Inspection:
The licensee plans to evaluate the IC procedural changes and determine what modifications are needed. In addition, the licensee is considering performing an Apparent Cause Evaluation to evaluate the concern. The inspectors concluded that procedural changes were performed by the Operations Department without engaging the Engineering Department to ensure there were no adverse impacts to the IC or associated design and licensing bases.
ISCO [Isolation Condenser]
Operating Procedures," dated May 28, 2015. The licensee plans t o evaluate the IC procedural changes and determine what modifications are needed. In addition, the licensee is considering performing an Apparent Cause Evaluation to evaluate the concern. The inspectors concluded that procedural changes were performed by the Operations Department without engaging the Engineering Department to ensure there were no adverse impact s to the IC or associated design and licensing bases.


=====Analysis:=====
=====Analysis:=====
The inspectors determined that the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3
The inspectors determined that the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet, which was contrary to 10 CFR, Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency.


===.5 feet, which was contrary to===
Specifically, the added steps would result in the IC being shutdown when required to operate per the ICs design bases.


10 CFR, Part 50, Appendix B, Criterion III, "Design Control
The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality, and affected the cornerstone's objective of ensuring the availability, reliability and capability of the systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC from performing its design basis function of removing decay heat from the reactor.
," and was a performance deficiency. Specifically, the added steps would result in the IC being shutdown when required to operate per the IC's design bases
. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality
, and affected the cornerstone's objective of ensuring the availability, reliability and capability of the systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC fro m performing its design basis function of removing decay heat from the reactor.


In accordance with Inspection Manual Chapter (IMC)0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings
In accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of mitigating structures, systems, and components (SSC); however, the SSC maintained its operability or functionality as applicable. Specifically, the licensee administratively maintains the shell water level at or above 7 feet and the temperature is maintained below 210 degrees Fahrenheit. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 foot limit. Therefore, the inspectors answered "yes" to the Mitigating Systems Screening Question A.1 in Exhibit 2, and screened the finding as having very-low safety significance (Green).
," Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone.


As a result, the inspectors determined the finding could be evaluated using Appendix A , "The Significance Determination Process for Findings At
The finding has a cross-cutting aspect in the area of Human Performance; Teamwork because the licensee did not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes. [H.4]
-Power," Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of mitigating structure s , systems, and component s (SSC); however, the SSC maintained its operability or functionality as applicable.


Specifically, the licensee administratively maintains the shell water level at or above 7 feet and the temperature is maintained below 210 degrees Fahrenheit. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 f oot limit. Therefore, the inspectors answered "yes" to the Mitigating Systems Screening Question A.1 in Exhibit 2 , and screened the finding as having very
=====Enforcement:=====
-low safety significance (Green).
Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.


The finding has a cross-cutting aspect in the area of Human Performance
Contrary to the above, from April 22, 2013, to May 29, 2015, the licensee failed to ensure that applicable regulatory requirements and the ICs design basis were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases.
; Teamwork because the licensee di d not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes.  [H.4]
Enforcement
:  Title 10 CFR , Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions
. Contrary to the above, from April 22, 2013, to May 29, 2015, the licensee failed to ensure that applicable regulatory requirements and the IC's design basis were correctly translated into procedures. Specifically, the licensee added steps to the 7 IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the IC's design bases.


This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very
This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance and was entered into the licensees CAP as Action Request 02506445, NRC MOD/5059 Inspection: ISCO Operating Procedures, dated May 28, 2015. The licensee will continue to administratively control level of the shell at or above seven feet to provide additional margin to the IC to perform its function. (NCV 05000237/2015007-01; NCV 05000249/2015007-01, Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis)
-low safety significance and was entered into the licensee's CAP as Action Request 02506445, "NRC MOD/5059 Inspection:
ISCO Operating Procedures," dated May 28, 2015. The licensee will continue to administratively control level of the shell at or above seven feet to provide additional margin to the IC to perform its function. (NCV 05000237/2015007
-01; NCV 05000249/2015007
-01, Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis)


===.2 Permanent Plant Modifications===
===.2 Permanent Plant Modifications===


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed nine permanent plant modifications that had been installed in the plant during the last 3 years. This review included in
The inspectors reviewed nine permanent plant modifications that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for portions of the modified High Pressure Coolant Injection (HPCI) system to assess recent replacement of the auxiliary oil pump. The modifications were selected based upon risk-significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
-plant walkdowns for portions of the modified High Pressure Coolant Injection (HPCI)system to assess recent replacement of the auxiliary oil pump.
* the supporting design and licensing basis documentation was updated;
 
* the changes were in accordance with the specified design requirements;
The modifications were selected based upon risk-significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
* the procedures and training plans affected by the modification have been adequately updated;
the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.
* the test documentation as required by the applicable test programs has been updated; and
* post-modification testing adequately verified system operability and/or functionality.


The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.
The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.


This inspection constitut ed nine permanent plant modification samples as defined in IP
This inspection constituted nine permanent plant modification samples as defined in IP 71111.17-04.
 
==71111.17 - 04.==


====b. Findings====
====b. Findings====
Emergency Diesel Generator Usable Fuel Calculations Failed to Consider Appropriate Emergency Diesel Generator Frequency Variations
Emergency Diesel Generator Usable Fuel Calculations Failed to Consider Appropriate     Emergency Diesel Generator Frequency Variations


=====Introduction:=====
=====Introduction:=====
The inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR , Part 50, Appendix B, Criterion III, "Design Control," for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG)endurance calculations which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz), and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour.
The inspectors identified a finding of very low safety significance (Green)and an associated NCV of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG) endurance calculations which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz), and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.


8 Description
=====Description:=====
The TSs SR 3.8.1.2 allow s an EDG frequency tolerance of +/-
The TSs SR 3.8.1.2 allows an EDG frequency tolerance of +/- 2 percent.
2 percent. This tolerance was based on R G 1.9 , "Application and Testing of Safety
-Related Diesel Generators in Nuclear Power Plants
," Revision 4, requirements that the EDG frequency recover to within +/-
2 percent of 60 Hz (i.e., 58.8 - 61.2 Hz) within a specified period during the sequencing of loads on the bus.


