ML100610336

EOC Annual Assessment Letter, Inspection/Activity Plan

ML100610336
Person / Time
Site:	Dresden
Issue date:	03/03/2010
From:	West S K Division Reactor Projects III
To:	Pardee C G Exelon Generation Co, Exelon Nuclear
References
Download: ML100610336 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 March 3, 2010

Mr. Charles G. Pardee Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

ANNUAL ASSESSMENT LETTER - DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 (05000237/2010001; 05000249/2010001)

Dear Mr. Pardee:

On February 11, 2010, the NRC staff completed its performance review of Dresden Nuclear Power Station, Units 2 and 3.

Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information.

A separate letter designated and marked as "Official Use Only -- Security Information" will include the Security Cornerstone review and resultant inspection plan.

Dresden Unit 2 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter as well as the first three quarters of the assessment cycle, was within the Licensee Response column of the NRC's Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections on Unit 2.

Dresden Unit 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Regulatory Response column of the NRC

=s Action Matrix, based on one inspection finding in the Mitigating Systems Cornerstone being classified as having low to moderate safety significance (White). This White finding, from the third quarter of 2009, involved the inadvertent withdrawal of three control rods by non-licensed operators during a shutdown condition. We will plan to conduct a supplemental inspection in accordance with Inspection Procedure (IP) 95001 in response to this White finding after we are notified of your readiness. This supplemental inspection will be in addition to baseline inspections at your facility.

C. Pardee

Additionally, the staff has identified a substantive cross-cutting issue (SCCI) in the area of Human Performance (HP) with a cross-cutting theme in the aspect of Work Practices-Human Error Prevention Techniques, H.4(a). During this assessment period, there were 14 findings documented with cross-cutting aspects in the HP area. Five of these findings shared a common cross-cutting Human Error Prevention Techniques aspect and were from different cornerstones. We have a concern with your progress in addressing this issue; specifically, your corrective actions have been in place for some time but have not yet proven to be effective. There has been no sustained period of improved performance. This substantive cross-cutting issue will remain open until the NRC gains confidence in your performance through your demonstration of positive, sustainable improvement in the area of Human Performance and after consideration of the number of findings with the same cross-cutting aspect.

In our 2009 mid-cycle assessment, we identified a cross-cutting theme in the area of Problem Identification and Resolution (PI&R) involving the station's ability to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity, P.1(d). We had determined that a substantive cross-cutting issue was not warranted in this area at the time since you had appropriately identified the theme, and scheduled or taken a range of corrective actions to address the issue. In this assessment we have determined that it appears the station has made improvement within this area as evident by the reduction in findings sharing the P.1(d) aspect. Therefore, we are not proposing a substantive cross-cutting issue at this time.

The enclosed inspection plan details the inspections, less those related to security, scheduled through June 30, 2011. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature.

Additional inspections scheduled include: component design basis, independent spent fuel storage installation operation, post-approval license renewal (for Units 2 and 3), managing fatigue, and a supplemental inspection for the White finding on Unit 3. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC

=s A Rules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

C. Pardee

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven West, Director Division of Reactor Projects Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Dresden Inspection/Activity Plan cc w/encl: Distribution via ListServ C. Pardee

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mark Ring at (630) 829-9703 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven West, Director Division of Reactor Projects Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Dresden Inspection/Activity Plan cc w/encl: Distribution via ListServ

DOCUMENT NAME: G:\1-SECY\1-WORK IN PROGRESS\2009 EOC LETTERS\DRESDEN 2009 EOC LETTER.DOC

G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive To receive a copy of this document, indicate in th e concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII E RIII RIII RIII NAME MRing:cms SWest DATE 02/24/10 03/03/10 OFFICIAL RECORD COPY

Letter to C. Pardee from S. West dated March 3, 2010

SUBJECT:

ANNUAL ASSESSMENT LETTER - DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 (05000237/2010001; 05000249/2010001)

DISTRIBUTION

Susan Bagley

RidsNrrDorlLpl3-2

RidsNrrPMDresden Resource RidsNrrDirsIrib Resource Cynthia Pederson Steven Orth Jared Heck

