IR 05000249/2010010

IR 05000249-10-010, on 10/18/2010 - 11/19/2010, Dresden Nuclear Power Station, Unit 3, Post Approval Site Inspection for License Renewal

ML103560677
Person / Time
Site:	Dresden
Issue date:	12/22/2010
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-10-010
Download: ML103560677 (44)

Text

ber 22, 2010

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNIT 3 NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000249/2010010

Dear Mr. Pacilio:

On November 19, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed Post-Approval Site Inspection for License Renewal at your Dresden Nuclear Power Station, Unit 3.

The enclosed report documents the results of this inspection, which were discussed on November 19, 2010, with Mr. T. Hanley, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of this NCV, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Dresden Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this Inspection Report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Dresden Nuclear Power Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-249 License Nos. DPR-25

Enclosure:

Inspection Report 05000249/2010-010 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 05000249 License Nos: DPR-25 Report No: 05000249/2010-010 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Unit 3 Location: Morris, IL Dates: October 18, 2010 - November 19, 2010 Inspectors: S. Sheldon, Senior Reactor Engineer (Lead)

T. Bilik, Senior Reactor Engineer G. ODwyer, Reactor Engineer M. Jones, Reactor Engineer E. Sanchez, Reactor Engineer Approved by: A. M. Stone, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000249/2010010; 10/18/2010 - 11/19/2010; Dresden Nuclear Power Station, Unit 3;

Post-Approval Site Inspection for License Renewal.

The report covers a team inspection conducted by region-based engineering inspectors. The inspectors concluded that commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license were being met. One Green finding was identified by the inspectors. The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Barrier Integrity

Green.

A finding of very low safety-significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the failure to accomplish activities affecting quality in accordance with procedures. Specifically, the licensee non-destructive examination (NDE) examiner failed to perform an Ultrasound Thickness Measurement of the drywell liner in accordance with procedures. The licensee initiated corrective action document AR 01141740 to address the issue.

The finding was determined to be more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically by failing to perform an adequate Ultrasound Thickness Measurement of the drywell liner potential degradation could have gone undetected. This finding is of very low safety-significance (Green) because the inspectors answered no to all of the characterizations worksheet questions in Table 4a of MC 0609.04. The inspectors determined this finding had no associated cross-cutting aspect because none of them represented the underlying cause for this violation to occur. (Section 4OA5.1)

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA5 Other Activities

.1 Post-Approval Site Inspection for License Renewal (Phases I and II) - IP 71003

The purpose of this inspection is to verify that committed actions and license conditions associated with the renewed license for Unit 3 are implemented in accordance with 10 CFR Part 54. Inspection Report 05000237/2009007 (ADAMS ascension number ML093570258) documented the inspectors review of the licensees actions associated with the renewed Unit 2 license. Because several of these actions involve common programs, the Unit 2 report is referenced where appropriate.

a. Inspection Scope

(1) Review of Newly Identified SSCs The inspectors discussed the identification of new systems structures and components, under the purview of 10 CFR 54.37(b), with the licensees license renewal staff. The licensee personnel indicated that no components had been identified that should have been within the scope of its license renewal program due to discovering components in the plant that were not accurately reflected in the database used to originally generate the application for a renewed license. The inspectors did not identify any deficiencies.

The inspectors contacted the Office of Nuclear Reactor Regulation, Division of License Renewal (NRR/DLR) staff for information on any generic NRC communications naming newly identified systems, structures, and components. The Office of Nuclear Reactor Regulation Division of License Renewal NRR/DLR staff advised the inspectors that the NRC has not generically specified newly identified systems, structures, and components beyond those referenced in Regulatory Issue Summary RIS 2007-16, Revision 1. The SSCs referenced in RIS 2007-16 were reviewed as part of Dresdens application.

(2) Review of Updated Final Safety Analysis Report (UFSAR) and Commitment Item Change Process As part of reviewing the Aging Management Programs (AMPs) associated with the commitments, the inspectors reviewed the UFSAR descriptions to confirm the implemented programs were consistent with the UFSAR descriptions. Some minor disparities were noted in programs that had been implemented where the UFSAR said they would be implemented. The licensee initiated AR 01131093 to update the UFSAR.

The inspectors reviewed the licensees procedures to ensure that Commitment Item revisions would follow the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Item Changes, including the elimination of commitments, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59. The inspectors also reviewed the licensees Commitment Item tracking program to evaluate its effectiveness.

With respect to implementation, the inspectors reviewed changes associated with each commitment. No disparities were identified as detailed below.

(3) Review of Commitments The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, performed visual inspection of structures and components including those not accessible during power operation, and observed the activities described below to verify the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license.

The inspectors verified the licensee implemented the Aging Management Programs and time-limited aging analyses (TLAA) included in NUREG-1796, Safety Evaluation Report (SER) Related to the License Renewal of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2, in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors verified a selected sample of corrective actions taken to address issues identified in the Unit 2 license renewal inspection, which is documented in Inspection Report 05000237/2009007.

When changes to these commitments were identified, the inspectors reviewed the Commitment Item Change Evaluation Form (CCEF) to verify the licensee followed the guidance in NEI 99-04 for the license renewal Commitment Item change process, including the elimination of commitments, and properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.

