IR 05000237/2023003

Integrated Inspection Report 05000237/2023003 and 05000249/2023003 and Exercise of Enforcement Discretion

ML23317A081
Person / Time
Site:	Dresden
Issue date:	11/13/2023
From:	Robert Ruiz NRC/RGN-III/DORS/RPB1
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
EA?23?087 IR 2023003
Download: ML23317A081 (1)

Text

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2023003 AND 05000249/2023003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear David Rhoades:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On October 18, 2023, the NRC inspectors discussed the results of this inspection with P. Boyle, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, 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; and the NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3.

November 13, 2023 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000237 and 05000249 License Nos. DPR19 and DPR25

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000237 and 05000249

License Numbers:

DPR-19 and DPR-25

Report Numbers:

05000237/2023003 and 05000249/2023003

Enterprise Identifier:

I2023003-0051

Licensee:

Constellation Energy Generation, LLC

Facility:

Dresden Nuclear Power Station, Units 2 and 3

Location:

Morris, IL

Inspection Dates:

July 01, 2023 to September 30, 2023

Inspectors:

J. Cassidy, Senior Health Physicist

A. Muneeruddin, Resident Inspector

M. Porfirio, Illinois Emergency Management Agency

C. St. Peters, Resident Inspector

J. Steffes, Senior Resident Inspector

Approved By:

Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.1

List of Findings and Violations

Failure to Perform Performance Response Check for Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000237,05000249/202300301 Open/Closed

[H.11] -

Challenge the Unknown 71124.08 The inspectors identified a finding of very low safety significance (Green), and an associated non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to implement procedures for control of radioactivity. Specifically, the licensee did not conduct a performance source check on a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas, as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.

Failure to Install Safety-Related Circuit Breakers in the Unit 2 Alternate Battery, a Safety-Related System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237,05000249/202300302 Open/Closed None (NPP)71152A A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion III, occurred on July 6, 2023, when it was identified that non-quality controlled, non-dedicated circuit breakers were installed in the Unit 2 125VDC alternate battery, a safety-related system.

Additional Tracking Items

Type Issue Number Title Report Section Status ED EA23087 Enforcement Action EA23087: Failure to Comply with 10 CFR Part 37 71124.08 Closed

PLANT STATUS

Unit 2 began the inspection period at full rated thermal power. On July 8, 2023, the unit was reduced to 82 percent power for control rod pattern adjustment and the unit was returned to full power the next day. On August 19, 2023, the unit was reduced to 82 percent power for control rod pattern adjustment and the unit was returned to full power the next day. On September 1, 2023, the unit was reduced to 84 percent power for control rod pattern adjustment, and the unit was returned to full power the same day. On September 2, 2023, the unit was reduced to 84 percent power for the final control rod pattern adjustment and scram solenoid pilot valve replacement; the unit was returned to full power the same day. On September 8, 2023, the unit entered coast down operations in preparation for refueling outage D2R28 and remained in that condition for the remainder of the inspection period.

Unit 3 began the inspection period at full rater thermal power. On September 1, 2023, the unit was reduced to 67 percent power for control rod pattern adjustment and turbine generator automatic voltage regulator maintenance. The unit was returned to full power operation on September 2, 2023, and remained at or near full power for the remainder of the inspection period.

INSPECTION SCOPES

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

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 2 high pressure coolant injection (HPCI) system on August 2-7, 2023

(2) Unit 3 A reactor building closed cooling water on August 8-18, 2023

(3) Unit 2 service water system on August 9-21, 2023

(4) Unit 2 low pressure coolant injection system on August 31, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone (FZ) 8.2.1A, Unit 2 condensate pumps elev. 469', and FZ 8.2.1B, Unit 3 condensate pumps elev. 469' on July 7, 2023

(2) FZ 11.3, Unit 2/3 circulating water pumps elev. 490', Unit 2/3 service water pumps / traveling screens elev. 509', and Unit 2/3 crib house ground floor elev. 517' on August 2, 2023

(3) FZ 11.2.2, Unit 2 southeast corner room elev. 476' on August 3, 2023

(4) FZ 1.1.2.1, Unit 2 torus basement elev. 476' and torus catwalk on August 3, 2023

(5) FZ 7.0A.13/8.2.7, Unit 2 battery room elev. 549' on August 7, 2023

(6) FZ 1.1.1.2 Unit 3 reactor building ground floor elev. 517', and FZ 1.1.1.3 Unit 3 reactor building general area elev. 545' on August 22, 2023

(7) FZ 11.1.3, Unit 3 HPCI pump room elev. 476', and FZ 11.1.2 Unit 3 southeast corner room elev. 476' on August 30, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on August 10, 2023.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the: Unit 2 reactor building mezzanine elevation 545' Unit 3 reactor building mezzanine elevation 545'

