IR 05000237/2016007
| ML16152A101 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/31/2016 |
| From: | Jamnes Cameron Reactor Projects Region 3 Branch 4 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2016007 | |
| Download: ML16152A101 (28) | |
Text
May 31, 2016
Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000237/2016007; 05000249/2016007
Dear Mr. Hanson:
On April 29, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Dresden Nuclear Power Station, Units 2 and 3. The NRC inspection team discussed the results of this inspection with Mr. P. Karaba and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection sample, the inspection team determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety. The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety. Discussed in the enclosed report is an identified weakness associated with the quality of some of your self-assessments. Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Jamnes Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
IR 05000237/2016007; 05000249/2016007 cc: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-237; 50-249 License Nos: DPR-19; DPR-25 Report No: 05000237/2016007; 05000249/2016007 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Dates: April 11 through April 29, 2016 Inspectors: J. Rutkowski, Project Engineer and Team Leader G. Hausman, Senior Reactor Inspector G. O'Dwyer, Reactor Engineer C. Phillips, Project Engineer M. Porfirio, Resident Inspector, Illinois Emergency Management Agency Approved by: J. Cameron, Chief Projects Branch 4 Division of Reactor Projects 2
SUMMARY
Inspection Report 05000237/2016007; 05000249/2016007; 04/11/2016 - 04/29/2016;
Dresden Nuclear Power Station, Units 2 and 3; Biennial Problem Identification and Resolution Inspection Report This inspection was performed by four NRC regional inspectors and the site Illinois Emergency Management Agency inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, dated February 2014. Problem Identification and Resolution On the basis of the sample selected for review, the team determined that implementation of the corrective action (CA) program at the Dresden Nuclear Power Station, Units 2 and 3, was generally good. The licensee demonstrated a low threshold for identifying problems and entering them in the CA program. Items entered into the CA program were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies although weaknesses with self-assessments were identified in one department. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns directly into the CA program or through their supervisors but some non-supervisory personnel questioned the value of identifying concerns for what they perceived as low-level issues.
NRC-Identified
and Self-Revealed Findings None
Licensee-Identified Violations
None 3
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
The activities documented in Sections
.1 through .4 constituted one biennial sample of problem identification and resolution as defined in IP 71152. .1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensee's corrective action (CA) program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel. The inspectors reviewed risk and safety significant issues in the licensee's CA program since the last NRC Problem Identification and Resolution (PI&R) inspection completed in March 2014. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed action requests/issue reports (ARs) generated as a result of facility personnel's daily plant activities. The inspectors also reviewed a selection of work orders (WOs), performance indicator reports, system health reports, and completed investigations from the licensee's various investigation methods, which included root cause evaluations (RCE) and apparent cause evaluations (ACE). The inspectors selected electronic board components used in safety-related equipment to review in detail. The inspectors' review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these and associated components through effective implementation of station monitoring programs. A five year review of the electronic component was undertaken to assess the licensee staff's efforts in monitoring for system degradation due to aging aspects. The inspectors also performed a partial system walkdown of emergency diesel generators and equipment associated with a station battery room ventilation to review if conditions of the equipment was appropriately represented in plant health reports, work orders, and the CA program. During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's CA program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined whether licensee personnel were identifying station issues at the proper threshold, entering the station issues into the station's CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations.
