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

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. 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 Report Aspect Section Occupational Green [H.11] - 71124.08 Radiation Safety NCV 05000237,05000249/202300301 Challenge the Open/Closed Unknown 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 Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000237,05000249/202300302 Open/Closed 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 71124.08 Closed EA23087: Failure to Comply with 10 CFR Part 37

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) (2 Samples)

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 Report Aspect Section Occupational Green [H.11] - 71124.08 Radiation Safety NCV 05000237,05000249/202300301 Challenge the Open/Closed Unknown 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 Enforcement Action EA23087: 71124.08 Discretion Failure to Comply with 10 CFR Part 37

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 Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000237,05000249/202300302 Open/Closed 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 Type Designation Description or Title Revision or

Procedure 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 15

Cooling Service Water Electrical Checklist

71111.04 Procedures DOP 1500M1 Unit 2 Low Pressure Coolant Injection and Containment 50

Cooling Valve Checklist

71111.04 Procedures DOP 2300M1/E1 Unit 2 High Pressure Coolant Injection System Checklist 40

71111.04 Procedures DOP 3700M2/E2 Unit 3 RBCCW System Checklist 20

71111.04 Procedures DOP 3900E1 Unit 2(3) Service Water and Screen Wash System Electrical 14

Checklist

71111.04 Procedures DOP 3900M1 Unit 2/3 Service Water and Screen Wash Valve Checklist 64

71111.04 Procedures DOP 3900M2 Unit 2 Emergency Room Coolers Valve Checklist 9

71111.05 Corrective Action 4698552 4.0 Critique Crew 5 Q3 Announced Fire Drill 08/25/2023

Documents

71111.05 Fire Plans 100 Prefire Plan Dresden Generating Station Pre-Fire Plan 3

Master Legend

71111.05 Fire Plans 101 U2RB1 Unit 2 Torus Basement Elevation 476' and Torus Catwalk 4

71111.05 Fire Plans 103 U2RB3 Unit 2 Southeast Corner Room Elev. 476' 4

71111.05 Fire Plans 120 U3RB23 FZ 1.1.1.2 Unit 3 Rx Ground Floor Elev. 517' 5

71111.05 Fire Plans 124 U3RB26 FZ 1.1.1.3 Unit 3 General Area Elev. 545' 6

71111.05 Fire Plans 133 U2TB36 FZ 8.2.1A Unit 2 Condensate Pumps Elev. 469' 3

71111.05 Fire Plans 151 U2TB53 Unit 2 Battery Room Elev. 549' 5

71111.05 Fire Plans 157 U3TB68 FZ 8.2.1B Unit 3 Condensate Pumps Elev. 469' 4

71111.05 Fire Plans 196 Circ PPs-124 FZ 11.3 Unit 2/3 Circulating Water Pumps Elev. 490' 2

71111.05 Fire Plans 197 SW PPs-125 FZ 11.3 Unit 2/3 Service Water Pumps / Traveling Screens 3

Elev. 509'

71111.05 Fire Plans 198 U2/3 CH126 FZ 11.3 Unit 2/3 Crib House Ground Floor Elev. 517' 3

71111.05 Miscellaneous Fire Drill Scenario Diesel Generator Fire (IEMA Building) 08/10/2023

204

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Procedures 118 U3RB21 FZ 11.1.2 Unit 3 Southeast Corner Room Elevation 476' 3

71111.05 Procedures 119 U3RB22 FZ 11.1.3 Unit 3 High Pressure Coolant Injection Pump 6

Room Elevation 476'

71111.06 Engineering 390874 4KV Switchgear Internal Flood Barrier Protection Risk 0

Changes Insight - Enhancement Dash Buses 331 and 341

71111.06 Engineering 393162 4KV Switchgear Internal Flood Barrier Protection Risk 0

Changes Insight - Enhancement Dash Buses 231 and 241

71111.06 Miscellaneous DRPSA012 Dresden Internal Flood Evaluation Summary and Notebook 05

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 07/05/2023

ID: D228019

71111.11Q Procedures ReMA Plan D2C28 End of Cycle Rod Pull - 9D and 9B Array 07/03/2023