Therefore, the EDGs could operate at a frequency of 61.2 Hz, which would be the worst
This tolerance was based on RG 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants, Revision 4, requirements that the EDG frequency recover to within +/- 2 percent of 60 Hz (i.e., 58.8 - 61.2 Hz) within a specified period during the sequencing of loads on the bus. Therefore, the EDGs could operate at a frequency of 61.2 Hz, which would be the worst-case scenario for loading of the EDGs.
-case scenario for loading of the EDGs.


Additionally, TS SR 3.8.1.4 verifies adequate level of fuel oil in the day tank and the bulk storage tanks. The level selected is to ensure adequate fuel oil for a minimum of one hour of EDG operation at 110 percent of full load for the day tank and approximately two days at 100 percent full load for the bulk storage tanks.
Additionally, TS SR 3.8.1.4 verifies adequate level of fuel oil in the day tank and the bulk storage tanks. The level selected is to ensure adequate fuel oil for a minimum of one hour of EDG operation at 110 percent of full load for the day tank and approximately two days at 100 percent full load for the bulk storage tanks. The levels identified by TS SR 3.8.1.4 are 205 gallons and 10,000 gallons for the day tank and bulk storage tank, respectively.


The levels identified by TS SR 3.8.1.4 ar e 205 gallons and 10,000 gallons for the day tank and bulk storage tank, respectively.
During review of Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, the inspectors questioned why the licensee based their fuel consumption on the EDGs operating at 110 percent at 60 Hz rather than 61.2 Hz as allowed by TS SR 3.8.1.2. The higher frequency would result in higher fuel consumption; therefore, would be more conservative. Specifically, the estimated fuel consumption at 110 percent loading at 61.2 Hz would be approximately 211.3 gallons/hour. The calculation did identify that the 2 percent frequency tolerance would result in higher fuel consumption; however, the more conservative frequency was only applied to calculating EDG loading at 100 percent. The calculation of the day tank level at 110 percent only considered the less conservative 60 Hz frequency.


During review of Calculation 10553-CALC-07, "Dresden Station Emergency Diesel Generators Endurance Calculations," Revision 2, the inspectors questioned why the licensee based their fuel consumption on the EDGs operating at 110 percent at 60 Hz rather than 61.2 Hz as allowed by TS SR 3.8.1.2. The higher frequency would result in higher fuel consumption; therefore, would be more conservative.
The inspectors determined that the EDGs could operate at a steady state frequency up to 61.2 Hz according to TS SR 3.8.1.2. This would result in a higher fuel consumption that would exceed the TS 3.8.1.4 minimum volumetric fuel requirements. The TS 3.8.1.4 minimum fuel requirements were based on operating the EDGs at a frequency up to 60 Hz, rather than 61.2 Hz, which resulted in non-conservative TS.


Specifically, the estimated fuel consumption at 110 percent loading at 61.2 Hz would be approximately 211.3 gallons/h our. The calculation did identify that the 2 percent frequency tolerance would result in higher fuel consumption; however, the more conservative frequency was only applied to calculating EDG loading at 100 percent. The calculation of the day tank level at 110 percent only considered the less conservative 60 Hz frequency.
The inspectors discussed the issue with the licensee and identified that the licensee had administrative procedures that would limit the frequency of the EDG to 60.5 Hz and would ensure the day tank level remained greater than 350 gallons. The Dresden Procedure DGA-12, Partial or Complete Loss of AC Power, Revision 73, ensures operators maintain frequency of the EDGs between 59.5 to 60.5 Hz. Additionally, Dresden Surveillance Procedure DOS 6600-14, Diesel Oil Transfer Pump Operation and Fuel Consumption Test, Revision 20, requires operators to maintain at least 350 gallons in the day tank. Therefore, the EDG would remain capable of performing its specified safety function. However, even with the administrative limits, the minimum fuel requirements identified in TS SR 3.8.1.4 would remain non-conservative since the fuel consumption would still be higher at the 60.5 Hz which is not represented in TS SR 3.8.1.4. The licensee captured this issue and entered it into their CAP as Action Request 02506869. The licensee intends to evaluate the effect of the increased frequency on their EDG Calculations.


The inspectors determined that the EDGs could operate at a steady state frequency up to 61.2 Hz according to TS SR 3.8.1.2. This would result in a higher fuel consumption that would exceed the TS 3.8.1.4 minimum volumetric fuel requirements.
=====Analysis:=====
The inspectors determined that the licensees failure to account for increased fuel oil consumption during the development of the EDG Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, resulted in non-conservative TS and was contrary to 10 CFR, Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz, and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.


The TS 3.8.1.4 minimum fuel requirements were based on operating the EDGs at a frequency up to 6 0 Hz, rather than 61.2 Hz, which resulted in non-conservative TS.
The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency. Therefore, the licensee did not ensure that the minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.


The inspectors discussed the issue with the licensee and identified that the licensee ha d administrative procedures that would limit the frequency of the EDG to 60.5 Hz and would ensure the day tank level remained greater than 350 gallons. The Dresden Procedure DGA
In accordance with IMC 0609, Significance Determination Process, Attachment 609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality as applicable. Specifically, the licensee was able to demonstrate that adequate fuel in the storage tanks would be available to support the EDGs mission time when operating at the administratively controlled higher frequency limit specified in procedures. Therefore, the inspectors answered "no" to all the Mitigating Systems Screening Questions in Exhibit 2, and screened the finding as having very-low safety significance (Green).
-12, "Partial or Complete Loss of AC Power," Revision 73, ensures operators maintain frequency of the EDGs between 59


===.5 to 60.5 Hz.===
This finding has a cross-cutting aspect in the area of Problem Identification and Resolution; Identification because the licensee did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation. Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS. [P.1]
Additionally, Dresden Surveillance Procedure DOS 6600-14, "Diesel Oil Transfer Pump Operation and Fuel Consumption Test," Revision 20, requires operators to maintain at least 350 gallons in the day tank. Therefore, the EDG would remain capable of performing its specified safety function. However, even with the administrative limits, the minimum fuel requirements identified in TS SR 3.8.1.4 would remain non
-conservative since the fuel consumption would still be higher at the 60.5 Hz which is not represented in TS SR 3.8.1.4. The licensee captured this issue and entered it into their CAP as Action Request 02506869. The licensee intends to evaluate the effect of the increased frequency on their EDG Calculations.