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during rod pattern adjustment in support of end of cycle operations on July 8-9, 2023

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed crew performance in the simulator during scenarios LT SEG 2301A and LT SEG DOA 440006, on August 9, 2023

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Radiation monitoring

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Unit 2 station blackout (SBO) diesel maintenance window from June 26-29, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Emergent plant challenges associated with grassing event at the ultimate heat sink, on July 19, 2023

(2) Station risk during elevated outside temperatures, week of August 21-25, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 3 battery room A/C compressor and fan breaker tripped, as documented in CR 4688851

(2) Unit 3 SBO diesel generator output breaker failed to close during testing as documented in CR 4548341

(3) Unit 3 HPCI check valve 32301-7 will not open < 90 ft/lbs torque as documented in CR 4535439

(4) FLEX hose trailer 3 not tied down as documented in CR 4694915 (5)2/3 reactor building and chimney particulate, iodine, and noble gas monitor system following sample results as documented in CR 4695055

(6) Cardox fire suppression system functionality determination following leak identification as documented in CR 4695609

(7) Unit 2 emergency diesel generator (EDG) failed to start from the control room as documented in CR 4696270 (8)

===24115-500, Fire Protection H2 Seal Unit Deluge System SV, valve closed without required fire watch established as documented in CR 4696111

(9) Increase in Unit 2 drywell floor drain leakage as documented in CR 4701027

71111.18 - Plant Modifications

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

=

The inspectors evaluated the following temporary or permanent modifications:

(1) TCC202302-037, U2 digital electrohydraulic control (DEHC) axial thrust bearing wear detector probe #1 forced value entered

(2) TCC202303-003, Install an auxiliary oil tank in the drywell to provide ability to add oil to the 3B recirculation pump motor lower bearing

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)

(1) Unit 3 station blackout (SBO) diesel run following breaker replacement, on July 15, 2023

(2) Unit 3 B fuel pool cooling pump run following replacement of 31901-108B, 3B fuel pool cooling pump suction, on August 25, 2023

(3) Unit 2 EDG modified run following replacement of control switch 26640-48 on August 28, 2023

Surveillance Testing (IP Section 03.01) (2 Samples)

(1) Unit 3 HPCI system test, work order 5382243

(2) Unit 2 HPCI system test, work order 5379811

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1)2/3 diesel generator cooling water pump test, work order

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling,

Storage, & Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:

(1) Interim Radwaste storage facility

(2) Unit 1 Sealand yard

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Resins associated with the ALPS system

(2) Bags and barrels in the radwaste storage bins

Waste Characterization and Classification (IP Section 03.03) (4 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) ALPS Cation Resin

(2) DAW Smears

(3) Fuel Pool Resin

(4) ALPS Anion Resin

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed the preparation of radioactive shipment DW23026

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) DW22020; Resin Cask; LSA-II

(2) DW22010; Fuel Pool Cleanup Resin; LSA-II

(3) DW23001; DAW Trash; LSA-II

(4) DW23020; ALPS Resin; LSA-II

OTHER ACTIVITIES-BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07)===

(1) Unit 2 (July 1, 2022 through June 30, 2023)

(2) Unit 3 (July 1, 2022 through June 30, 2023)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 2 (July 1, 2022 through June 30, 2023)

(2) Unit 3 (July 1, 2022 through June 30, 2023)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 2 (July 1, 2022 through June 30, 2023)

(2) Unit 3 (July 1, 2022 through June 30, 2023)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 (November 1, 2022 through May 31, 2023)

(2) Unit 2 (November 1, 2022 through May 31, 2023)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) November 1, 2022 through May 31, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) November 1, 2022 through May 31, 2023 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample 1 Partial)

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

(1) Non-safety-related components installed in the Unit 2 125V DC alternate battery feed circuit breakers, which require safety-related components, as documented in CR 4688989 (2)

(Partial)2/3 emergency diesel generator output breaker opened unexpectedly during surveillance run

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Enforcement:

Violation: Dresden Nuclear Power Station, Unit 2, Renewed Facility Operating License, section 2.E requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection plan requires compensatory measures are established when fire protection SSCs are impaired. Procedure CCAA211, Fire Protection Program, Revision 9, details the fire protection and prevention administrative control procedures are established to govern the handling and use of transient combustible materials, maintain housekeeping to minimize fire hazards, control cutting and welding operations by use of a permit system, control the use of temporary heating sources, control the impairment of fire protection SSCs, and post fire watches. Procedure OPAA201007, Fire Protection System Impairment Control, Revision 2, provides instructions for establishing and performing compensatory measure fire watch inspections. Last, procedure OPAA108101, Control of Equipment and System Status, Revision 18, addresses the identification of temporary equipment conditions and status via the Abnormal Component Position Sheets (ACPS) and Equipment Status Tags.