Allan Barker Carole Ariano Linda Linn

DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

Inspection / Activity Plan Page 1 of 2 02/24/2010 Report 22 03/01/2010

-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Dresden ISFSI-ISFSI INSPECTION 1 2 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 03/01/2010 07/31/2010 BI PI&R-BIENNIAL PI&R INSPECTION 4 2, 3 IP Identification and Resolution of Problems 71152B 03/01/2010 03/19/2010 OL EXAM-DRESDEN INIT EXAM MARCH/2010 3 2 OL - INITIAL EXAM - MAR 2010 - DRES W90218 03/08/2010 03/19/2010 BI ENG-COMPONENT DESIGN BASIS INSPECTION 6 2 IP Component Design Bases Inspection 7111121 04/19/2010 05/21/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 05/03/2010 05/07/2010 2 IP Reactor Coolant System Activity 71151-BI01 05/03/2010 05/07/2010 BI OL-LIC. OPERATOR REQUAL. PROGRAM EVALUATION 1 2, 3 IP Licensed Operator Requalification Program 7111111B 05/24/2010 05/28/2010 TI-TEMPORARY INSTRUCTION 2515/180 1 2 IP Inspection of Procedures and Processes for Managing Fatigue 2515/180 06/17/2010 06/17/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Occupational Dose Assessment 71124.04 08/16/2010 08/20/2010 2 IP Public Radiation Safety 71124.07 08/16/2010 08/20/2010 2 IP RETS/ODCM Radiological Effluent 71151-PR01 08/16/2010 08/20/2010 RENEWAL-LICENSE RENEWAL 71003 - PHASE 2 - U3 7 3 IP Post-Approval Site Inspection for License Renewal 71003 10/18/2010 10/29/2010 RENEWAL-LICENSE RENEWAL 71003 - PHASE 1 - U3 3 3 IP Post-Approval Site Inspection for License Renewal 71003 11/01/2010 11/19/2010 BI ENG-ENGINEERING INSERVICE INSPECTION 1 3 IP Inservice Inspection Activities - BWR 7111108G 11/01/2010 11/19/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Occupational ALARA Planning and Controls 71124.02 11/08/2010 11/19/2010 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 11/08/2010 11/19/2010 2 IP Occupational Exposure Control Effectiveness 71151-OR01 11/08/2010 11/19/2010 BI ENG-RPV HEAVY LOADS SMART SAMPLE 1 2 IP Refueling and Other Outage Activities 7111120 01/10/2011 01/28/2011 OL PREP-DRESDEN INIT PREP - 02/2011 3 2 OL - INITIAL EXAM - MARCH 2011 - DRES W90229 02/14/2011 02/18/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 02/21/2011 02/25/2011 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Inspection / Activity Plan Page 2 of 2 02/24/2010 Report 22 03/01/2010

-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Dresden BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Reactor Coolant System Activity 71151-BI01 02/21/2011 02/25/2011 OL EXAM-DRESDEN INIT EXAM - 03/2011 3 2 OL - INITIAL EXAM - MARCH 2011 - DRES W90229 03/07/2011 03/18/2011 BI EP-EP EXERCISE INSPECTION / PI VERIFICATION 3 2 IP Exercise Evaluation 7111401 03/21/2011 03/25/2011 2 IP Drill/Exercise Performance 71151-EP01 03/21/2011 03/25/2011 2 IP ERO Drill Participation 71151-EP02 03/21/2011 03/25/2011 2 IP A lert & Notification System 71151-EP03 03/21/2011 03/25/2011 BI ENG-TRIENNIAL HEAT SINK INSPECTION 1 2 IP Heat Sink Performance 7111107T 03/28/2011 04/01/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 2 IP Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 2515/179 06/20/2011 06/24/2011 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 06/20/2011 06/24/2011 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 06/20/2011 06/24/2011 2 IP Occupational Dose Assessment 71124.04 06/20/2011 06/24/2011 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.