The inspectors also reviewed corrective actions from licensee's ARs 01513452, "NRC Preliminary White Finding-Flood Mitigation Procedure," 02445040, "NRC Report 2014-005 Preliminary White Finding for ERV," and 02437067, "FWLC 2-0640-33 Failed; Resulting in Loss of Baily FWLC SYS" which were not completed by the licensee as of closeout inspections for the associated violations. Documents reviewed are listed in the Attachment to this report. b. Assessment (1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of ARs and information from interviews, the inspectors determined that the licensee has a low threshold for initiating ARs, and from the ARs reviewed, the threshold was appropriate and that all station departments were active in generating ARs. The inspectors did not identify any safety significant item that was not entered into the CA program. Some personnel stated that they might not document low-level issues, due to the perception that those issues would not be effectively addressed through the CA program. The inspectors also determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The inspectors assessed the effectiveness of problem identification as adequate to support nuclear safety. Observations The inspectors found that issues were being identified and captured in the licensee's CA program. The licensee initiated approximately 13,000 ARs in calendar year 2015. The licensee identified that approximately 1727 ARs were in the approved status (reviewed) but assigned action was not complete. There were also approximately 795 issue reports in an approved status that were categorized as a condition not required to be in the formal CA program (categorized as an "NCAP"). The inspectors noted that licensee's procedures allowed for closing some low-level ARs to the work order system. The inspectors noted that at the time of the inspection there were approximately 2403 open work orders (WOs) with the majority of the orders classified as not critical. The inspectors concluded that the number of open ARs and WOs appeared consistent with industry averages. The inspectors reviewed open corrective WOs, open corrective action items, and system health reports for the last five years for electronic component history. The inspectors also discussed the licensee's aging management program for those components with system engineers and physically verified the apparent physical conditions of some equipment containing those components with a system engineer. The inspectors did not identify any major conflicts between actual system conditions and the condition of the systems as represented in WOs, system health reports, and CA program documents. Additional details are provided in Section
.1 b.(2). Findings
No findings were identified.
(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensee's overall performance in the prioritization and evaluation of issues was generally appropriate. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were appropriately screened by the originating departments, the Station Ownership Committee (SOC), Management Review Committee, and Operations shift management for items potentially impacting equipment operability. Evaluations in apparent cause and root cause reports reviewed by the inspectors were appropriate to support nuclear safety; however, the inspectors noted numerous examples in which it was not clear whether specified corrective actions had been completed from the review of completed ARs. Also the inspectors found some corrective actions were rescheduled beyond the initial scheduled completion dates and some developed actions were rescheduled several times. Observations The inspectors identified no items in the backlogs of the CA program or maintenance WO system that were risk significant, either individually or collectively, although the inspectors noted several instances of multiple extensions for actions. The inspectors also noted several instances where they questioned whether actions classified as an Action Tracking Item (ACIT) should have been specified as CAs. The inspectors questioned the ease of an ACIT being changed or cancelled with minimal or no review; the inspectors did not identify any examples of where an ACIT actions would have changed if it had been categorized as a CA. The inspectors reviewed the licensee's WO backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately. The inspectors had difficulty in following the activities in several ARs to final completion due to the lack of documented results and only references to other document numbers. Some examples were:
- AR 01239089, "Failed Equipment Is Obsolete - Engineering Required for Eval," showed status as complete and the SOC in the Action Request Details stated "WR [work request] generated to replace 2-3241-98," however, only one AR assignment was identified and the in-progress notes did not identify the WR number or the results of the engineering evaluation. The In-Progress Notes did state "EC 385199 generated on 7/13/11 to replace 2-3241-98," but there was no reference to the results of the engineering evaluation or when a replacement was installed.
- AR 01398536, "U3 MPT Protective Relay Obsolete with No Replacement;" showed the AR status as complete and the SOC in the Action Request Details stated "OAD have 3 relays that can be refurb/repaired" and "Stores has been notified of the relays on hand. Closed to actions taken." The AR did not indicate any assignments that scheduled actions to address and track the issue to resolution. With no In-Progress Notes available to determine what action the licensee took, the completion status of any required actions could not be determined.
- AR1493744 was written to address obsolete meterological tower wind sensors. The AR was closed with a statement that a contract to obtain new sensors was initiated, but did not state the final outcome and whether parts were delivered.