=====Analysis:=====
=====Enforcement:=====
The inspectors determined that the licensee
Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to ensure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
's failure to account for increased fuel oil consumption during the development of the EDG Calculation 10553-CALC-07, "Dresden Station Emergency Diesel Generators Endurance Calculations," Revision 2, resulted in non
 
-conservative TS and was contrary to 10 CFR , Part 50, Appendix B, Criterion III, "Design Control
Contrary to the above, from May 25, 2011, until May 29, 2015, the licensee failed to ensure that applicable regulatory requirements and the design basis were correctly translated into specifications during development of the EDG Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz, and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.
," and was a performance deficiency. Specifically, the 9 licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz , and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone
's objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency
. Therefore, the licensee did not ensure that the minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour
. In accordance with IMC 0609, "Significance Determination Process," Attachment 609.04, "Initial Characterization of Findings," Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, "The Significance Determination Process for Findings At
-Power," Exhibit 2, for the Mitigating Systems cornerstone.


The performance deficiency affected the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality as applicable. Specifically, the licensee was able to demonstrate that adequate fuel in the storage tanks would be available to support the EDGs mission time when operating at the administratively controlled higher frequency limit specified in procedures. Therefore, the inspectors answered "no" to all the Mitigating Systems Screening Questions in Exhibit 2, and screened the finding as having very
This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance, and was entered into the licensees CAP as Action Request 02506869, NRC MOD/5059 Inspection:
-low safety significance (Green). This finding has a cross
EDG Fuel Consumption, dated May 28, 2015. The licensee is evaluating the effect of the increased frequency on their EDG calculations, and will continue to administratively control level in the fuel oil day tank high enough to ensure the SSC remains operable.
-cutting aspect in the area of Problem Identification and Resolution
; Identification because the licensee did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation. Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS. [P.1]
Enforcement
: Title 10 CFR , Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to e nsure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions
. Contrary to the above, from May 25, 2011, until May 29, 2015, the licensee fail e d to ensure that applicable regulatory requirements and the design basis were correctly translated into specifications during development of the EDG Calculation 10553
-CALC-07, "Dresden Station Emergency Diesel Generators Endurance Calculations," Revision 2 , which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz , and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs' mission time at 110 percent for one hour.


This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very
      (NCV 05000249/2015007-02; NCV 05000237/2015007-02, EDG Usable Fuel Calculations Failed to Consider Appropriate EDG Frequency Variations)
-low safety significance, and was entered into the licensee's CAP as Action Reque st 02506869 , "NRC MOD/5059 Inspection:
EDG Fuel Consumption," dated May 28, 2015. The licensee is evaluating the effect of the increased frequency on their EDG calculations, and will continue to administratively 10 control level in the fuel oil day tank high enough to ensure the SSC remains operable.  (NCV 05000249/2015007-0 2; NCV 05000237/2015007-0 2 , EDG Usable Fuel Calculations Failed to Consider Appropriate EDG Frequency Variations)


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
Line 259: Line 206:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent p lant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification
The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification, and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.
, and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
 
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Exit Meeting===
===.1 Exit Meeting Summary===


Summary O n Ma y 2 9, 2015 , the inspector s presented the inspection results to Mr. Shane Marik
On May 29, 2015, the inspectors presented the inspection results to Mr. Shane Marik, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.
, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