The inspectors reviewed the commitments listed below which are referenced to Appendix A of the SER. Specific documents reviewed are listed in the enclosure.

1. Item 1, ASME Code,Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Commitment Item 1 specified that the existing ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Aging Management Program is part of the Inservice Inspection (ISI) Program. It provides identification of signs of degradation, and establishment of corrective actions for condition monitoring of reactor coolant pressure retaining piping and components within the scope of license renewal.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, non-destructive examination (NDE) records, and related condition reports (CRs); and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 1.

2. Item 2, Water Chemistry Commitment Item 2 specified that the existing water chemistry program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 licensing renewal inspection and ensured that the program remained effective for both units. The inspectors verified that planned and completed chemistry surveillance tests and related CRs demonstrated that the water chemistry program was appropriately applied to Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 2.

3. Item 3, Reactor Head Closure Studs

Commitment Item 3 specified that the existing Reactor Head Closure Studs Aging Management Program provided for condition monitoring and preventive activities to manage stud cracking. The program is implemented through station procedures based on the examination and inspection requirements specified in ASME Section XI, Table IWB-2500-1 and preventive measures described in Regulatory Guide 1.65, "Materials and Inspection for Reactor Vessel Closure Studs." The reactor head studs at Dresden are not metal plated and have had manganese phosphate coatings applied.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors interviewed the plant personnel responsible for the program and reviewed the program bases documents, implementing procedures, work orders, and related ARs to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 3.

4. Item 4, BWR Vessel ID Attachment Welds

Commitment Item 4 specified that the existing BWR Vessel Attachment Welds Aging Management Program activities incorporated the inspection and evaluation recommendations of BWRVIP-48, 'Vessel 10 Attachment Weld Inspection and Evaluation Guidelines," as well as the water chemistry recommendations of EPRI TR-103515-R2, "BWR Water Chemistry Guidelines."

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records, and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3. The inspectors verified the implementation of the recommendations of report GE-NE-523-A71-0594-A, Revision 1, which was approved by the NRC staff.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 4.

5. Item 5, BWR Feedwater Nozzle

Commitments Item 5 specified that the existing BWR Feedwater Nozzle program was credited for license renewal and would be enhanced prior to the period of extended operation. This program implemented enhanced inservice inspection in accordance with the ASME Code for the feed water nozzles.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records, and related CRs; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3. The inspectors verified that the licensee implement the recommendations of report GE-NE-523-A71-0594-A, Revision 1, which was approved by the NRC staff.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 5.

6. Item 6, Control Rod Drive Return Line Nozzle

Commitment Item 6 specified that the existing BWR Control Rod Drive Return Line Nozzle inspection program was credited for license renewal. This program implemented enhanced inservice inspection in accordance with the ASME Code for the control rod drive return line nozzles.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis documents, procedures, and NDE examination records to verify that the program was adequately implemented for Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 6.

7. Item 7, BWR Stress Corrosion Cracking (SCC)

Commitment Item 7 specified that the existing BWR SCC Program was credited for license renewal. The BWR SCC Program is credited for managing the aging affects of crack initiation and growth, loss of fracture toughness, and loss of material in susceptible components.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, implementing procedures, weld examination records, and related ARs; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 7.

8. Item 8, BWR Penetrations

Commitment Item 8 specified that the existing BWR reactor vessel penetration inspection program was credited for license renewal. This program implemented inspection and flaw evaluation in conformance with BWRVIP-27 and BWRVIP-49.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis documents, procedures, and NDE examination records to verify that the program was adequately implemented for Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 8.

9. Item 9, BWR Vessel Internals

Commitment Item 9 specified that the ASME inservice inspection program inspections would be enhanced with inspections consistent with BWRVIP-48. The BWR Vessel internals Aging Management Program mitigates the effect of stress corrosion cracking, intergranular stress corrosion cracking (IGSCC), and irradiation assisted stress corrosion cracking in reactor pressure vessels internals through water chemistry activities that are implemented through station procedures and are consistent with the guidelines of EPRI TR-103515-R2, BWR Water Chemistry Guidelines, 2000 Revision. The program also manages cracking of reactor of reactor pressure vessel internals through condition monitoring activities that consist of examinations and the BWRVIP guidelines, as well as the requirements of ASME Section XI. The program has also been enhanced by NRC approved BWRVIP Steam Dryer Inspection and Evaluation Guidelines.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3.

The licensee implemented Commitment Item change to update the scope this program to reflect the use of EPRI 1016579, BWR Water Chemistry Guidelines, and BWRVIP-190, BWR water Vessel and Internals Project, BWR Water Chemistry Guidelines 2008 Revision, EPRI Report 1016579 instead of EPRI TR-103515-R2, BWR Water Chemistry Guidelines, 2000 Revision.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 9.

10. Item 10, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

Commitment Item 10 specified that a new Aging Management Program was to be implemented for thermal aging and neutron irradiation embrittlement of CASS reactor internal components within the scope of license renewal, to ensure the integrity of the CASS components exposed to the high temperature and neutron fluence present in the reactor environment. This program includes a specific evaluation of the loss of fracture toughness. For those components where the loss of fracture toughness may affect function of the component, an enhanced VT-1 inspection will be conducted for those components where flaws have been detected. These inspections will be in accordance with BWRVIP-03, and will be performed as part of the ISI program.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures, and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 10.