Contrary to the above, on August 4, 2023, the licensee failed to implement provisions of the approved fire protection program. Specifically, the site terminated the continuous fire watch previously established when valve 24415-500, Fire Protect H2 Seal Unit Deluge System SV, was taken to the closed position. The fire watch was terminated without restoring the valve to the open position. This is contrary to the guidance and requirements established in the procedures requiring a continuous fire watch until the valve was restored to its normal position, open.

Significance/Severity: Green. Specifically, the inspectors determined that this finding screened to Green because the degraded or non-functional detection or fixed suppression system did not adversely affect the ability of the system to protect any equipment important to safe shutdown.

Corrective Action References: AR 4696111, Impairment closed out improperly Failure to Perform Performance Response Check for Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000237,05000249/202300301 Open/Closed

[H.11] -

Challenge the Unknown 71124.08 The inspectors identified a finding of very low safety significance (Green), and an associated non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to implement procedures for control of radioactivity. Specifically, the licensee did not conduct a performance source check on a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.

Description:

Licensee procedure RPAA700, Controls for Radiation Protection Instrumentation establishes the administrative controls for radiation protection instrumentation maintained for use at the Dresden Station. Step 4.9.5 describes the source response checks for portable survey instruments and stationary GM friskers and states Except as noted below, short-term issued portable survey meters and stationary GM friskers shall be performance checked daily or prior to use, whichever is less frequent. Step 4.9.5.6 (a defined exception to the daily frequency) states, Portable survey instruments and stationary GM friskers may be performance source checked weekly in accordance with this section, provided they are not used for critical surveys. Procedure RPAA700, Controls for Radiation Protection Instrumentation Step 2.9 defines a critical survey as Surveys of personnel or materials for release for unrestricted use On July 3, 2023, the personnel contamination monitor at the radwaste control room was removed from service. This monitor surveyed personnel leaving the radiologically controlled area (RCA) into the unrestricted area. Removing the personnel contamination monitor from service required personnel to use a stationary hand-held frisker to perform the critical radiological surveys necessary to leave the RCA. Consequently, the performance source check frequency should have changed from weekly to daily for this stationary frisker when it was used for these critical surveys.

On July 17, 2023, the frisker successfully passed the performance source check.

On July 19, 2023, the inspectors identified that frisker appeared non-responsive to background radiation with only an occasional click, with long intervals of silence. It was explained that the area was low background. However, when radiation protection personnel conducted a performance source check the asfound condition of the instrument was not within acceptance criteria for the response check.

Corrective Actions: The licensee changed the performance source check frequency for this frisker, and other friskers located at RCA exit points, to a daily frequency. Additionally, the licensee performed radiological survey 2023197910 of the area likely impacted (radwaste control room) by this performance deficiency and demonstrated radioactive contamination was not identified in the unrestricted area.

Corrective Action References: AR 04691430

Performance Assessment:

Performance Deficiency: The licensee did not conduct a performance source check a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.

Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. The performance deficiency had the potential to lead to a more significant radiation safety concern because of an ineffective radiation program barrier. Specifically, when response checked, the asfound condition of the instrument was not within acceptance criteria for the response check.

This is Example 6.b from Inspection Manual Chapter 0612 Appendix E Examples of Minor Issues.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, because:

(1) it did not involve aslow-asreasonably-achievable (ALARA)planning or work controls,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, when radiation protection removed the personnel contamination monitor from service the risk from potentially inadequate surveys from the inferior replacement equipment was not recognized, evaluated, or managed.

Enforcement:

Violation: Technical Specification 5.4.1, Procedures, states in part, written procedures shall be established, implemented and maintained covering activities contained in Regulatory Guide 1.33, Revision 2, Appendix-A, dated February 1978.

NRC Regulatory Guide 1.33, Appendix A, Section 7 addresses Procedures for Control of Radioactivity, and Section e. Radiation Protection Procedures,

(4) addresses Contamination Control.

Licensee procedure RPAA700 Controls for Radiation Protection Instrumentation, Revision 09, provides requirements for instrumentation used to survey potentially contaminated personnel and materials before being released to unrestricted areas (a critical survey). Step 4.9.5 requires stationary GM friskers used for critical surveys shall be performance source checked daily.

Contrary to the above, between July 3 and July 19, 2023, the licensee failed to implement step 4.9.5 of procedure RP-AA-700. Specifically, the licensee failed to conduct daily performance source checks as required for a frisker used for critical surveys as required by the procedure.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Enforcement Discretion Enforcement Action EA23087:

Failure to Comply with 10 CFR Part 37 71124.08

Description:

On April 27, 2016, the licensee was issued NRC Inspection Report Nos. 05000237/2016405 and 05000249/2016405, which documented a licensee-identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for enforcement discretion as described in Enforcement Guidance Memorandum (EGM)14001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.