- AR2602903 identified that the station lift pump transformer TR-41 was obsolete, but did not clearly state how the issue would be addressed. The licensee satisfactorily answered the inspectors' questions and provided documentation that the issues had been resolved. However, as stated, these conclusions could not be reached based on a review of the CA program entries alone. 5 Year Review for Obsolescence and Age Degradation The inspectors performed a review of the licensee's CA Program and associated documents focusing on electronic components to determine whether any obsolescence and aging issues existed for the last five years. The inspectors' review and evaluation were focused on obsolescence and aging issues to ensure corrective actions were:
complete, accurate, and timely; considered extent of condition; provided appropriate classification and prioritization; provided identification of root and contributing causes; appropriately focused actions taken that resulted in the correction of the identified problem; identified negative trends; operating experience was adequately evaluated for applicability; and applicable lessons learned were communicated to appropriate organizations. The inspectors determined that the licensee established an Obsolescence Steering Committee (OSC) in accordance with Procedure ER-AA-550, "Equipment Obsolescence Process," Revision 2, which requires quarterly meetings to discuss, maintain and resolve a Top Ten List of obsolescence components. In addition, the OSC presents the obsolescence Top Ten List to the Plant Health Committee (PHC) on a semi-annual frequency. No findings were identified. The inspector's review concentrated on the last five years of CA program actions associated with obsolescence and aging issues of the Unit 2 and Unit 3 Containment Oxygen Analyzer and the actions associated with the Control Room Habitability Calculations. Through interviews and reviews of CA program documents, the inspectors found that during the time period between April 10, 2011, and April 29, 2016, the Unit 2 and Unit 3 Primary Containment Oxygen Analyzers were out-of-service for 374 days and 140 days, respectively. Unit 3 continued to remain out-of-service as of April 29, 2016. The inspectors observed that at one time Unit 2 and Unit 3 were out-of-service for 200 and 62 consecutive days, respectively. The Primary Containment Oxygen Analyzers are required to be operational per technical specification (TS) 3.6.3.1. If the Primary Containment Oxygen Analyzers are not operational, a manual sample must be taken every 7 days to verify the primary containment oxygen is within limits. This requires chemistry and radiation protection technicians to obtain the sample. The sample takes 4 man-hours to complete. As a result, a conservative 54 samples (i.e., 216 man-hours)and 20 samples (i.e., 80 man-hours) were required to maintain Unit 2 and Unit 3 TS requirements, respectively. Findings No findings were identified.
(3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the CAs appeared generally appropriate for the identified issues. Those CAs addressing selected NRC documented violations were also determined to be generally effective and usually timely. The inspectors' review of Corrective Actions to Prevent Reoccurrence (CAPRs) did not identify subsequent recurrence of the addressed issues. The inspectors' review of the previous five years of the licensee's efforts to address issues with electronic components did not identify any recent negative trends or inability by the licensee to address long-term issues. Observations A maintenance fundamentals self-assessment (AR 2502328) completed in July 2015 listed two deficiencies. Maintenance workers and first line supervisors were not consistently applying all of the maintenance fundamentals. This conclusion was based on a series of ARs and observations made by the assessors. The sole action from these two deficiencies was to present a single slide at the beginning of the maintenance cycle training in April 2016 which was almost a year after the assessment was completed. The Nuclear Oversight (NOS) assessments of maintenance in 2012, 2014, and 2016 all identified issues with the control of quality parts. Although these conditions adverse to quality were addressed on an individual basis the trend was not addressed effectively which resulted in the recurring deficiency. Corrective Actions Associated with Root Cause Evaluations for White NRC Findings associated with Flood Mitigation Procedure, and Failed Electromagnetic Relief Valve At the NRC closeout of inspections associated with cited violations, not all of the corrective actions that the licensee had developed were completed. However, the actions that were completed were deemed sufficient to close the violations. However, the NRC requires that those actions not completed also require eventual inspection. During this inspection the inspectors reviewed:
- AR 01513452, "NRC: Preliminary White Finding - Flood Mitigation Procedure." Corrective actions reviewed were deemed acceptable. The following items/assignments in the AR remained opened at the time of this inspection and remain to be reviewed in a subsequent inspection: 41 and 42.
- AR 2445040, "NRC Report 2014-005 "Preliminary White Finding for ERV." Corrective actions reviewed were deemed acceptable. The following items/assignments in the report remained opened at the time of this inspection and remain to be reviewed in a subsequent inspection: 25, 28, 35, and 36.
Findings No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' review was to determine whether the licensee was effectively integrating operating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed whether corrective actions, as a result of OE, were identified, and effectively and timely implemented. In addition, the inspectors review included a sample portion of OE driven corrective actions resulting from 10 CFR Part 21 reports. The inspectors verified the licensee adequately evaluated the vendor's issues for applicability to the station. The inspectors also confirmed the licensee correctly justified whether programmatic controls were in place that would prevent similar issues at the site. In addition, the inspectors verified that the licensee initiated actions to detect, prevent, monitor and correct conditions to prevent future occurrences related to the vendor's report. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors' review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities. Observations The team noted that root and apparent cause evaluations were required to evaluate whether internal or external operating experience was available associated with the event or failure being examined, and whether the evaluation and actions to address those items had been effective. Additionally, all root cause evaluations reviewed included an assessment as to whether the issue being evaluated had potential application to other similar components or plants. The inspectors had one observation in the area of OE. AR 2578767, "10 CFR 21 Notifications Not Reviewed At Dresden," discussed that during the performance of the biennial OE program review performed in 2015, the licensee identified that three 10 CFR Part 21 reports from 2014, that did not specifically identify Dresden Station as being impacted by the report, were not evaluated for applicability to the station by the licensee.