11. Item 11, Flow Accelerated Corrosion (FAC)

Commitment Item 11 specified that the existing FAC Program was credited for license renewal with enhancements to include portions of the main steam and the reactor vessel head vent systems prior to the period of extended operation. The FAC Program is credited for predicting, detecting, and monitoring for loss of material by wall thinning in piping, fittings, and valve bodies due to FAC.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, implementing procedures, pipe examination records, and related ARs; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 11.

12. Item 12, Bolting Integrity Commitment Item 12 specified that the existing bolting integrity program was credited for license renewal and that the program would be enhanced prior to the period of extended operation. The Bolting Integrity Program was an existing program that consisted of the preventive and condition monitoring of pressure retaining bolted joints for piping and components for age-related degradation to discover and correct conditions that could lead to a loss of intended function.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors reviewed the licensing basis, the Bolting Integrity Program basis documentation, implementing procedures, planned, and completed work orders for Unit 3, related corrective action documents, and interviewed personnel responsible for the program regarding these documents to verify that the program was adequately implemented for Unit 3. The inspectors reviewed records of the isolation condenser shell to tube bundle flange VT-3 inspection. No issues were identified.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 12.

13. Item 13, Open-Cycle Cooling Water Program Commitment Item 13 specified that the existing open-cycle cooling program was credited for license renewal and that the program would be enhanced, prior to the period of extended operation, to include periodic inspections of additional heat exchangers and sub-components, external surfaces of various submerged pumps, components in the high humidity/moisture environments of the pump vaults and piping, and strainer internals in the component cooling service water (CCSW) supply line to the main control room heating, ventilation and air conditioning (HVAC) system.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, planned and completed work orders, Issue Reports, and inspection procedures to verify the program is being implemented on Unit 3. The inspectors observed eddy current testing on the 3B Low Pressure Coolant Injection (LPCI) Heat Exchangers and the as-found inspection of the 3B LPCI room cooler. In addition the inspectors reviewed documents and records of the 3A LPCI room coolers eddy urrent inspection and the cleaning of the 3B LPCI room coolers. No issues were identified.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 13.

14. Item 14, Closed-Cycle Cooling Water Chemistry Commitment Item 14 specified that the existing closed-cycle cooling water chemistry program was credited for license renewal and that the program would be enhanced prior to the period of extended operation to be consistent with EPRI guidance.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, implementing procedures, chemistry results, and related ARs; and interviewed the plant personnel responsible for the program regarding these documents procedures to verify the program is being implemented on Unit 3. The licensee implemented a Commitment Item change to incorporate requirements from the latest EPRI guidance document, EPRI TR 1007820, Closed Cooling Water Chemistry Guideline, Revision 1. The inspectors verified that this change was appropriate.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 14.

15. Item 15, Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Commitment Item 15 specified that the existing inspection of overhead heavy load and light load (related to refueling) handling systems program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007.

The inspectors reviewed the overhead heavy load and light load (related to refueling)handling systems program as applied to Unit 3. The inspectors reviewed the licensing basis, the program basis documentation, changes to the program that occurred after the Unit 2 inspection, implementing procedures, planned and completed work orders, related corrective action documents, and interviewed personnel responsible for the program regarding these documents. The inspectors verified that planned and completed work orders and related CRs demonstrated that the overhead heavy load and light load (related to refueling) handling systems program was applied appropriately to Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 15.

16. Item 16, Compressed Air Monitoring Commitment Item 16 specified that the existing compressed air monitoring program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, implementing procedures, scheduled and completed work orders, and EPRI TR-108147 procedures to verify the program is being implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensees actions the inspectors determined that the licensee met Commitment Item 16.

17. Item 17, BWR Reactor Water Cleanup System Commitment Item 17 specifies that the existing program is credited for license renewal and is consistent with the NUREG-1801 Generic Aging Lessons Learned (GALL).

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors determined that no further review was required for Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 17.

18. Item 18, Fire Protection Commitment Item 18 specified that the licensee would enhance the existing fire protection program as follows:

• Provide specific guidance to check fire doors for wear and holes in skin that could affect intended function during weekly tours.

• Inspection of external surfaces of the Halon system and carbon dioxide system.

• Periodic capacity tests of the isolation condenser makeup pumps.

• Specific fuel supply leak inspection criteria for fire pumps and isolation condenser makeup pumps during testing.

• Inspection frequencies for fire doors and spill barriers will be provided.

• Perform a visual inspection (VT-1 or equivalent) on a 10 percent sample population of each type of fire seal on a refueling outage frequency. Expand the sample population by 10 percent if any of the inspected seals are found to have abnormal degradation that could prevent the seal from performing its intended function.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis documents, and revised implementing procedures and determined that the program was not unit specific. The inspectors verified that the procedure revisions addressed the minor issues identified in Inspection Report 05000237/2009007, and did not negatively affect other aspects of the program.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 18.

19. Item 19, Fire Water System Commitment Item 19 specified that the existing fire water system program was credited for license renewal and that the program would include several enhancements prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors verified that planned and completed work orders and related CRs demonstrated that the fire water system program was appropriately applied to Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 19.