SUPPLEMENTAL
==KEY POINTS OF CONTACT==
INFORMATI ON KEY POINTS OF CONTAC
 
T Licensee  
Licensee
: [[contact::G. Baxa]], Regulatory Assurance
: [[contact::G. Baxa]], Regulatory Assurance
: [[contact::M. Budelier ]], Senior Manager Design Engineering
: [[contact::M. Budelier]], Senior Manager Design Engineering
: [[contact::D. Doggett ]], Regulatory Assurance
: [[contact::D. Doggett]], Regulatory Assurance
: [[contact::D. Eaman ]], Design Instrumentation and Control
: [[contact::D. Eaman]], Design Instrumentation and Control (I&C) Manager
(I&C) Manager  
: [[contact::B. Franzen]], Regulatory Assurance Manager
: [[contact::B. Franzen ]], Regulatory Assurance
: [[contact::R. Gaston]], Licensing Manager - Corporate
Manager  
: [[contact::R. Gaston]], Licensing Manager
- Corporate  
: [[contact::T. Griffith]], Senior Licensing Engineer
: [[contact::T. Griffith]], Senior Licensing Engineer
: [[contact::B. Kapellas ]], Maintenance Director
: [[contact::B. Kapellas]], Maintenance Director
: [[contact::B. Madderom ]], Design Electrical Manager  
: [[contact::B. Madderom]], Design Electrical Manager
: [[contact::S. Marik ]], Site Vice President
: [[contact::S. Marik]], Site Vice President
: [[contact::G. Morrow]], Operations Directo
: [[contact::G. Morrow]], Operations Director
r
: [[contact::P. OBrien]], Site Corrective Action Program Manager
: [[contact::P. O'Brien]], Site Corrective Action Program
Manager  
: [[contact::R. Osgood]], Senior Nuclear Site Communications Specialist
: [[contact::R. Osgood]], Senior Nuclear Site Communications Specialist
: [[contact::E. Rogers ]], Nuclear Oversight
: [[contact::E. Rogers]], Nuclear Oversight
: [[contact::R. Schmidt ]], Chemistry Manager
: [[contact::R. Schmidt]], Chemistry Manager
: [[contact::B. Surges]], Work Control  
: [[contact::B. Surges]], Work Control
: [[contact::D. Walker ]], NRC Coordinator
: [[contact::D. Walker]], NRC Coordinator
: [[contact::J. Washko]], Plant Manager
: [[contact::J. Washko]], Plant Manager
: [[contact::D. Wolverton]], Design Mechanical Manager  
: [[contact::D. Wolverton]], Design Mechanical Manager
: [[contact::U.S. Nuclear Regulatory Commission K. O'Brien ]], Director , Division of
U.S. Nuclear Regulatory Commission
Reactor Safety  
: [[contact::K. OBrien]], Director, Division of Reactor Safety
: [[contact::G. Roach]], Senior Resident Inspector
: [[contact::G. Roach]], Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSS
ED Opened and Closed
05000 2 3 7/20 15 00 7-01; 05000249/2015007
-01 NCV Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis
  (Section 1R17.1b.) 05000 2 3 7/20 15 00 7-02; 05000249/2015007
-02 NCV EDG Usable Fuel Calculations Failed to Consider Appropriate EDG Frequency Variations
(Section 1R17.2b.) Discussed None
LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
ANALYSIS (ENGINEERING)
Number Description or Title
Date or Revision
DR-27D-M-002 Dresden SBO Building Ventilation Air Requirement
DRE13-0004 Use of U2/3 or U3 DG Cooling H 2 O Pump As An Alternate M/U Source During Design Basis Flood
2 EC 391519 Cumulative Effect of FM on Dresden
U3 Reactor Vessel and
Connected Systems
- D3R22 0 0 EC 391643 Alternate
IC, RPV and SFP M
/U H 2 O Source 0 9 EC 396217 D2R23 - Cumulative Effect of
FM on the Reactor Vessel and Connected Systems
0 GEH Proprietary
0000-0130-8389-R1 ICF Task T0305:
RPV Flow Induced Vibration
1 GEH Proprietary
0000-0140-6826-R1 ICF Task T0318:
Piping Flow Induced Vibration
1  ASSESSMENTS
Number Description or Title
Date or Revision
AR 02419476 Unauthorized TCC Installed for Discharge Canal Temperature Recorder
January 20, 2014 AR 02469215-04 Inadequate 50.59 Review
U 2/U3 ASD Modification
April 15, 2015  10 CFR 50.59 EVALUATIONS
Number Description or Title
Date or Revision
2012-02-001 Temporary N
Inerting Gas Supply
2012-06-001 TAT TR32 Open Phase Detection Protective Relay Circuit Installation , Revision 0 October 17, 20 12 2012-11-001 Cumulative Effects of
FM on Dresden
U3 Reactor Vessel and Connected Systems
- D3R22 0 0 2013-09-001 Dresden Increased Core Flow Implementation , Revision 0 October 8, 20 13 2013-10-001 Temporarily Bypass
U2 RWCU Trips
2013-11-001 Disable Fuel Pool Cooling Pump Trips, Revision 0 November 8, 201 3 2013-11-003 D2R23 - Cumulative Effects of
FM on Dresden
U 2 Reactor Vessel and Connected Systems
- D3R22 0 0 10 CFR 50.59 SCREENINGS
Number Description or Title
Date or Revision
2012-0007 DG RM Air Temp High
0
10 CFR 50.59 SCREENINGS
Number Description or Title
Date or Revision
2012-0039 Repair Air U3 SBO Fuel Day Tank Room Exhaust
Fan 3-5790-6007B, Revision
February 27, 2012 2012-0967 Floods 0 0 2012-1002 Engine Start Air Pressure Low or Locked Out or Air Valve Closed or Not Full
0 2013-0025 Alternate IC, RPV
& Spent Fuel M
/U H 2 O Source 0 0 2013-0028 Automatic Operation of the IC
0 2013-0029 Secure IC on
Hi/Low Level
0 2013-0030 Manual Operation of the IC
0 2013-0032 IC M/U Pumps Local Operation
0 2013-0144 U2 RAT TR 22 Sudden Pressure Relay
Out of 3 Trip Logic, Revision
July 11, 2013 2014-0095 HPCI System Standby Operation
0 2014-0168 SFP Instrumentation
- Fukushima, Revision
April 8, 2015 2014-0181 Replace Relay CR
-102 Panel 2253-11, Revision
October 31, 2014 2014-0205 Inspect Discharge Check Valve 2
-2099-970B 0 0 2015-0042 Issue Calculation Analyzing TOL Relays in a Degraded Voltage
Condition, Revision
February 24, 2015  CALCULATIONS
Number Description or Title
Date or Revision
0101-0072-01 Dresden IC Heat Transfer Calculation
2 9389-46-19-2 Calculation for DG 2 Loading Under Design Bases Accident Condition, Revision
April 4, 2007 10553-CALC-07 Dresden EDGs Endurance Calculations , Revision 2 May 25, 2011 DRE07-0005 Determination of Connected Loading on 120/240Vac ES Bus Dist. Panel
2-49 Powered from UPS at Panel
2-63, Revision
February 23, 2015 DRE13-001 Validation of TOL Relay Sizes Subject to a Degraded Voltage Condition, Revision