D228019

71111.12 Corrective Action 4442021 Unexpected Alarm 9033 C3, Isolation Condenser Vent 08/22/2021

Documents Monitor Downscale

71111.12 Corrective Action 4551062 Unexpected Alarm 9023 B3 Isolation Condenser Vent Rad 01/29/2023

Documents Hi

71111.12 Corrective Action 4676867 Unexpected Alarm 9033 F1 Area Rod Monitor Downscale 05/09/2023

Documents

71111.12 Corrective Action 4678267 Unexpected Alarm 9033 F1 Area Rad Monitor Downscale 05/15/2023

Documents

71111.12 Corrective Action 4681722 MCR Nuisance Alarm: 9023 B3 Isolation Condenser Vent 05/31/2023

Documents Rad HI

71111.12 Miscellaneous Radiation Monitor System Health Report

71111.12 Miscellaneous WR 1540455 TS&R 31803-30, ARM 30 Off Gas Filter Building Spurious 05/15/2023

Alarms

71111.12 Procedures DIS 130004 Isolation Condenser Vent Radiation Monitor Functional 31

Calibration and Operational Checks

71111.12 Work Orders 1233135 EWP Mechanical Maintenance 12 Year Preventative 06/26/2023

Maintenance 2B Station Blackout Diesel Generator,

Replace Air Start FLEX Hoses

71111.12 Work Orders 1233234 Unit 2 12Year Preventative Maintenance Replace Starting 06/26/2023

Air Motor FLEX Hoses on Station Blackout

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Work Orders 1638572 Unit 2 8Year Preventative Maintenance Calibration Station 06/27/2023

Blackout Immersion Heater Temperature Switch 26620-

119B

71111.12 Work Orders 5121931 Electrical Maintenance 2Year Preventative Maintenance 06/29/2023

Station Blackout Diesel Generator Electrical Inspection

71111.12 Work Orders 5126475 EWP Unit 2 2Year Preventative Maintenance Station 06/29/2023

Blackout Diesel Generator Mechanical Maintenance

Inspection

71111.12 Work Orders 5181428 Unexpected Alarm 9033 C3, Isolation Condenser Vent 12/14/2021

Monitor Downscale

71111.12 Work Orders 5276782 IMD TSR 2B RBV Vent Rad Monitor 07/16/2022

71111.12 Work Orders 5371795 Rework, EWP Replace 3B RBV Stack Sample Pump 0

71111.12 Work Orders 5372150 TS&R U2 IC Vent Rad Monitor Nuisance Alarms 06/05/2023

71111.13 Corrective Action 4697778 U2 Circ Water Pump Bearing Temperatures 08/22/2023

Documents

71111.13 Corrective Action 4698205 U3 Circ Water Pump Motor Bearing Temps Peaking Above 08/24/2023

Documents PPC Setpoint

71111.13 Corrective Action 4698424 Unexpected Alarm 9232 C2, TR81 TR83 TR86 Major 08/24/2023

Documents

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 15

71111.13 Miscellaneous DAN 9322 C2 TR81 TR83 TR86 Major 21

71111.13 Procedures OPDR108111-Hot Weather Strategy 7

1001

71111.13 Procedures OPDR108111-Intake Blockage Station Response 0

1006

71111.15 Corrective Action 4535439 HPCI Check Valve 32301-7 Will Not Open < 90 ft/lbs. 11/08/2022

Documents Torque

71111.15 Corrective Action 4688851 39400-121/5 U3 Battery Room A/C Compressor & Fan 07/05/2023

Documents Breaker Tripped

71111.15 Corrective Action 4694915 FLEX Hose Trailer 3 Not Tied Down 08/06/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