The inspectors reviewed 10 CFR Part 21 report number 2016-009 from the NRC public web site on April 27, 2016. This 10 CFR Part 21 report did not state that it was specifically applicable to Dresden Station. The inspectors selected this report because of its potential applicability to Dresden Station. Exelon internally generates a Daily Industry Events Report (DIER) that compiles all industry OE every week day. The station was notified of this 10 CFR Part 21 report (2016-009) via the DIER on March 18, 2016. At the time the inspectors reviewed this report on April 27, 2016, the licensee had not yet assigned an action to review the report for applicability, a period of about 40 days. The licensee's procedure PI-AA-115-1003, "Processing of Level 3 OPEX Evaluations," Revision 2, Step 4.2.1 had a requirement to assign an action to review 10 CFR Part 21 reports for applicability with a completion date goal within 30 days of the time the action was assigned. There was, however, no time period specified for the assignment to review the Part 21 report after the receipt of the report. The licensee acknowledged this as an issue at the exit meeting on April 29, 2016. However, the issue was not placed into the CA program until May 9, 2016, when questioned by the inspectors.
b. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors assessed the licensee staff's ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. Assessment The inspectors concluded that most self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold with some exceptions in one department. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee. Observations The inspectors reviewed three radiation protection (RP) department self-assessments. Of the three RP assessments there was only one deficiency identified. One of these assessments was a review of all the areas the NRC planned to inspect over the next year (AR 1613009). No deficiencies were identified. The inspectors also reviewed AR 2614410 which identified that corporate RP had performed four assessments in the past year. Three of those assessments had no strengths, recommendations, or deficiencies. The fourth discussed a recommendation but no assignment to address that recommendation was put into the CA Program. The assessments performed by NOS in the RP area in 2015, however, had found seven deficiencies that were addressed (AR 2422723). Based on these observations, the inspectors concluded that the self-assessments performed by the station and corporate RP staff of the station's RP department were not effective.
b. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The inspectors assessed the licensee's safety conscious work environment (SCWE) through the reviews of the facility's employee concerns program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from 2012 and 2014 organization effectiveness surveys and meeting minutes of the Safety Culture Monitoring Panel. As part of the overall inspection effort, inspectors discussed department and station programs with a variety of people. In addition, the inspectors held scheduled interviews with 59 non-supervisory individuals, in groups of four to eleven people, from various departments to assess their willingness to raise nuclear safety issues. Additionally other personnel were randomly asked their views of the effectiveness of the CA program. The individuals for the scheduled interviews were randomly selected to provide a distribution across the various departments at the site. In addition to assessing individuals' willingness to raise nuclear safety issues, the interviews included discussion on any changes in the plant environment over the last 12 months. Other items discussed included:
- knowledge and understanding of the CA program;
- effectiveness and efficiency of the CA program;
- willingness to use the CA program; and
- knowledge and understanding of ECP. The inspectors also discussed the functioning of the ECP with the program coordinator; reviewed program logs from 2014 and 2015; and reviewed two case files. Assessment The inspectors did not identify any issues of concern regarding the licensee's SCWE. Information obtained during the interviews indicated that an environment was established where the majority of licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CA program and other processes, including the ECP and the NRC's allegation process, through which concerns could be raised; and safety significant issues could be freely communicated to supervision. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews even with 2014 survey issues identifying conditions that potentially might act to inhibit discussion of items. Observations Non-supervisory personnel in the interviewed groups stated that at their level there were no issues with working with and communicating with workers in other groups. Several of the groups interviewed expressed concerns with their supervisors' qualifications or a lack of support from their department managers.