February 24, 2015 EC 388351 Temporary N
Inerting Gas Supply
CORRECTIVE ACTION PROGRAM DOCUMENTS
(ARs) I SSUED DURING INSPECTION
Number Description or Title
Date or Revision
2493498 PORC Approved 10
CFR 50.59 Evaluation Cannot Be Located
April 30, 2015 02499058 NRC INSP:  Parts Evaluation Errors
May 11, 2015 02499647 NRC INSP:
Typo in 50.59 Screening 2012
-0007 & DAN 923-74-045 May 12, 2015 02506445 NRC MOD/5059 Inspection:
IC Operating Procedures
May 28, 2015 02506845 NRC MOD/5059 Inspection:
Observation Improvement to DOS
20-01 May 28, 2015
CORRECTIVE ACTION PROGRAM DOCUMENTS
(ARs) I SSUED DURING INSPECTION
Number Description or Title
Date or Revision
2506869 NRC MOD/5059 Inspection:
EDG Fuel Consumption
May 28, 2015  CORRECTIVE ACTION PROGRAM DOCUMENTS (ARs) REVIEWED Number Description or Title
Date or Revision
00191696 Uncovering of the IC
Tubes December 18, 2003 00210558 Additional Proof Needed to Conclude Cold M/U Splash March 24, 2004 00919110 NRC Concern
- EDG Fuel Oil Storage Tank Alarm Setpoint Margin
May 13, 2009 01405505 1B CCCT Supply Pump Found Tripped
August 27, 2012 01456015 Procedure Enhancement Regarding IC Level
December 27, 2012 01533278 C/O Requires a 50.59 Screening
July 13, 2013 02386093 Mod/50.59 2014 FASA
- EDG Fuel Consumption
September 25, 2014 02388710 Dresden Susceptible to Similar NRC Violation Issued to Fermi
September 30, 2014 02420155 C/O 118604 Has Been Placed for >90
Days December 3, 2014 02469215 Inadequate 50.59 Eval for ASD Modifications
March 16, 2015  DRAWINGS Number Description or Title
Date or Revision
2E-2302A Key Diagram 4160
/480V SWGR s & 480V MCC s Y 12E-2304 Key Diagram 4160V SWGRs 23-1 and 24-1 W 12E-2306 Key Diagram
-Reactor Building 480V SWGR 28 & 29 AE 12E-2328 Single Line Diagram Emergency Power System
O 12E-2509, Sheet 1 Schematic Diagram Primary Containment Isolation System Clean
-Up System Isolation Logic
AY & AZ M-22 Diagram of SW Piping EO M-27 Diagram of Core Spray Piping
AAN M-30, Sheet 1 Diagram of RWCU System AAP M-355 Diagram of SW Piping SI M-375 Diagram of Fire Protection Piping
M M-517 DG Engine Cooling
H 2 O System I  MODIFICATIONS
Number Description or Title
Date or Revision
EC 347256 Replacement of Solenoid Valves 2(3)-1601-58, -59, -61, -62 with EQ Qualified Solenoid Valves
April 3, 2012 EC 380369 Revise Setpoints for ED G Fuel Oil Storage Tanks Level Switches
0 EC 383034 IC Valves Cable Reroutes
1
MODIFICATIONS
Number Description or Title
Date or Revision
EC 388981 Modify Supports on CREV RCU 2/3
-9400-102 Skid/Frame to Facilitate Replacement of Valves
EC 390811 Rewire MOV 3
-3901 Circuitry to Support MSO Project, Revision
November 14, 2012 EC 391291 Rewire MOV 2
-1501-22B Circuitry to Support MSO Project, Revision
November 30, 2012 EC 398999 SFP Instrumentation
- Fukushima 0 0 IEE 81788 IEE for US Electric Motor, CAT.
ID 1414246-4 September 12, 2013 IEE 8178 9 IEE for US Electric Motor, CAT. ID
1452042-4 March 26, 2012  OTHER DOCUMENTS
Number Description or Title
Date or Revision
EC 0000346716
Review and Approve EQ ASCO Solenoid Valve Model NP8316A54E to Replace Commercial Non-EQ Solenoid Valve HB8316D14 for 2(3)-1601-58, 59, 61, & 62.
February 5, 2004 EC 0000347323
Review and Approve Seismic Qualification of Solenoid Valve Model NP8316A54E to Replace Solenoid Valve HB8316D14 for 2(3)
-1601-58, 59, 61, & 62. EC
346716 Addressed EQ Portion Only
February 13, 2004 GEH-OLNC-0000-010 4-3152-02-R0 On-Line NobleChemTM (OLNC) Application Technical Safety Evaluation for Dresden
U 2 00 NEDC-33635P On-Line NobleChemTM (OLNC) Application Technical Safety Evaluation for Dresden
U 3 0 1 WO 99016611 D3 6Y PM Replace SR/EQ Solenoid on N
M/U VLV 1601-59 November 21, 2006  PROCEDURES
Number Description or Title
Date or Revision
CC-AA-112 Temporary Configuration
Changes 22 CC-AA-304 Component Classification
5 CC-AA-309-1002 Key Calculation Identification and Improvement
2 DAN 902(3)-3D-4 IC Level Hi/Low Annunciator Respond Procedure
DAN DG2(3)(2/3)AC
-2 Engine Start Air Press Low or Locked Out or Air Valve Closed or Not Full Open Annunciator Response Procedure
DES 0040-08 ASCO Solenoid Valve Surveillance/Replacement
DGA-12 Partial or Complete Loss of AC Power
DIS 6600-01 DG Starting Air Press Instrumentation Calibration
DOA 0010-04 Floods 34 DOP 1300-02 Automatic Operation of IC
& 26 DOP 1300-03 Manual Operation of IC
& 35 DOP 1300-09 IC M/U Pump Local Operation
6 DOP 2300-01 HPCI System Standby Operation
PROCEDURES
Number Description or Title
Date or Revision
DOS 0500-05 Calculation of Core Thermal Power
DOS 6600-01 DG Surveillance Tests
28 DOS 6600-14 Diesel Oil Transfer Pump Operation and Fuel Consumption Test
EP-AA-1004 Addendum 3 Dresden EAL Tables
0 OP-AA-109-101-1002 Clearance
and Tagging Quarterly Audit
3 SM-AA-300 Procurement Engineering Support Activities
6 SM-AA-300-1001 Procurement Engineering Process and Responsibilities
REFERENCES
Number Description or Title
Date or Revision
NRR Letter to Commonwealth Edison Company
Safety Evaluation By NRR Related to Amendment 140 to FOL
No. DPR-19 September 21, 1995
LIST OF ACRONYMS USE
D ADAMS Agencywide Documents Access and Management System
CALC Calculation
CAP Corrective Action Program
CFR Code of Federal Regulations
CNO Chief Nuclear Officer
DRS Division of Reactor Safety
EDG Emergency Diesel
Generator HPCI High Pressure Coolant Injection
Hz Hertz IC Isolation Condenser
IMC Inspection Manual Chapter
IP Inspection Procedure
ISCO Isolation Condenser
LLC Limited Liability Company
MBtu Million British Thermal Units
NCV Non-Cited Violation
NEI Nuclear Energy Institute
NRC U.S. Nuclear Regulatory Commission
NRR Office of Nuclear Reactor Regulation
NUREG NRC Technical Report Designation
PARS Public Available Records
RG Regulatory Guide
SR Surveillance Requirement
SSC Structures, Systems and Components TS Technical Specifications
UFSAR Updated Final Safety Analysis Report