Subsequently, the inspectors reevaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14001.

Corrective Actions: As specified in EGM 14001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action.

Enforcement:

Violation: On April 27, 2016, a violation of 10 CFR Part 37 was documented in Dresden Inspection Report Nos. 05000237/2016405 and 05000249/2016405. The inspectors determined that the previously identified violation remains.

Basis for Discretion: This violation met the criteria for enforcement discretion as described in Enforcement Guidance Memorandum (EGM) 14001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.

Failure to Install Safety-Related Circuit Breakers in the Unit 2 Alternate Battery, a Safety-Related System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237,05000249/202300302 Open/Closed None (NPP)71152A A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion III, occurred on July 6, 2023, when it was identified that non-quality controlled, non-dedicated circuit breakers were installed in the Unit 2 125VDC alternate battery, a safety-related system.

Description:

Around 1978, the 125V DC distribution panel number 5 and two GE model AK circuit breakers were originally installed in the Unit 1 HPCI building for the U1 HPCI 125V DC battery and charger. The original design for the components was U1 Division I Engineered Safety Feature, meaning the components were classified as safety-related (SR). Controlled drawings, on the record, identified nuclear safety-related equipment is shown on this drawing, which implied that SR quality equipment was procured and installed around this timeframe.

In the 1990s, a modification, SR modification M120-90013A 125 vdc Alternate Battery Installation, was approved for the installation of a new U2 safety-related 125V DC alternate battery. This installation was to be in the U1 HPCI building, as well as SR cable connections from distribution panel number 5 to the U2 Turbine Building SR 125V DC Bus 2A1. The modification repurposed the two SR GE model AK circuit breakers that were previously installed for the U1 HPCI 125V DC battery and charger to be used now for the new U2 alternate battery and charger. In 1991, a letter was issued from the NRC to Dresden Nuclear Station to follow up on discussions regarding the 125V DC alternate batteries. The letter included a description of the 125 VDC System design, an overview of the alternate 125 VDC battery design and installation, an overview of the Technical Specification changes to be proposed, and a schedule for submittal of these amendments, and the controls which will be imposed on any alternate battery usage prior to receipt of the amended Technical Specifications. The letter discussed the ability of the alternate battery to be put into service when the main battery is unavailable. Classification was established and controlled in plant documentation.

In 2003, the originally installed AK25 circuit breaker, Equipment Part Number (EPN)283125-5AC2, failed to close and a vendor overhaul was performed. The installed circuit breakers did not have a catalog identification number associated with them. The site planned to procure a new circuit breaker to install while the failed circuit breaker was being overhauled. A Quality Level 4 (QL4), or non-safety-related, catalog identification number was created. The work order created to install a new circuit breaker classified the work as non-safety related (NSR), and a NSR breaker was installed on March 26, 2004. This was a missed opportunity, as the correct quality level for the component should have been QL1, safety related.

In 2006, the site underwent a 16-year breaker overhaul for the original SR AK50 circuit breaker, EPN 283125-5AC1. In the work order for this overhaul, the circuit breaker was incorrectly noted to be a non-safety-related, augmented quality component, or QL3. This was another missed opportunity for the site to identify the circuit breakers were supposed to be safety related, QL1 components.

In 2011, an engineering change request (ECR) was done to add a safety classification to the U2 125V DC alternate battery circuit breakers in the Passport computer system due to the information being blank. The ECR noted the components were classified as safety-related, seismic class 1E components. In 2012, the ECR was completed with the safety classification information being filled in, but no reviews were conducted to look at work performed while the information in Passport was incomplete. This resulted in the site not being aware of the non-safety-related circuit breakers being installed.

In 2023, the site was preparing for the 16-year preventative maintenance on the Unit 2 125V DC alternate battery circuit breakers; it was discovered that the currently installed circuit breakers were non-safety-related components. A condition report was written, and the site performed a corrective action program evaluation (CAPE) to determine the cause of non-safety-related components being installed and maintained for a safety-related function.

The inspectors reviewed the condition report, CAPE, relevant associated documentation, and held discussions with the licensee staff to better understand the time frame and history of the circuit breakers and the U2 125V DC alternate battery. The inspectors questioned if the ECR in 20112013 would have involved reviewing the currently installed components at that time to see if they matched the missing safety classification. The site stated that nothing specific would have prompted that review in the engineering change request process. The licensee informed the inspectors they would be procuring QL1 circuit breakers to install during the planned 16-year preventative maintenance scheduled for September 2023.

Corrective Actions: Corrective actions included, but were not limited to, the site conducting a CAPE and replacement of the non-safety-related circuit breakers with safety-related circuit breakers on September 15, 2023.