71111.15 Corrective Action 4696111 Impairment Closed Out Improperly 08/12/2023

Documents

71111.15 Corrective Action 4694745 Time Critical Action 16 Paperwork Error

Documents

Resulting from

Inspection

71111.15 Corrective Action 4699214 NRC Questions on CCDR118 08/29/2023

Documents

Resulting from

Inspection

71111.15 Engineering 350673 Effects of Elevated Temperatures on Unit 3 Station 7

Evaluations Batteries

71111.15 Procedures 660006 Powering Unit 3 4 Kilovolt Buses Via the Station Blackout 24

Diesel Generator 3

71111.15 Procedures CCAA211 Fire Protection Program 9

71111.15 Procedures CCDR118 Site Implementation of Diverse and Flexible Coping 8

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

and Hardened Containment Vent System (HCVS) Program

71111.15 Procedures DGA12 Loss of Offsite Power 80

71111.15 Procedures DOP 660005 Powering Unit 2 4 Kilovolt Buses Via the Station Blackout 19

Diesel Generator 2

71111.15 Procedures DOS 001047 Operations Monthly FLEX Inspections 12

71111.15 Procedures DOS 230004 HPCI Testable Check Valve Manual Full Stroke Operability 15

Test

71111.15 Procedures OPAA102106 Operator Response Time Validation Sheet 5

71111.15 Procedures OPAA108101 Abnormal Component Position Sheet (ACPS) 18

71111.15 Procedures OPAA201007 Fire Protection System Impairment Control 2

71111.15 Work Orders 5096300 QTR/CSD IST HPCI Test Injection Check Valve Operability 11/07/2022

Test Surveillance

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 11/13/2022

230-7 Full Stroke

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Engineering 638300 Temporary Aux Oil Reservoir with Remote Oil Fill for 3B 0

Changes Reactor Recirculating Pump Motor Lower Bearing

71111.18 Engineering 638300 Temporary Aux Oil Reservoir with Remote Oil Fill for 3B 3

Changes Reactor Recirculating Pump Motor Lower Bearing

71111.18 Engineering 638300 Temporary Aux Oil Reservoir with Remote Oil Fill for 3B 4

Changes Reactor Recirculating Pump Motor Lower Bearing

71111.18 Engineering 639377 Temporary Force Unit 2 DEHC Logic Point for Axial Position 0

Changes 1 Probe

71111.18 Procedures CCAA112F-03 Temporary Configuration Change (TCC) Installation and 2

Removal Authorizations

71111.18 Procedures LSAA104 Exelon 50.59 Review Process 12

71111.24 Corrective Action 4689928 U3 SBO Would Not Synchronize to Bus 33 07/11/2023

Documents

71111.24 Corrective Action 4698273 Unexpected Alarm: 9034 G24 Fuel Pool PP Trip 08/24/2023

Documents

71111.24 Corrective Action 4698754 4.0 Critique for 3B Fuel Pool Cooling Pump Trip on 8/24/2308/27/2023

Documents

71111.24 Corrective Action 4689636 NRC Question: 2/3 Emergency Diesel Generator Cooling 07/10/2023

Documents Water Pump InService Testing Work Order 5354595

Resulting from

Inspection

71111.24 Corrective Action 4690019 NRC ID: Documentation for DOS 660008 Incomplete 07/12/2023

Documents

Resulting from

Inspection

71111.24 Procedures DOS 662007 SBO Unit 2 (3) Diesel Generator Surveillance Tests 49

71111.24 Work Orders 538248501 EM EWP Breaker Swap Cubicle 3 at Bus 71 (Feed to Bus 07/21/2023

33)

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 08/25/2023

Suction)