B. Hanson -2- In accordance with Title 10 of the Code of Federal Regulations
==LIST OF ITEMS==
(10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy
 
of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide
===OPENED, CLOSED AND DISCUSSED===
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
 
-rm/adams.html
===Opened and Closed===
(the Public Electronic Reading Room).
: 05000237/2015007-01;        NCV    Procedure Revisions Resulted in Isolation Condenser Unable
Sincerely,  /RA/
: 05000249/2015007-01                to Meet Design Basis (Section 1R17.1b.)
Dariusz Szwarc , Acting Chief Engineering Branch
: 05000237/2015007-02;         NCV    EDG Usable Fuel Calculations Failed to Consider Appropriate
Division of Reactor Safety
: 05000249/2015007-02                EDG Frequency Variations (Section 1R17.2b.)
Docket Nos. 50
 
-237, 50-249; 72-037 License Nos. DPR
===Discussed===
-19; DPR-25 Enclosure:
 
Inspection Report
None
0500 0237/2015007; 05000249/2015007 cc w/encl:
 
Distribution via LISTSERV  DISTRIBUTION
==LIST OF DOCUMENTS REVIEWED==
w/encl: Kimyata MorganButler
 
RidsNrrDorlLpl3
-2 Resource
RidsNrrPMDresden Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Darrell Roberts
Richard Skokowski
Allan Barker Carole Ariano
Linda Linn
DRPIII DRSIII Jim Clay Carmen Olteanu
ROPreports.Resource@nrc.gov
ADAMS Accession Number ML15183A063
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 E RIII        NAME MJeffers for GHausman:cl DSzwarc    DATE 06/25/15 07/01/15    OFFICIAL RECORD COPY
}}
}}

Latest revision as of 04:29, 20 December 2019

IR 05000237/2015007; 05000249/2015007; on 05/11/2015 - 05/29/2015; Dresden Nuclear Power Station; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications (Gmh)
ML15183A063
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/01/2015
From: Dariusz Szwarc
Engineering Branch 3
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2015007
Download: ML15183A063 (20)


Text

UNITED STATES uly 1, 2015

SUBJECT:

DRESDEN NUCLEAR POWER STATION - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000237/2015007; 05000249/2015007

Dear Mr. Hanson:

On May 29, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Dresden Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on May 29, 2015, with Mr. Shane Marik, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

NRC inspectors documented two NRC-identified findings of very-low safety significance (Green)

in this report. These findings were determined to involve violations of NRC requirements.

However, because of their very-low safety significance, and because these issues were entered into your Corrective Action Program, the NRC is treating these issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2, of the NRC Enforcement Policy.

If you contest the subject or severity of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Dresden Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Dresden Nuclear Power Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dariusz Szwarc, Acting Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-237, 50-249;72-037 License Nos. DPR-19; DPR-25

Enclosure:

Inspection Report 05000237/2015007; 05000249/2015007

REGION III==

Docket Nos: 50-237; 50-249 License Nos: DPR-19; DPR-25 Report No: 05000237/2015007; 05000249/2015007 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station Location: Morris, IL Dates: May 11 - 29, 2015 Inspectors: George M. Hausman, Senior Engineering Inspector (Lead)

Jorge J. Corujo-Sandin, Engineering Inspector Mark T. Jeffers, Engineering Inspector Observer: Christopher A. Hunt, Reactor Engineer Approved by: Dariusz Szwarc, Acting Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000237/2015007; 05000249/2015007; 05/11/2015 - 05/29/2015; Dresden

Nuclear Power Station; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments, and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. Two findings of very-low safety significance were identified by the inspectors. The findings were considered Non-Cited Violations of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were determined using IMC 0310, Aspects within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very-low safety significance, and an associated Non-Cited Violation (NCV) of Title 10, Code of Federal Regulations (CFR),

Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that applicable regulatory requirements and the isolation condensers (ICs) design bases were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases. The licensee entered the issue into their Corrective Action Program (CAP) as Action Request 02506445, NRC MOD/5059 Inspection: ISCO [Isolation Condenser] Operating Procedures, dated May 28, 2015.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality, and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC from performing its design function of removing decay heat from the reactor. The finding has a cross-cutting aspect in the area of Human Performance; Teamwork, because the licensee did not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes.

[H.4] (Section 1R17.1b)

Green.

The inspectors identified a finding of very-low safety significance, and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG) Calculation 10553-CALC-07, Dresden Station

Emergency Diesel Generators Endurance Calculations, Revision 2, which resulted in non-conservative Technical Specifications (TS). Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz),

and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour. The licensee entered the issue into their CAP as Action Request 02506869,

NRC MOD/5059 Inspection: Emergency Diesel Generator Fuel Consumption, dated May 28, 2015.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency. Therefore, the licensee did not ensure that the minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution; Identification, because the licensee did not did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation. Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS.

[P.1] (Section 1R17.2b)

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed 7 evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine if the evaluations were adequate, and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 15 screenings, where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

  • the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59, and that sufficient documentation existed to confirm that a license amendment was not required;
  • the safety issue requiring the change, tests or experiment was resolved;
  • the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and
  • the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide (RG) 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted 7 samples of evaluations, and 15 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP) 71111.17-04.

b. Findings

Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis

Introduction:

The inspectors identified a finding of very-low safety significance (Green),and an associated Non-Cited Violation (NCV) of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that applicable regulatory requirements and the isolation condensers (ICs) design bases were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases.

Description:

The safety-related IC system functions as a heat sink for decay heat removal from the reactor vessel following a reactor scram, and isolation from the main condenser. Each IC (one per unit) consists of two tube bundles immersed in a large water storage tank. The IC system operates by natural circulation. During operation, the IC tube side will contain reactor coolant water, and the shell side will contain clean demineralized water.