Corrective Action References: CR 4688989, U2 125VDC Alt Battery Feed Circuit Breakers, SR Components Required

Performance Assessment:

Performance Deficiency: The inspectors determined the licensees failure to ensure safety-related circuit breakers were installed in the Unit 2 alternate battery, a safety-related system in accordance with 10 CFR 50 Appendix B, Criterion III, was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This determination was informed by IMC 0612, Appendix E, example 5.c, due to non-safety-related components, circuit breakers, being installed in the plant and the safety-related system, Unit 2 125 VDC alternate battery, returned to service.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered yes to question A1 in Exhibit 2 - Mitigating Systems Screening Question. This resulted in the issue screening to green.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Contrary to the above, from March 26, 2004, to July 6, 2023, the licensee failed to review for suitability of application of parts essential to the safety-related functions of the Unit 2 alternate battery. Specifically, the licensee found non-safety-related circuit breakers were installed when safety-related components were required to be installed in the Unit 2 alternate battery.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On October 18, 2023, the inspectors presented the integrated inspection results to P. Boyle, Site Vice President, and other members of the licensee staff.

• On July 21, 2023, the inspectors presented the radiation protection inspection results to C. Joseph, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Drawings

M22

Diagram of Service Water Piping

EZ

71111.04

Drawings

M29

Diagram of Low Pressure Coolant Injection Piping, Sheet 1

CR

71111.04

Drawings

M347

Diagram of Reactor Feed Piping

CK

71111.04

Drawings

M51

Diagram of High Pressure Coolant Injection Piping

CX

71111.04

Procedures

DOP 1500E1

Unit 2 Low Pressure Coolant Injection and Containment

Cooling Service Water Electrical Checklist

71111.04

Procedures

DOP 1500M1

Unit 2 Low Pressure Coolant Injection and Containment

Cooling Valve Checklist

71111.04

Procedures

DOP 2300M1/E1

Unit 2 High Pressure Coolant Injection System Checklist

71111.04

Procedures

DOP 3700M2/E2

Unit 3 RBCCW System Checklist

71111.04

Procedures

DOP 3900E1

Unit 2(3) Service Water and Screen Wash System Electrical

Checklist

71111.04

Procedures

DOP 3900M1

Unit 2/3 Service Water and Screen Wash Valve Checklist

71111.04

Procedures

DOP 3900M2

Unit 2 Emergency Room Coolers Valve Checklist

71111.05

Corrective Action

Documents

4698552

4.0 Critique Crew 5 Q3 Announced Fire Drill

08/25/2023

71111.05

Fire Plans

100 Prefire Plan

Master Legend

Dresden Generating Station Pre-Fire Plan

71111.05

Fire Plans

101 U2RB1

Unit 2 Torus Basement Elevation 476' and Torus Catwalk

71111.05

Fire Plans

103 U2RB3

Unit 2 Southeast Corner Room Elev. 476'

71111.05

Fire Plans

20 U3RB23

FZ 1.1.1.2 Unit 3 Rx Ground Floor Elev. 517'

71111.05

Fire Plans

24 U3RB26

FZ 1.1.1.3 Unit 3 General Area Elev. 545'

71111.05

Fire Plans

133 U2TB36

FZ 8.2.1A Unit 2 Condensate Pumps Elev. 469'

71111.05

Fire Plans

151 U2TB53

Unit 2 Battery Room Elev. 549'

71111.05

Fire Plans

157 U3TB68

FZ 8.2.1B Unit 3 Condensate Pumps Elev. 469'

71111.05

Fire Plans

196 Circ PPs-124

FZ 11.3 Unit 2/3 Circulating Water Pumps Elev. 490'

71111.05

Fire Plans

197 SW PPs-125

FZ 11.3 Unit 2/3 Service Water Pumps / Traveling Screens

Elev. 509'

71111.05

Fire Plans

198 U2/3 CH126

FZ 11.3 Unit 2/3 Crib House Ground Floor Elev. 517'

71111.05

Miscellaneous

Fire Drill Scenario

204

Diesel Generator Fire (IEMA Building)

08/10/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.05

Procedures

118 U3RB21

FZ 11.1.2 Unit 3 Southeast Corner Room Elevation 476'

71111.05

Procedures

119 U3RB22

FZ 11.1.3 Unit 3 High Pressure Coolant Injection Pump

Room Elevation 476'