20. Item 20, Above-ground Carbon Steel Tanks Commitment Item 20 specified that the existing above-ground carbon steel tanks program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

The enhancements included periodic system engineer walkdowns on the nitrogen storage tanks utilizing stand alone procedures, periodic internal/external inspections of the aluminum storage tanks, and periodic UT thickness inspections of the tank bottoms.

Program requirements and inspections for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. As the tanks are common to both units, the inspectors determined that these activities reviewed were also adequate for Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 20.

21. Item 21, Fuel Oil Chemistry Commitment Item 21 specified that the existing fuel oil chemistry program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, scheduled, and completed work orders, issue reports, and implementing procedures to verify that the program is being implemented for Unit 3. The inspectors verified that the licensee has implemented a program that evaluates the material condition and bottom thickness of the fuel oil storage tanks to ensure aging effects are effectively managed. The inspectors reviewed work orders and procedures implemented to ensure the licensee initiated evaluations at an appropriate threshold, commensurate with the programs requirements. The inspectors also reviewed Operating Experience to ensure the licensee was screening appropriately in addition to performing evaluations when necessary.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 21.

22. Item 22, Reactor Vessel Surveillance Commitment Item 22 specified that the existing reactor vessel surveillance Aging Management Program was credited for license renewal and that the program would be enhanced prior to the period of extended operation. The program is implemented through station procedures that conform to the requirements of 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements. Neutron embrittlement is predicted utilizing chemistry tables and Position 1.3 limitations as described in Regulatory Guide 1.99, Revision 2, Radiation Embrittlement of Reactor Vessel Materials.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures and interviewed the plant personnel responsible for the program regarding these documents to verify that the program is being implemented for Unit 3. The inspectors verified that the licensee incorporated the testing requirements for reactor vessel test capsules have been incorporated into station programs and procedures similarly for both units.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 22.

23. Item 23, One-Time Inspection Commitment Item 23 specified that the licensee perform one-time inspections of selected plant equipment to verify that current plant Aging Management Programs are effective in managing the effects of aging prior to the period of extended operation.

The one-time inspection program provides for examinations of representative materials in environments that are not expected to experience aging effects in order to verify that this is the case.

The licensee had established separate one-time inspection programs covering the specific commitments listed in the SER. General program requirements for this commitment were reviewed in Dresden Unit 2 Inspection Report 05000237/2009007 which identified two findings in this area.

The inspectors reviewed each program basis document, program changes, work orders, and corrective actions for the issues from the previous inspection. The inspectors also observed the one time visual examination of the High Pressure Coolant Injection (HPCI)lube oil piping. No issues were identified.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 23.

24. Item 24, Selective Leaching of Materials Commitment Item 24 specified one-time visual inspection of a sample of materials susceptible to selective leaching of materials prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors reviewed the licensing basis, the Selective Leaching of Materials Program basis documentation, completed work orders, and interviewed personnel responsible for the program regarding these documents and verified the program was appropriately applied to Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 24.

25. Item 25, Buried Piping and Tanks Inspection Commitment Item 25 specified an enhancement to complete one-time inspections prior to the period of extended operation. The Buried Piping and Tanks Inspection Program was an existing program that provided preventive and condition monitoring measures to manage loss of material, due to either corrosion of ferrous piping and tanks or aggressive chemical attack of asbestos concrete piping, from external environments for buried piping and tanks.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors verified that planned and completed work orders and related CRs demonstrated that the program was appropriately applied to Unit 3 Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 25.

26. Item 26, ASME Code,Section XI, Subsection IWE Commitments 26 specified that the existing ASME Code,Section XI, Subsection IWE program was credited for license renewal and would be enhanced prior to the period of extended operation. This program implemented inservice inspection in accordance with the ASME Code,Section XI, Subsection IWE for the containment structure.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. Dresden Unit 3 is considered the lead unit as it has more potential for corrosion of the containment shell due to previous wetting. The inspectors reviewed the program basis documents, and inspection records to verify that the program is being implemented for Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 26.

27. Item 27, ASME Code,Section XI, Subsection IWF Commitment Item 27 ASME Code Section XI, Subsection IWF Component Support Program specified that the existing American Society of Mechanical Engineers (ASME)

Code Section XI, Subsection IWF Component Support Program was credited for license renewal with enhancement to include inspection of Code Class MC supports.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis document, implementing procedures, examination records, and related ARs to verify the program is being implemented on Unit 3. The inspectors also observed the licensee perform an underwater visual examination of torus column supports and reviewed the containment shear lug support examinations to determine if the licensee was effectively implementing this program. The inspectors observed the visual examination of the biological shield to containment stabilizers. No issues were identified.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 27.

28. Item 28, Appendix J of 10 CFR Part 50, Commitment Item 28 specifies the existing 10 CFR Part 50 Appendix J Aging Management Program was credited for license renewal. The program provides for aging management of pressure boundary degradation due to loss of material in the primary containment and various systems penetrating primary containment. The program also manages changes in material properties of gaskets, O rings, and packing materials for the primary containment pressure boundary access points. Containment leak rate tests are performed to assure that leakage through the primary containment and systems and components penetrating primary containment does not exceed allowable leakage limits specified in the Technical Specifications. The program includes an exception to NUREG 1801 for two-ply design bellows that cannot be tested to satisfy the requirements of Appendix J. Testing is in accordance with NRC-approved alternate test until bellows are replaced.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, issue reports implementing procedures, and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit 3. The inspectors verified that the requirements for testing two-ply bellows have been incorporated into station programs and procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 28.