The inspectors observed that the licensee made changes to three IC control procedures.

The procedure changes directed operators to secure the IC on a low-shell side level condition. Specifically, the IC would be secured if the shell side level could not be maintained above 3.5 feet. At this height, the water level in the shell is just above the top of the tube bundles. The purpose of the procedure change was to prevent uncovering of the tube bundles in order to protect the IC for future availability (i.e., when the shell side level could be restored to ensure the IC would be available to respond to a Beyond Design Basis External Event). The procedures affected were as follows:

  • DOP 1300-02, Automatic Operation of Isolation Condenser, Revision 25, Step G.4.a;
  • DOP 1300-03, Manual Operation of the Isolation Condenser, Revision 34, Step G.9.a; and
  • DAN 902(3)-3D-4, Isolation Condenser Level Hi/Low Annunciator Respond Procedure, Revision 12, Step B.2.a.

In the Updated Final Safety Analysis Report (UFSAR), Section 5.4.6 and the Technical Specifications (TS) Bases 3.5.3, the IC design basis was described as:

(1) remove 252.5 Million British thermal units (MBtu)/hour, which is equivalent to the decay heat rate 8.8 minutes after the scram; and
(2) provide sufficient decay heat removal capability for 20 minutes of operation without makeup water to the shell. The TS requires a number of surveillance requirements (SRs) be performed to ensure these bases are met, including the following:
  • SR 3.5.3.1: Verify the IC system shellside water level 6 feet, and shellside water temperature 210°F; and
  • SR 3.5.3.4: Verify the IC system heat removal capability to remove design heat load [i.e., 252.5MBtu/hour].

The licensee maintains the shell water level above 7 feet via administrative controls and monitors the temperature in an effort to remain well below the temperature limits.

However, the licensing bases of the isolation condenser states that water level of the shell is expected to go below 3.5 feet in order to mitigate a credited event under design bases conditions. As a result, procedural guidance, which would prevent the isolation condenser shell water level from going below 3.5 feet, would preclude the component from performing its design function under design bases conditions.

As part of immediate corrective actions the licensee marked the procedures for review in order to determine required changes. In addition, the licensee demonstrated the shell water temperature was monitored in order to maintain it well below TS requirements and the water level was administratively maintained at or above 7 feet. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 foot limit.

The licensee documented the inspectors concern under AR 02506445, NRC Mod/5059 Inspection: ISCO [Isolation Condenser] Operating Procedures, dated May 28, 2015.

The licensee plans to evaluate the IC procedural changes and determine what modifications are needed. In addition, the licensee is considering performing an Apparent Cause Evaluation to evaluate the concern. The inspectors concluded that procedural changes were performed by the Operations Department without engaging the Engineering Department to ensure there were no adverse impacts to the IC or associated design and licensing bases.

Analysis:

The inspectors determined that the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet, which was contrary to 10 CFR, Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency.

Specifically, the added steps would result in the IC being shutdown when required to operate per the ICs design bases.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Procedure Quality, and affected the cornerstone's objective of ensuring the availability, reliability and capability of the systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the inadequate procedures would drive the operators to stop the IC during a design bases event and prevent the IC from performing its design basis function of removing decay heat from the reactor.

In accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of mitigating structures, systems, and components (SSC); however, the SSC maintained its operability or functionality as applicable. Specifically, the licensee administratively maintains the shell water level at or above 7 feet and the temperature is maintained below 210 degrees Fahrenheit. This provides additional margin to the IC to perform its design function prior to reaching the 3.5 foot limit. Therefore, the inspectors answered "yes" to the Mitigating Systems Screening Question A.1 in Exhibit 2, and screened the finding as having very-low safety significance (Green).

The finding has a cross-cutting aspect in the area of Human Performance; Teamwork because the licensee did not communicate and coordinate activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Operations Department failed to communicate and coordinate with the Engineering Department when developing the procedural changes. [H.4]

Enforcement:

Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from April 22, 2013, to May 29, 2015, the licensee failed to ensure that applicable regulatory requirements and the ICs design basis were correctly translated into procedures. Specifically, the licensee added steps to the IC control procedures which directed operators to secure the IC in order to prevent the water level in the shell from going below 3.5 feet. The added steps would result in the IC being shutdown when required to operate per the ICs design bases.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance and was entered into the licensees CAP as Action Request 02506445, NRC MOD/5059 Inspection: ISCO Operating Procedures, dated May 28, 2015. The licensee will continue to administratively control level of the shell at or above seven feet to provide additional margin to the IC to perform its function. (NCV 05000237/2015007-01; NCV 05000249/2015007-01, Procedure Revisions Resulted in Isolation Condenser Unable to Meet Design Basis)

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed nine permanent plant modifications that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for portions of the modified High Pressure Coolant Injection (HPCI) system to assess recent replacement of the auxiliary oil pump. The modifications were selected based upon risk-significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

  • the supporting design and licensing basis documentation was updated;
  • the changes were in accordance with the specified design requirements;
  • the procedures and training plans affected by the modification have been adequately updated;
  • the test documentation as required by the applicable test programs has been updated; and
  • post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.

This inspection constituted nine permanent plant modification samples as defined in IP 71111.17-04.

b. Findings

Emergency Diesel Generator Usable Fuel Calculations Failed to Consider Appropriate Emergency Diesel Generator Frequency Variations

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated NCV of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the failure to account for increased fuel oil consumption during the development of the Emergency Diesel Generator (EDG) endurance calculations which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hertz (Hz), and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.

Description:

The TSs SR 3.8.1.2 allows an EDG frequency tolerance of +/- 2 percent.

This tolerance was based on RG 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants, Revision 4, requirements that the EDG frequency recover to within +/- 2 percent of 60 Hz (i.e., 58.8 - 61.2 Hz) within a specified period during the sequencing of loads on the bus. Therefore, the EDGs could operate at a frequency of 61.2 Hz, which would be the worst-case scenario for loading of the EDGs.