71111.06

Engineering

Changes

390874

4KV Switchgear Internal Flood Barrier Protection Risk

Insight - Enhancement Dash Buses 331 and 341

71111.06

Engineering

Changes

393162

4KV Switchgear Internal Flood Barrier Protection Risk

Insight - Enhancement Dash Buses 231 and 241

71111.06

Miscellaneous

DRPSA012

Dresden Internal Flood Evaluation Summary and Notebook

71111.11Q

Procedures

NFAB720F-1

Control Rod Sequence Review and Approval Sheet

07/05/2023

71111.11Q

Procedures

NFAB720F-5

Special Maneuver Rod Move Sheet Sequence

ID: D228019

07/05/2023

71111.11Q

Procedures

ReMA Plan

D228019

D2C28 End of Cycle Rod Pull - 9D and 9B Array

07/03/2023

71111.12

Corrective Action

Documents

4442021

Unexpected Alarm 9033 C3, Isolation Condenser Vent

Monitor Downscale

08/22/2021

71111.12

Corrective Action

Documents

4551062

Unexpected Alarm 9023 B3 Isolation Condenser Vent Rad

Hi

01/29/2023

71111.12

Corrective Action

Documents

4676867

Unexpected Alarm 9033 F1 Area Rod Monitor Downscale

05/09/2023

71111.12

Corrective Action

Documents

4678267

Unexpected Alarm 9033 F1 Area Rad Monitor Downscale

05/15/2023

71111.12

Corrective Action

Documents

4681722

MCR Nuisance Alarm: 9023 B3 Isolation Condenser Vent

Rad HI

05/31/2023

71111.12

Miscellaneous

Radiation Monitor System Health Report

71111.12

Miscellaneous

WR 1540455

TS&R 31803-30, ARM 30 Off Gas Filter Building Spurious

Alarms

05/15/2023

71111.12

Procedures

DIS 130004

Isolation Condenser Vent Radiation Monitor Functional

Calibration and Operational Checks

71111.12

Work Orders

233135

EWP Mechanical Maintenance 12 Year Preventative

Maintenance 2B Station Blackout Diesel Generator,

Replace Air Start FLEX Hoses

06/26/2023

71111.12

Work Orders

233234

Unit 2 12Year Preventative Maintenance Replace Starting

Air Motor FLEX Hoses on Station Blackout

06/26/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.12

Work Orders

1638572

Unit 2 8Year Preventative Maintenance Calibration Station

Blackout Immersion Heater Temperature Switch 26620-

119B

06/27/2023

71111.12

Work Orders

21931

Electrical Maintenance 2Year Preventative Maintenance

Station Blackout Diesel Generator Electrical Inspection

06/29/2023

71111.12

Work Orders

26475

EWP Unit 2 2Year Preventative Maintenance Station

Blackout Diesel Generator Mechanical Maintenance

Inspection

06/29/2023

71111.12

Work Orders

5181428

Unexpected Alarm 9033 C3, Isolation Condenser Vent

Monitor Downscale

2/14/2021

71111.12

Work Orders

276782

IMD TSR 2B RBV Vent Rad Monitor

07/16/2022

71111.12

Work Orders

5371795

Rework, EWP Replace 3B RBV Stack Sample Pump

71111.12

Work Orders

5372150

TS&R U2 IC Vent Rad Monitor Nuisance Alarms

06/05/2023

71111.13

Corrective Action

Documents

4697778

U2 Circ Water Pump Bearing Temperatures

08/22/2023

71111.13

Corrective Action

Documents

4698205

U3 Circ Water Pump Motor Bearing Temps Peaking Above

PPC Setpoint

08/24/2023

71111.13

Corrective Action

Documents

4698424

Unexpected Alarm 9232 C2, TR81 TR83 TR86 Major

08/24/2023

71111.13

Miscellaneous

Workweek Highlights - DRESDEN Station Week of 0821-

08/25/2023

71111.13

Miscellaneous

Augmented Operator Round Points

08/23/2023

71111.13

Miscellaneous

DAN 902(3)-6 E9

RFP Vent Exhaust Air Temp Hi

71111.13

Miscellaneous

DAN 9322 C2

TR81 TR83 TR86 Major

71111.13

Procedures

OPDR108111-

1001

Hot Weather Strategy

71111.13

Procedures

OPDR108111-

1006

Intake Blockage Station Response

71111.15

Corrective Action

Documents

4535439

HPCI Check Valve 32301-7 Will Not Open < 90 ft/lbs.