All interviewees indicated that they could and would bring up safety issues with supervision, management, or through the CA program. Several of the groups stated the view that the CA program was ineffective for addressing low-level issues. None of the interviewed personnel stated that there was intimidation or retaliation when they brought up issues. Those same interviewees predominantly said they would use the ECP but saw no need to have to resort to the ECP for issue reporting.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary On April 29, 2016, the inspectors presented the inspection results to the Site Vice President, Mr. P. Karaba, 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 and that all material considered proprietary by the licensee was returned to the licensee. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Karaba, Site Vice President
- J. Washko, Station Plant Manager
- G. Baxa, Senior Regulatory Engineer
- F. Gogliotti, Director, Site Engineering
- G. Morrow, Operations Director
- S. Matzke, Corrective Action Program Manager
- D. Walker, Regulatory Assurance - NRC Coordinator
Nuclear Regulatory Commission
- J. Cameron, Chief, Division of Reactor Projects, Branch 4
- M. Porfirio, Resident Inspector, Illinois Emergency Management Agency
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
- None
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- PLANT PROCEDURES Number Description or Title Date or RevisionDAP 14-19
- Oversight of Project/Modification Testing Equipment Obsolescence Process 0 2
- PI-AA-125-1001 Maintenance Rule - Dispositioning Between (A)(1) and (A)(2) Root Cause Analysis Manual
- 7 2
- LS-AA-104-1000 Exelon 50.59 Resource Manual 9
- PI-AA-125-1003 Apparent Cause Evaluation Manual 2
- PI-AA-115 Operating Experience Program 1
- PI-AA-115 Operating Experience Program 1
- PI-AA-115-1003 Processing of Level 3 Opex Evaluations 2
- PI-AA-125 Corrective Action Program (Cap) Procedure 3
- PI-AA-125-1001 Root Cause Analysis Manual 2
- PI-AA-125-1003 Apparent Cause Evaluation Manual 10
- PI-AA-125-1004 Effectiveness Review Manual 1
- MA-AA-716-001 Quality Material/Components Control And Identification/Segregation of Non-Conforming Items 8
- DIS 6600-08 Unit 3 Diesel Generator Pressure Switches and Pressure Indicators Calibration 1
- DIS 6600-08 Unit 3 Diesel Generator Pressure Switches and Pressure Indicators Calibration 2
- ER-AA-440 Emergency Diesel Generator (EDG) Reliability Program 1
- DOP 1300-02 Automatic Operation of Isolation Condenser 23
- DOP 1300-02 Automatic Operation of Isolation Condenser 24
- DOP 1300-02 Automatic Operation of Isolation Condenser 26
- DOP 1300-02 Automatic Operation of Isolation Condenser 27
- AD-AA-3000 Nuclear Risk Management Process 1
- CC-AA-309 Control of Design Analyses 11
- CC-AA-309-1001 Guidelines for Preparation and Processing of Design Analyses 8
- CC-AA-311-1001 Controlled Document Prioritization 8
- PLANT PROCEDURES Number Description or Title Date or RevisionDOS 7000-26 Local Leak Rate Testing of Unit 2(3) Feedwater System Valves [2(3)-220-58A(B),
[2(3)-220-62A(B)] 7
- ER-AA-200 Preventative Maintenance Program 2
- ER-AA-200-1001 Equipment Classification 1
- ER-AA-310-1003 Maintenance Rule - Performance Criteria Selection 5
- ER-AA-550 Equipment Obsolescence Process 2
- MA-AA-733-1001 Guidance for Check Valve General Visual Inspection 7
- MA-DR-MM-4-3201 Feedwater Check Valve Maintenance 3
- PI-AA-120 Issue Identification and Screening Process 3