29. Item 29, Masonry Wall Program Commitment Item 29 specified that the existing masonry wall program was credited for license renewal and would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors reviewed the licensing basis, the program basis documentation, and interviewed responsible masonry wall program personnel to confirm that visual inspection of masonry walls was ongoing and would implemented into the period of extended operation. The inspectors verified that planned and completed work orders and related CRs demonstrated that the Masonry Wall program was appropriately applied to Unit 3.

The inspectors identified a minor concern with documentation of completed inspections not being entered into the licensees records retention system. The licensee entered this issue into the corrective action program as IR 1129200.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 29.

30. Item 30, Structures Monitoring Program Commitment Item 30 specified that the existing structures monitoring program was credited for license renewal and would be enhanced prior to the period of extended operation. The structures monitoring program was an existing program that provided for aging management of various structures and external surfaces of mechanical components within the scope of license renewal.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis documents, and inspection records to verify that the program is being implemented for Unit 3. The inspectors walked down an area of the plant to compare current condition with that recorded from a walkdown conducted in 1996. No additional degradation was identified. The inspectors also observed the visual inspection of the pressure suppression piping supports.

The inspectors identified a minor concern with documentation of completed inspections not being entered into the licensees records retention system. The licensee entered this issue into the corrective action program as IR 1129200.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 30.

31. Item 31, Regulatory Guide (RG) 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Commitment Item 31 specified that the existing RG 1.127, "Inspection of Water-Control Structures Associated with Nuclear Power Plants," program was credited for license renewal and would be enhanced prior to the period of extended operation. This program was part of the Structures Monitoring Program and consisted of procedures that provided for condition monitoring of structural steel elements, concrete, and earthen structures within the scope of license renewal.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documentation, and revised implementing procedures.

The inspectors reviewed documents and video records of the U3 Discharge Outfall Structure below the water line VT-3 inspection completed during the D3R21 outage.

No issues were identified.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 31.

32. Item 32, Protective Coating Monitoring and Maintenance Program Commitment Item 32 specified enhancements to the Protective Coating Monitoring and Maintenance Program to be implemented prior to the period of extended operation. The Protective Coating Monitoring and Maintenance Program was an existing program that provided for aging management of Service Level I coatings inside primary containment.

Service Level I coatings were used in areas where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.

The program provided for visual inspections to identify any condition that adversely affects the ability of the coating film to function as intended.

The inspectors reviewed the program basis documentation, revised implementing procedures, and pre-inspection trend report. The inspectors also observed portions of the torus vapor area coatings inspection, inspections in the Unit 3 drywell, and video records of underwater torus inspections conducted during D3R21.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 32.

33. Item 33, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Commitment Item 33 specified that licensee would develop a program that is consistent with NUREG-1801 AMP XI.E1 for electrical cables and connections installed in adverse localized environments not subject to 10 CFR 50.49 environmental qualification requirements.

The licensee developed a program to visually inspect all accessible electrical cables and connections installed in adverse localized environments for signs of accelerated age-related degradation. Additional inspections, repairs, or replacements are to be initiated as appropriate.

General program requirements for this commitment were reviewed in Dresden Unit 2 Inspection Report 05000237/2009007. A finding was identified at that time for failure to implement a program in accordance with the license renewal program basis document B.1.33. The inspectors reviewed licensing basis, the program basis documentation, revised implementing procedures and records of walkdowns for determining adverse localized environments and visual inspections for cables. The inspectors also reviewed corrective actions to address the finding from Inspection Report 05000237/2009007.

The inspector observed walkdown visual examinations of cables in several adverse environmental areas in the plant.

Based on the licensees actions to correct the issues identified by the inspectors, the inspectors determined that the licensee met Commitment Item 33.

34. Item 34, Metal Fatigue of Reactor Coolant Pressure Boundary Commitment Item 34 specified an enhancement to use the EPRI-licensed FatiguePro cycle counting and fatigue usage factor tracking computer program, to provide for calculation of stress cycles and fatigue usage factors from operating cycles, automated counting of fatigue stress cycles, and automated calculation and tracking of fatigue cumulative usage factors prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection to ensure that the program remained effective for both units. The inspectors verified that planned and completed work orders and calculations; and related CRs demonstrated that the Metal Fatigue of Reactor Coolant Pressure Boundary program was appropriately applied to Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 34.

35. Item 35, Environmental Qualification (EQ) of Electrical Components Commitment Item 35 specified that the licensee was to maintain the existing environmental qualification program of the electrical components for the period of extended operation.

Program activities establish, demonstrate and document the level of qualification, qualified configuration, maintenance, surveillance and replacement requirements necessary to meet 10 CFR 50.49.

The inspectors reviewed the licensing basis, program basis document, and various existing EQ Binders. The inspectors also reviewed the self-assessment report completed August 21, 2009, and corrective actions resulting from the assessment.

Based on the review of the timeliness and adequacy of the licensees actions and assessment for the program, the inspectors determined that the licensee met Commitment Item 35.