Torque

11/08/2022

71111.15

Corrective Action

Documents

4688851

39400-121/5 U3 Battery Room A/C Compressor & Fan

Breaker Tripped

07/05/2023

71111.15

Corrective Action

4694915

FLEX Hose Trailer 3 Not Tied Down

08/06/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

71111.15

Corrective Action

Documents

4696111

Impairment Closed Out Improperly

08/12/2023

71111.15

Corrective Action

Documents

Resulting from

Inspection

4694745

Time Critical Action 16 Paperwork Error

71111.15

Corrective Action

Documents

Resulting from

Inspection

4699214

NRC Questions on CCDR118

08/29/2023

71111.15

Engineering

Evaluations

350673

Effects of Elevated Temperatures on Unit 3 Station

Batteries

71111.15

Procedures

660006

Powering Unit 3 4 Kilovolt Buses Via the Station Blackout

Diesel Generator 3

71111.15

Procedures

CCAA211

Fire Protection Program

71111.15

Procedures

CCDR118

Site Implementation of Diverse and Flexible Coping

Strategies (FLEX), Spent Fuel Pool Instrumentation (SFPI),

and Hardened Containment Vent System (HCVS) Program

71111.15

Procedures

DGA12

Loss of Offsite Power

71111.15

Procedures

DOP 660005

Powering Unit 2 4 Kilovolt Buses Via the Station Blackout

Diesel Generator 2

71111.15

Procedures

DOS 001047

Operations Monthly FLEX Inspections

71111.15

Procedures

DOS 230004

HPCI Testable Check Valve Manual Full Stroke Operability

Test

71111.15

Procedures

OPAA102106

Operator Response Time Validation Sheet

71111.15

Procedures

OPAA108101

Abnormal Component Position Sheet (ACPS)

71111.15

Procedures

OPAA201007

Fire Protection System Impairment Control

71111.15

Work Orders

5096300

QTR/CSD IST HPCI Test Injection Check Valve Operability

Test Surveillance

11/07/2022

71111.15

Work Orders

530804007

OP PMT Perform as Left Seat Leak Test Per DOS 710006

11/13/2022

71111.15

Work Orders

530804008

OP PMT IST HPCI Test Injection Check Valve

230-7 Full Stroke

11/13/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.18

Engineering

Changes

638300

Temporary Aux Oil Reservoir with Remote Oil Fill for 3B

Reactor Recirculating Pump Motor Lower Bearing

71111.18

Engineering

Changes

638300

Temporary Aux Oil Reservoir with Remote Oil Fill for 3B

Reactor Recirculating Pump Motor Lower Bearing

71111.18

Engineering

Changes

638300

Temporary Aux Oil Reservoir with Remote Oil Fill for 3B

Reactor Recirculating Pump Motor Lower Bearing

71111.18

Engineering

Changes

639377

Temporary Force Unit 2 DEHC Logic Point for Axial Position

Probe

71111.18

Procedures

CCAA112F-03

Temporary Configuration Change (TCC) Installation and

Removal Authorizations

71111.18

Procedures

LSAA104

Exelon 50.59 Review Process

71111.24

Corrective Action

Documents

4689928

U3 SBO Would Not Synchronize to Bus 33

07/11/2023

71111.24

Corrective Action

Documents

4698273

Unexpected Alarm: 9034 G24 Fuel Pool PP Trip

08/24/2023

71111.24

Corrective Action

Documents

4698754

4.0 Critique for 3B Fuel Pool Cooling Pump Trip on 8/24/23

08/27/2023

71111.24

Corrective Action

Documents

Resulting from

Inspection

4689636

NRC Question: 2/3 Emergency Diesel Generator Cooling

Water Pump InService Testing Work Order 5354595

07/10/2023

71111.24

Corrective Action

Documents

Resulting from

Inspection

4690019

NRC ID: Documentation for DOS 660008 Incomplete

07/12/2023

71111.24

Procedures

DOS 662007

SBO Unit 2 (3) Diesel Generator Surveillance Tests

71111.24

Work Orders

538248501

EM EWP Breaker Swap Cubicle 3 at Bus 71 (Feed to Bus

33)

07/21/2023

71111.24

Work Orders

5391951

U2 EDG Control Switch Contacts Need to be Burnished

08/28/2023

71111.24

Work Orders

5394386

IMD replace 31901-108B (3B Fuel Pool Cooling Pump

Suction)