- PI-AA-127 Passport Action Tracking Management Procedure 2
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 291401 3 8540 5, U3 Primary Containment O2 Analyzer Failed 01/17/05
- 519376 O2 Analyzer not Functioning 08/13/06
- 861036 Analyzer Flow not High Enough 12/29/08
- 917864 U3 O2 Monitor Having Erratic Indication Over 24 Hours 05/10/09
- 939142 Adverse Trend Identified on U3 DW O2 Analyzer 07/06/09
- 1187682
- 2-2301-51 Check Valve is Obsolete 03/15/11
- 1204088-17 Provide Status CR Habitability Calculations 06/14/12
- 1210549 Contingency Relay is Obsolete w/ no Direct Replacement 05/02/11
- 213989 CR Habitability Calculations Need Revision 12/12/13
- 24866 U3 Drywell O2 Analyzer Flow Lo Alarm (923-5A B-3) 06/05/11
- 1230101 Inst Air Regulators Failed for 3-8501-3B and 3-8501-5B 06/17/11
- 1239089 Failed Equipment is Obsolete - Engineering Required for Eval 07/12/11
- 1296084 2/3-1740-203 Obsolete and Parts no Longer Available 11/30/11
- 1305676 Material Requested in
- DIS 0700-13 is Obsolete 12/21/11
- 1327169 NOS ID: Uncontrolled Quality Part Found in MMD and EMD Shops 02/15/12
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1374428 U2 EDGCWP Failed to Start 06/05/12
- 1393901-13 Procedure Change Tracking due to Spare Parts Evaluation 10/18/13
- 1398536 U3 MPT Protective Relay Obsolete with no Replacement 08/08/12
- 1434927 U3 Battery Room HVAC Needs Mrule a(1) Determination 11/02/12
- 1493744 Met Wind Sensors are Obsolete and Requires Replacement 03/28/13
- 1513452 NRC: Preliminary White Finding - Flood Mitigation Procedure 05/13/13
- 1590535
- 2-3902 MOV Failed to Open 11/27/13
- 1617579 Zones Unable to Test 02/05/14
- 1618987 As Left Zero not within Tolerance 02/10/14
- 22805 Root Cause Report Requested for SGI Classification 02/18/14
- 26267 NOS ID: Corrective Action not Assigned & Completed 02/20/14
- 1626985 NOS ID: Safety Related Parts not Traceable to Work Orders 02/27/14
- 1644740 NRC Questions Why
- 2-3902 Valve Failure not MRFF 04/08/14
- 1650033 Mrule A1 Determination Needed for MRFF Z39-1 05/10/14
- 1658449 Security - CCTV
- OSS 05/10/14
- 1662096 Issues with Procedure Revisions Identified 05/20/14
- 1670444 NRC Questions Regarding Iso Cond MOV
- 2-1301-3 06/11/14
- 1854476 MOV
- 2-1301-3 Stroke Length Found Longer than Expected 09/06/14
- 2404375 Level IV Green Finding 3rd Quarter NRC Exit 10/31/14
- 2411760 Stud Cleaning Refuel CAM Alarm 11/14/14
- 2414608 3-1601-60 Failed to Operate from
- MCR 11/19/14
- 2431672 U3 DW %O2 Slow Trend Up 01/01/15
- 2437067 FWLC
- 2-0640-33 Failed; Resulting in Loss of Bailey FWLC Sys 01/14/15
- 2445040 Corrective Actions - NRC Report 2014-005 Preliminary White Finding for
- ERV 01/30/15
- 2470558 Hittman Driver Released Without RP Approval 03/18/15
- 2478121 AFI
- EN.1.1, Engineering Fundamentals 04/01/15
- 2486872 Temp Shield
- SSP 2013-006 and -011 Need to be Made Permanent 04/17/15
- 2490022 Found FME In U2 D/G Main Bearing Low Oil Press (MB1)
- PS 04/23/15
- 2490584 Trng. Thorough Surrounding Written Exam Administration 04/24/15
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 2490696 IR to Document Possible Degradation of U2 DW O2 Sample
- PP 04/24/15
- 2502176 U2 Drywell O2 Analyzer System Issue 05/18/15
- 2502695 Mispositioned Test Switch During Performance of
- DIS 1500-05
- 05/19/15
- 2506847 PMC - U2 and U3 Main Condenser Fouling 05/28/15
- 2518096 Water/Oil on U3
- TB 517' Floor 06/23/15
- 2518113 Severe Weather Safeguards Suspension 06/22/15
- 2518113 Security - Severe Weather Safeguards Suspension 06/22/15