71124.08 Corrective Action AR 04691430 NRC ID: Inaccurate Frisking Instructions 07/19/2023

Documents

Resulting from

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

71124.08 Corrective Action AR 04691476 NRC Identified: Frisker Probe Found Broken 07/19/2023

Documents

Resulting from

Inspection

71124.08 Miscellaneous Dresden Generating Station Part 37 Security Plan for the 4

Protection of Category 1 and Category 2 Quantities of

Radioactive Material

71124.08 Miscellaneous DRE23001 Leak Test Exemption for Ni63 Sources Used in Explosive 08/07/2023

Monitors at Dresden

71124.08 Miscellaneous MA001122 Entry Scan 4 User Manual 4

71124.08 Miscellaneous MA001153 Itemiser3 Enhanced User Manual 2

71124.08 Miscellaneous N-AN-Exelon 10 CFR Part 37, Physical Protection of 0

RP10CFR37CBT Category 1 and Category 2 Quantities of Radioactive

Material

71124.08 Miscellaneous TBE Sample ID Waste Stream Review and Scaling Factor 07/21/2021

L955087 Report - ALPS Cation Resin

71124.08 Miscellaneous TBE Sample ID Waste Stream Review and Scaling Factor Report - DAW 11/19/2021

L955081 Smears

71124.08 Miscellaneous TBE Sample ID Waste Stream Review and Scaling Factor 10/04/2021

L955083 Report - Fuel Pool Resin

71124.08 Miscellaneous TBE Sample ID Waste Stream Review and Scaling Factor 01/11/2022

L955086 Report - ALPS Anion Resin

71124.08 Procedures RPAA700 Controls for Radiation Protection Instrumentation 09

71124.08 Procedures RPAA800 Control, Inventory, and Leak Testing of Radioactive Sources10

71124.08 Self-Assessments AR 46722302 Radioactive Solid Waste Processing and Radioactive 06/30/2023

Material Handling, Storage, and Transportation

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 02/16/2023

71124.08 Work Orders Work Order Quarterly Radwaste Facility Container Inspection 05/02/2023

05331539

Inspection Type Designation Description or Title Revision or

Procedure 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 07/01/2023-

Package 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 various

Specific Activity

71151 Miscellaneous LSAA2150 Monthly Data Elements for NRC ROP various

Indicator - RETS/ODCM Radiological Effluent Occurrences

71151 Procedures ERAA2002 System and Equipment Health Monitoring 24

71151 Procedures ERAA2008 Mitigating Systems Performance Index (MSPI) Monitoring 4

and Margin Evaluation

71151 Procedures LSAA2200 Mitigating System Performance Index Data Acquisition and 7

Reporting

71152A Corrective Action 4332151 Strengthen Procedures Involving Torquing 04/02/2020

Documents

71152A Corrective Action 4360154 Procedure Revisions Required - Corporate Torque High 07/31/2020

Documents Intensity Team Actions

71152A Corrective Action 4551179 2/3 EDG Output Breaker Trip 01/30/2023

Documents

71152A Corrective Action 4688989 U2 125VDC Alt Battery Feed Circuit Breakers, 07/06/2023

Documents SR Components Required

71152A Corrective Action 4691063 U2 Extent of Condition Review from IR 4551179 07/17/2023

Documents

71152A Corrective Action 4691067 U3 Extent of Condition Review from IR 4551179 07/17/2023

Documents

71152A Corrective Action 4692803 U2 SBO Banana Jack Extent of Condition Walkdown 07/26/2023

Documents

71152A Corrective Action 4692804 U3 SBO Banana Jack Extent of Condition Walkdown 07/26/2023

Documents

71152A Corrective Action 4701304 Low Resistance Readings During Breaker Inspection 09/08/2023

Documents

71152A Corrective Action PIAA120 Issue Identification and Screening Process 10

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

71152A Corrective Action 4687009 NRC Question: 2/3 EDG Banana Jacks 06/27/2023

Documents

Resulting from

Inspection

71152A Engineering 387004 Add Safety Classification for U2 125 VDC Alt Batt/Chgr to 04/30/2013

Changes Bus Breaker

(EPN 283125-5AC1, Component S35)

71152A Miscellaneous NOAA10 Quality Assurance Topical Report (QATR) 98

71152A Procedures CCAA304 Component Classification 6

71152A Procedures DIP 210028 Banana Jack Installation 15

71152A Procedures DIP 210028 Banana Jack Installation 16

71152A Procedures PIAA125 Corrective Action Program (CAP) Procedure 8

71152A Work Orders 1785276 D2 4Y TSNC 125V Sta Main Batt Modified Performance 09/09/2019

Test

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

23