36. Item 36, Boraflex Monitoring The Boraflex Monitoring program is not applicable to Dresden Unit 3.

Dresden uses Boral as a neutron absorber material in the spent fuel pool, and has an existing Boral monitoring program specified in its UFSAR Section 9.1.2.3.1. Based upon recent operating experience communicated in NRC Information Notice 2009-26, Degradation of Neutron-Absorbing Materials in the Spent Fuel Pool, the licensee has initiated actions to revise the current Boral surveillance program.

37. Item 37, Electrical Cables Not Subject to 10 CFR 50.49 Environmental Requirements Used in Instrument Circuits Commitment Item 37 specified that the licensee was to develop a program to manage aging of cables in sensitive instrumentation circuits with low level signals in the Nuclear Instrumentation Systems and Radiation Monitoring Systems.

The program is applied to the cables of the Nuclear Instrumentation Systems which included source range monitors (SRMs), intermediate range monitors (IRMs), local power range monitors, and Radiation Monitoring Systems, which included drywell high range radiation monitors, main steam line radiation monitors, and the steam jet air ejector radiation monitors. The program specified a review of calibration and surveillance results, and cable testing for cable aging degradation before the period of extended operation and every 10 years thereafter.

General program requirements and the initial trending for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007.

The inspectors reviewed Unit 3 test results. No issues were identified.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 37.

38. Item 38, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Requirements Commitment Item 38 specified that the licensee was to provide a new condition monitoring program in accordance with NUREG-1801, AMP XI.E3 to manage aging of five inaccessible medium voltage cables feeding the service water pumps.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the program basis document, corrective action documents and completed work orders for Unit 3.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 38.

39. Item 39, Corrective Action Program Commitment Item 39 specified that the existing corrective action program was credited for license renewal.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The program was further reviewed in March 2010 and found adequate as documented in problem identification and resolution Inspection Report 05000237/2010006; 05000249/2010006.

The inspectors reviewed the corrective action program documents related to license renewal and identified no issues.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 39.

40. Item 40, Periodic Inspection of Non-EQ, Non-Segregated Electrical Bus Ducts Commitment Item 40 specified that the licensee was to develop and implement a program to periodically inspect non-segregated bus ducts that connect the reserve auxiliary transformers (RATs) to 4160 V essential service (ESS), the non-segregated bus ducts that connect the Emergency Diesel Generators (EDGs) to the ESS buses, and the non-segregated bus ducts that connect ESS buses.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed completed Unit 3 work orders and reviewed photographic records of inspections performed during the Unit 3 outage. No issues were identified.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 40.

41. Item 41, Periodic Inspection of Ventilation System Elastomers Commitment Item 41 specified that the existing periodic inspection of ventilation system elastomers was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed changes to the program that occurred after the Unit 2 inspection and ensured that the program remained effective for both units. The inspectors verified that planned and completed work orders and related CRs demonstrated that the program was appropriately applied to Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 41.

42. Item 42, Periodic Testing of Drywell and Torus Spray Nozzles Commitment Item 42 specified that the existing periodic testing of drywell and torus spray nozzles was credited for license renewal.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed completed Unit 3 work orders and condition reports to verify that the program has been implemented on Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 42.

43. Item 43, Lubricating Oil Monitoring Activities Commitment Item 43 specified that the existing lubricating oil monitoring program would be enhanced to include components exposed to an environment of lubricating oil in the following systems: the high pressure coolant injection system, the emergency diesel generator and auxiliaries system, the station blackout system, the electro-hydraulic control system prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed licensing basis, program basis document, implementing procedures, scheduled and completed work orders, and applicable corrective action program documents to verify the program is being implemented on Unit 3. The inspectors verified that the licensee has enhanced the program to include the systems and subsystems listed in the commitment item in necessary documents to ensure that aging is managed through the period of extended operation for Units 2 and 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 43.

44. Item 44, Heat Exchanger Test and Inspection Activities Commitment Item 44 specified that the licensee would develop and implement an Aging Management Program for heat exchangers in scope of LR that are not tested or inspected by the open-cycle and closed-cycle cooling water system AMPs, to be completed prior to the period of extended operation. Additionally the Commitment Item states for the Dresden isolation condensers, the augmentation activities identified in NUREG-1801, lines IV.C1.4-a and IV.C1.4-b to manage loss of material and cracking will also be included in this Aging Management Program, and will provide for the following:

(1) temperature and radioactivity monitoring of the shell side(cooling) water;

(2) eddy current testing of the tubes; and

(3) visual inspections of the channel head, tube sheets, and internal surfaces of the shell, prior to the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis document, implementing procedures, scheduled, and completed work orders, related action requests, Engineering Changes (EC) and Evaluations to verify the program is being implemented on Unit 3. One minor issue was identified with a lack of acceptance criteria for isolation condenser inspections. This was entered into the licensees corrective action program as IR 1141127.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 44.

45. Item 45, Generator Stator Water Chemistry Activities Commitment Item 45 specified that the licensee was to implement a plant specific, non-NUREG 1801, Generator Stator Water Chemistry activities program that manages aging by monitoring and controlling stator water chemistry per established procedures.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed Unit 3 chemistry reports to verify that parameters were also monitored for Unit 3.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 45.

46. Item 46, Periodic Inspection of Plant Heating System Commitment Item 46 specified that the licensee would develop and implement an Aging Management Program to inspect components in the plant heating system once before the end of the current operating term and periodically at intervals not to exceed once every 5 years during the period of extended operation.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed completed Unit 3 work orders and condition reports to verify that samples for this inspection were also taken from Unit 3.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 46.