Additionally, TS SR 3.8.1.4 verifies adequate level of fuel oil in the day tank and the bulk storage tanks. The level selected is to ensure adequate fuel oil for a minimum of one hour of EDG operation at 110 percent of full load for the day tank and approximately two days at 100 percent full load for the bulk storage tanks. The levels identified by TS SR 3.8.1.4 are 205 gallons and 10,000 gallons for the day tank and bulk storage tank, respectively.

During review of Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, the inspectors questioned why the licensee based their fuel consumption on the EDGs operating at 110 percent at 60 Hz rather than 61.2 Hz as allowed by TS SR 3.8.1.2. The higher frequency would result in higher fuel consumption; therefore, would be more conservative. Specifically, the estimated fuel consumption at 110 percent loading at 61.2 Hz would be approximately 211.3 gallons/hour. The calculation did identify that the 2 percent frequency tolerance would result in higher fuel consumption; however, the more conservative frequency was only applied to calculating EDG loading at 100 percent. The calculation of the day tank level at 110 percent only considered the less conservative 60 Hz frequency.

The inspectors determined that the EDGs could operate at a steady state frequency up to 61.2 Hz according to TS SR 3.8.1.2. This would result in a higher fuel consumption that would exceed the TS 3.8.1.4 minimum volumetric fuel requirements. The TS 3.8.1.4 minimum fuel requirements were based on operating the EDGs at a frequency up to 60 Hz, rather than 61.2 Hz, which resulted in non-conservative TS.

The inspectors discussed the issue with the licensee and identified that the licensee had administrative procedures that would limit the frequency of the EDG to 60.5 Hz and would ensure the day tank level remained greater than 350 gallons. The Dresden Procedure DGA-12, Partial or Complete Loss of AC Power, Revision 73, ensures operators maintain frequency of the EDGs between 59.5 to 60.5 Hz. Additionally, Dresden Surveillance Procedure DOS 6600-14, Diesel Oil Transfer Pump Operation and Fuel Consumption Test, Revision 20, requires operators to maintain at least 350 gallons in the day tank. Therefore, the EDG would remain capable of performing its specified safety function. However, even with the administrative limits, the minimum fuel requirements identified in TS SR 3.8.1.4 would remain non-conservative since the fuel consumption would still be higher at the 60.5 Hz which is not represented in TS SR 3.8.1.4. The licensee captured this issue and entered it into their CAP as Action Request 02506869. The licensee intends to evaluate the effect of the increased frequency on their EDG Calculations.

Analysis:

The inspectors determined that the licensees failure to account for increased fuel oil consumption during the development of the EDG Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, resulted in non-conservative TS and was contrary to 10 CFR, Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz, and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to account for the increased fuel oil consumption resulting from operation at a higher EDG frequency. Therefore, the licensee did not ensure that the minimum fuel oil level in the day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.

In accordance with IMC 0609, Significance Determination Process, Attachment 609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality as applicable. Specifically, the licensee was able to demonstrate that adequate fuel in the storage tanks would be available to support the EDGs mission time when operating at the administratively controlled higher frequency limit specified in procedures. Therefore, the inspectors answered "no" to all the Mitigating Systems Screening Questions in Exhibit 2, and screened the finding as having very-low safety significance (Green).

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution; Identification because the licensee did not thoroughly evaluate the EDG fuel oil consumption when considering EDG frequency variation. Specifically, the licensee failed to translate applicable design bases into specifications which resulted in non-conservative TS. [P.1]

Enforcement:

Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to ensure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from May 25, 2011, until May 29, 2015, the licensee failed to ensure that applicable regulatory requirements and the design basis were correctly translated into specifications during development of the EDG Calculation 10553-CALC-07, Dresden Station Emergency Diesel Generators Endurance Calculations, Revision 2, which resulted in non-conservative TS. Specifically, the licensee failed to account for the increased fuel oil consumption at an EDG frequency of 61.2 Hz, and ensure that the minimum fuel oil level in the EDG day tanks, as required per TS 3.8.1.4, was adequate to support the EDGs mission time at 110 percent for one hour.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance, and was entered into the licensees CAP as Action Request 02506869, NRC MOD/5059 Inspection:

EDG Fuel Consumption, dated May 28, 2015. The licensee is evaluating the effect of the increased frequency on their EDG calculations, and will continue to administratively control level in the fuel oil day tank high enough to ensure the SSC remains operable.

(NCV 05000249/2015007-02; NCV 05000237/2015007-02, EDG Usable Fuel Calculations Failed to Consider Appropriate EDG Frequency Variations)

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification, and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On May 29, 2015, the inspectors presented the inspection results to Mr. Shane Marik, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

G. Baxa, Regulatory Assurance
M. Budelier, Senior Manager Design Engineering
D. Doggett, Regulatory Assurance
D. Eaman, Design Instrumentation and Control (I&C) Manager
B. Franzen, Regulatory Assurance Manager
R. Gaston, Licensing Manager - Corporate
T. Griffith, Senior Licensing Engineer
B. Kapellas, Maintenance Director
B. Madderom, Design Electrical Manager
S. Marik, Site Vice President
G. Morrow, Operations Director
P. OBrien, Site Corrective Action Program Manager
R. Osgood, Senior Nuclear Site Communications Specialist
E. Rogers, Nuclear Oversight
R. Schmidt, Chemistry Manager
B. Surges, Work Control
D. Walker, NRC Coordinator
J. Washko, Plant Manager
D. Wolverton, Design Mechanical Manager

U.S. Nuclear Regulatory Commission

K. OBrien, Director, Division of Reactor Safety
G. Roach, Senior Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000237/2015007-01; NCV Procedure Revisions Resulted in Isolation Condenser Unable
05000249/2015007-01 to Meet Design Basis (Section 1R17.1b.)
05000237/2015007-02; NCV EDG Usable Fuel Calculations Failed to Consider Appropriate
05000249/2015007-02 EDG Frequency Variations (Section 1R17.2b.)

Discussed

None

LIST OF DOCUMENTS REVIEWED