08/25/2023

71124.08

Corrective Action

Documents

Resulting from

AR 04691430

NRC ID: Inaccurate Frisking Instructions

07/19/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Inspection

71124.08

Corrective Action

Documents

Resulting from

Inspection

AR 04691476

NRC Identified: Frisker Probe Found Broken

07/19/2023

71124.08

Miscellaneous

Dresden Generating Station Part 37 Security Plan for the

Protection of Category 1 and Category 2 Quantities of

Radioactive Material

71124.08

Miscellaneous

DRE23001

Leak Test Exemption for Ni63 Sources Used in Explosive

Monitors at Dresden

08/07/2023

71124.08

Miscellaneous

MA001122

Entry Scan 4 User Manual

71124.08

Miscellaneous

MA001153

Itemiser3 Enhanced User Manual

71124.08

Miscellaneous

N-AN-

RP10CFR37CBT

Exelon 10 CFR Part 37, Physical Protection of

Category 1 and Category 2 Quantities of Radioactive

Material

71124.08

Miscellaneous

TBE Sample ID

L955087

Waste Stream Review and Scaling Factor

Report - ALPS Cation Resin

07/21/2021

71124.08

Miscellaneous

TBE Sample ID

L955081

Waste Stream Review and Scaling Factor Report - DAW

Smears

11/19/2021

71124.08

Miscellaneous

TBE Sample ID

L955083

Waste Stream Review and Scaling Factor

Report - Fuel Pool Resin

10/04/2021

71124.08

Miscellaneous

TBE Sample ID

L955086

Waste Stream Review and Scaling Factor

Report - ALPS Anion Resin

01/11/2022

71124.08

Procedures

RPAA700

Controls for Radiation Protection Instrumentation

71124.08

Procedures

RPAA800

Control, Inventory, and Leak Testing of Radioactive Sources

71124.08

Self-Assessments AR 46722302

Radioactive Solid Waste Processing and Radioactive

Material Handling, Storage, and Transportation

06/30/2023

71124.08

Shipping Records

DAW23020

Shipping Papers; ALPS Resin

06/06/2023

71124.08

Shipping Records

DW22010

Shipping Papers; Fuel Pool Cleanup Resin

06/21/2022

71124.08

Shipping Records

DW22020

Shipping Papers; RWCU Resin

08/04/2022

71124.08

Shipping Records

DW23001

Shipping Papers; DAW Trash

2/16/2023

71124.08

Work Orders

Work Order 05331539

Quarterly Radwaste Facility Container Inspection

05/02/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71151

Miscellaneous

MSPI Heat Removal Systems Prepared Data Package

07/01/2023-

06/30/2023

71151

Miscellaneous

MSPI Residual Heat Removal Systems Prepared Data

Package

07/01/2023-

06/30/2023

71151

Miscellaneous

MSPI Cooling Water Systems Prepared Data Package

07/01/2023-

06/30/2023

71151

Miscellaneous

LSAA2090

Monthly Data Elements for NRC ROP Indicator - RCS

Specific Activity

various

71151

Miscellaneous

LSAA2150

Monthly Data Elements for NRC ROP

Indicator - RETS/ODCM Radiological Effluent Occurrences

various

71151

Procedures

ERAA2002

System and Equipment Health Monitoring

71151

Procedures

ERAA2008

Mitigating Systems Performance Index (MSPI) Monitoring

and Margin Evaluation

71151

Procedures

LSAA2200

Mitigating System Performance Index Data Acquisition and

Reporting

71152A

Corrective Action

Documents

4332151

Strengthen Procedures Involving Torquing

04/02/2020

71152A

Corrective Action

Documents

4360154

Procedure Revisions Required - Corporate Torque High

Intensity Team Actions

07/31/2020

71152A

Corrective Action

Documents

4551179

2/3 EDG Output Breaker Trip

01/30/2023

71152A

Corrective Action

Documents

4688989

U2 125VDC Alt Battery Feed Circuit Breakers,

SR Components Required

07/06/2023

71152A

Corrective Action

Documents

4691063

U2 Extent of Condition Review from IR 4551179

07/17/2023

71152A

Corrective Action

Documents

4691067

U3 Extent of Condition Review from IR 4551179

07/17/2023

71152A

Corrective Action

Documents

4692803

U2 SBO Banana Jack Extent of Condition Walkdown

07/26/2023

71152A

Corrective Action

Documents

4692804

U3 SBO Banana Jack Extent of Condition Walkdown

07/26/2023

71152A

Corrective Action

Documents

4701304

Low Resistance Readings During Breaker Inspection

09/08/2023

71152A

Corrective Action

PIAA120

Issue Identification and Screening Process

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

71152A

Corrective Action

Documents

Resulting from

Inspection

4687009

NRC Question: 2/3 EDG Banana Jacks

06/27/2023

71152A

Engineering

Changes

387004

Add Safety Classification for U2 125 VDC Alt Batt/Chgr to

Bus Breaker

(EPN 283125-5AC1, Component S35)

04/30/2013

71152A

Miscellaneous

NOAA10

Quality Assurance Topical Report (QATR)

71152A

Procedures

CCAA304

Component Classification

71152A

Procedures

DIP 210028

Banana Jack Installation

71152A

Procedures

DIP 210028

Banana Jack Installation

71152A

Procedures

PIAA125

Corrective Action Program (CAP) Procedure

71152A

Work Orders

1785276

D2 4Y TSNC 125V Sta Main Batt Modified Performance

Test

09/09/2019

71152A

Work Orders

4665278

D2/3 10 Year EDG Time Delay Relay (TDR3) Replacement

03/28/2019

71152A

Work Orders

509970

Replace Breaker for 125VDC Alt Chgr

03/25/2004

71152A

Work Orders

5387993

U2 SBO Banana Jack Extent of Condition Walkdown

08/09/2023

71152A

Work Orders

5387995

U3 SBO Banana Jack Extent of Condition Walkdown

08/09/2023

71152A

Work Orders

774334

D2 16Y Breaker Overhaul 125 Alt Tie Bkr

07/19/2006

71152A

Work Orders

N-C0057

Torque Requirements

2