47. Item 47, Time-limited Aging Analysis (TLAA) - Neutron Embrittlement of the Reactor Vessel and Internals Commitment Item 47 specified that revised Pressure Temperature (P/T) limits will be prepared and submitted to the NRC for approval prior to the start of the extended period of operation using an approved fluence methodology. On October 17, 2005, License Amendment No. 209 approved revised P/T limits. The amendments revise Technical Specification (TS) Section 3.4.9, Reactor Coolant System Pressure and Temperature (P/T) Limits, by incorporating revisions to the P/T limit curves for 54 effective full power years (extending to the end of the renewed license). The ASME Code Case N-640 and N-588 were used for revising the P/T limits. The P/T limits will be managed using approved fluence calculations when there are changes in the power of core design in conjunction with surveillance capsule results from the BWRVIP integrated surveillance program.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the licensing basis, program basis documents, implementing procedures, and interviewed the plant personnel responsible for the program regarding these documents reports to verify that samples for this inspection were also taken from Unit 3. The inspectors verified that the program requirements have been incorporated into station programs and procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 47.

48. Item 48, TLAA - Metal Fatigue Commitment Item 48 specified commitments to the TLAA related to metal fatigue.

Specifically, the Unit 2 jet pump riser braces were to be repaired or replaced prior to the period of extended operation. In addition, plant-specific calculations were to be performed for applicable locations identified in NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components, for older-vintage BWR plants, to assess potential effects of reactor coolant on component fatigue life prior to the period of extended operation.

Unit 2 jet pump riser repairs for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed the Unit 3 plant-specific calculations performed for the applicable locations identified in NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components, for older-vintage BWR plants and verified the calculation assessed the potential effects of reactor coolant on component fatigue life.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 48.

49. Item 49, TLAA -Environmental Qualification of Electrical Equipment Commitment Item 49 specified a reanalysis will be applied to EQ components now qualified for the current operating term of 40 years. The EQ binders for components within the scope of 10 CFR 50.49 will be updated to include environmental conditions associated with Extended Power Uprate implementation together with an extended operating period of 60 years.

The requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. The inspectors reviewed several examples for EQ Binders for components within the scope of 10 CFR 50.49 and verified no further unit specific review was required.

Based on the examples reviewed and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 49.

50. Item 50, Plant-Specific TLAAs Commitment Item 50 specified that two specific TLAAs would be updated prior to the period of extended operation.

The first specified that the licensee conduct a UT inspection of the Dresden Unit 3 (the lead unit) drywell steel plate remaining thickness at the sand pocket level and use the results to revise the associated corrosion calculation and validate that an acceptable wall thickness will remain to the end of the 60-year licensed operating period.

The inspectors reviewed the licensing basis, inspection results, and related CRs; and interviewed the plant personnel responsible for the program. The inspectors also observed the licensee conduct UT inspection of the Dresden Unit 3 (the lead unit)drywell steel plate remaining thickness at the sand pocket level. A finding was identified and is detailed below in Section 4OA5.1.b. The inspectors verified that the licensee reaccomplished these inspections and evaluated the results. Evaluation EC 373104, Revision 3 determined that the thickness is expected to remain above ASME code allowable limits for approximately 59 years. The licensee intends to update this estimate with measurements taken every refueling outage.

The second TLAA specified that the licensee conduct a UT inspection of the ECCS suction strainer flange remaining thickness and use the results to revise the associated galvanic corrosion calculation and validate that an acceptable thickness will remain to the end of the 60-year licensed operating period.

The licensee changed the second part of this commitment that was associated with the second TLAA after the Unit 2 licensing renewal inspection as documented in Dresden Unit 2 Inspection Report 05000237/2009007. The licensee changed from a one-time inspection of the ECCS suction strainer flange to periodic inspections of the strainer bolt-holes which will monitor the suction strainer flange corrosion throughout the period of extended operation. The inspectors reviewed the commitment change. The inspectors verified that the change was appropriate and verified by completed and planned work orders and related CRs that the TLAA was properly applied to Unit 3.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 50.

51. Item 51, BWR Operating Experience - EPU levels Commitment Item 51 specified that the licensee perform an evaluation of operating experience at EPU levels to ensure that operating experience at EPU levels is properly addressed by the Aging Management Programs, and submit this evaluation to the NRC for review prior to entering the period of extended operation.

The inspectors documented in Dresden Unit 2 Inspection Report 05000237/2009007 that the licensee performed this evaluation and submitted it for NRC review on November 18, 2009. No further review was required.

52. AMP B.2.9, Periodic Inspection of Components Subject to Moist Air This commitment, discussed in SER Section 3.0.3.18, specified that the licensee would manage the aging of components within the scope of the LR program through the performance of periodic UT inspections, visual (VT-3) inspections, and visual inspection of flexible hoses for age related degradation.

This program is a new program that manages the loss of material aging degradation of stainless steel, carbon steel, cast iron, aluminum, copper, and brass and bronze components. The licensee created this program to ensure that aging degradation of components is inspected at a frequency that allows the identification of any degradation that may occur due to the components exposure to a moist air environment. If abnormal conditions are identified as a result of any of the programs UT or visual inspections, the licensee committed to performing engineering evaluations to address the progression of the degradation and identifying appropriate corrective actions in accordance with the site controlled Quality Assurance Program.

General program requirements for this commitment were determined to be complete in Dresden Unit 2 Inspection Report 05000237/2009007. This is a sampling program and most of the inspections were conducted on Unit 2. The inspectors reviewed completed work orders on Unit 3 components. The inspectors reviewed documents and video records of the U3 HPCI turbine casing VT-3 boroscope inspection completed during the D3R21 outage. Additionally, the inspectors reviewed documents related to the inspection/overhaul of the HPCI turbine control valves. No issues were identified.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee was meeting this commitment.

b. Findings and Observations

(1) Failure to Perform an Ultrasound Thickness Measurement of the Drywell liner in accordance with procedures.

Introduction:

A finding of very low safety-significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the failure of a licensee NDE examiner to accomplish activities affecting quality in accordance with procedures.

Description:

On November 4, 2010, the inspectors observed a licensee NDE examiner performing an ultrasound thickness measurement of the drywell liner. This exam was to be performed in the core bore holes located in the drywell basement. These pre-existing core bore holes enabled the licensee to measure the thickness of the drywell liner and determine if degradation was occurring. Due to the configuration, water often filled these core bore holes and the condition of the liner surface was not readily known. The inspectors identified that the examiner failed to perform the examination in accordance with the requirements of procedure ER-AA-335-004, Revision 4, Ultrasonic Measurement of Material Thickness and Interfering Condition. Specifically, this procedure states in part the surface shall be free of roughness and other conditions which may interfere with the free movement of the search unit or impair the transmission of ultrasound. Through discussions and observation, the inspectors identified that the examiner failed to ensure the surface to be examined was clean or prepared prior to performing of the UT examination. After performing the thickness measurements, the licensee noted discrepancies in the results of this examination and decided to re-perform the examination. Prior to re-performing the test, the licensee cleaned and prepared the surface as required by the procedure. The subsequent results appeared to be more consistent and more aligned with expectations.

In response to NRC questions, the licensee initiated AR 01141740 to address the concerns.

Analysis:

The inspectors determined that the failure to adequately perform an ultrasound thickness measurement of the drywell liner in accordance with procedures was contrary to 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and was a performance deficiency.

The finding was determined to be more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, potential degradation could have gone undetected had the inspector not questioned the conduct of the examination, and the results had come out above acceptance criteria.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I -

Initial Screening and Characterization of findings, Table 4a for the Barrier Integrity cornerstone. The inspectors determined that the finding was of very low safety-significance (Green) because the inspectors answered no to all of the worksheet questions.

The inspectors did not find an applicable cross-cutting aspect which represented the underlying cause of this performance deficiency; therefore, no cross-cutting aspect was not assigned.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Procedure ER-AA-335-004 Ultrasonic Measurement of Material Thickness and Interfering Conditions Part 3.3.5 states verify the contact surfaces on the material to be examined are free from weld spatter, roughness, of other conditions, which may interfere with free movement of the search unit or impair the transmission of sound.

Contrary to the above, on November 4, 2010, the licensee failed to clean and prepare the surface for the performance of the UT examination and in turn ensure the surface to be examined was free of roughness or other conditions that could interfere with the free movement of the search unit or impair the transmission of sound. Because this violation was of very low safety-significance and it was entered into the licensees corrective action program as AR 01141740, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000249/2010010-01),

Failure to Perform an Ultrasound Thickness Measurement of the Drywell liner in Accordance with Procedures.

c. Overall Conclusions The inspectors did not identify any other substantive instances of incomplete license renewal commitments with respect to timeliness or adequacy. The licensee has implemented corrective actions for the finding detailed above; therefore, the inspectors concluded that commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license were being met at the Dresden Nuclear Power Plant Unit 3.

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 19, 2010, the inspectors presented the inspection results to Mr. T. Hanley, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

An interim exit was conducted on October 29, 2010, where the inspectors presented the Phase II inspection results to Mr. J. Sipek and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Hanley, Site Vice President

S. Marik, Station Plant Manager

G. Ice, Regulatory Assurance - NRC Coordinator

D. Gronek, Operations Director

J. Hansen, Corporate Licensing

L. Jordan, Training Director

R. Kalb, Chemistry

P. Karaba, Maintenance Director

J. Kish, Engineering Programs

D. Leggett, Regulatory Assurance Manager

R. Laburn, Radiation Protection

P. Mankoo, Chemistry Supervisor

P. OConnor, Licensed Operator Requalification Training Lead

M. Overstreet, Lead Radiation Protection Supervisor

C. Podczerwinski, Maintenance Rule Coordinator

P. Quealy, Emergency Preparedness Manager

E. Rowley, Chemistry

R. Rybak, Regulatory Assurance

J. Sipek, Engineering Director

N. Starcevich, Radiation Protection Instrumentation Coordinator

J. Strmec, Chemistry Manager

S. Vercelli, Work Management Director

LIST OF ITEMS

Opened and Closed

05000249/2010010-01 NCV Failure to Perform an Ultrasound Thickness Measurement of the Drywell liner in accordance with procedures (4OA5.1.b(1))

Attachment