- 2518254 What Good are Flood Barriers if Wtr Comes in thru Floor Drains 06/23/15
- 2519394 NOS ID: Resolution of A 2013 RP Audit Def. not Effective 06/25/15
- ERV 95001 Preps 06/30/15
- 2527598 FASA ID: Deficiency In Maintenance Fundamentals 07/13/15
- 2527602 FASA ID: Deficiency In Maintenance Fundamentals 07/13/15
- 2532555 UHS Insp - Calc for DGCW Pumps Based at 501 Elevation 07/24/15
- 2548876 SPC Closure and Needs
- ACE 08/31/15
- 2549747 Dreambox Failure 09/01/15
- 2549747 Dreambox 02 Failure 09/01/15
- 2551306 Rx Bldg. / Turb. 569' Elev. Interlock Door Bypassed 09/04/15
- 2557390 Clean Floor Drains are Backing Up 09/18/15
- 2559581 Clean Floor Drains Backed Up While Flushing Temporary Demin 09/23/15
- 2560103 U3 SBO Inverter Transformer Failure 09/24/15
- 2564768 Disengagement of Filters Unit 2 Spent Fuel Pool 10/02/15
- 2565610 Ejector Pit Heaters Submerged 10/05/15
- 2567011
- ACE 2548876 Rejected by
- MRC 10/07/15
- 2570579 MRule:
- 2574338 REMP Missed Samples 10/21/15
- 2578767 10
- CFR 21 Notifications not Reviewed at Dresden 10/29/15
- CK 220-58B Exceeded Admin Alarm Limit 11/06/15
- CK 220-58B Exceeded Admin Alarm Limit 11/06/15
- 2583276 D2R24 FW
- CK 0220-62B LLRT Exceeded Admin Alarm Limit 11/06/15
- 2587167 Level 1 PCE While Removing Bladder From 62B FW Check Valve 11/13/15
- 2591977 NOS ID: CA Closure Documentation not Stand Alone 11/24/15
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 2592330 REMP Sampling Issues -Detached Wire 11/25/15
- 2593333 Lane 1 AVB Loose 11/30/15
- 2593333 Security-Lane 1 AVB Loose 11/30/15
- 2596243 Unit 3 Drywell O2 Analyzer Appears to be out of Calibration 12/05/15
- 2601715 FASA (EN): Emergency Diesel Reliability 12/17/15
- 2602903
- TR-41 is Obsolete and Should be Replaced 12/20/15
- 2605048 REMP Sampling Issues 12/28/15
- 2605164 U2 517' Clean Side Floor Drains Clogged 12/28/15
- 2611686 U3 Ejector Pit is Frozen, Backup Up Drains in the Plant 01/13/16
- 2614410 RP Self-Assessment Gaps Identified 01/15/16
- 2621750 DG FASA: Obsolete Equipment Noted 02/04/16
- 2633374 Quarterly SC Meeting Summary of February 2016 02/26/16
- 2633687 NOS Maintenance Audit 02/19/16
- 2640695 NRC FOF Inspection Presentation 03/15/16
- 2640695 NRC FOF Inspection Presentation 03/15/16
- 2640697 NRC FOF Inspection Presentation 03/15/16
- 2640697 NRC FOF Inspection Presentation 03/15/16
- 2644583 IR to Document Possible Degradation of U3 DW O2 Sample
- PP 03/23/16
- 2645113 Abnormal Trend on Unit 2 DW O2 Analyzer 03/24/16
- 2652902 NOS ID Work Package Issue 04/07/16
- 2653121 MOV Limitorque Motors 04/08/16
- 2653188 2A Recirc Motor Temps Erratic 04/09/16
- 2653534 3A CCSW Pump Discharge Vavle Could not be Closed 04/10/16
- 2653730 EMD Planning Discretionary Crew Clock Reset 04/01/16
- 2653764 Hose Was Found Disconnected And Split On LIC
- 3-3541-10A 04/09/16
- 2658154 Alarm 923-5A A-4, U2 Drywell O2 Content High 04/20/16
- 2660515 Calculation DRE15-0013 Error Identified 04/25/16
- OPERATING EXPERIENCE Number Description or Title Date or Revision
- 1620074 OPEX:
- Monticello Event Requires Possible Actions at Dresden 02/12/14
- BW-14-004) 02/12/14
- AUDITS, ASSESSMENTS AND
- SELF-ASSESSMENTS Number Description or Title Date or Revision
- 1689112 Proactive Action to Ensure NPDES Sampling Performed 08/04/14
- 2388710 Dresden Susceptible to Similar NRC Violation Issued to Fermi 09/30/14
- 2478177 Evaluation Needed to Determine Proper Response of HPCI
- AOP 04/01/15
- 2506698 Need OPEX Review of Quad
- IR 2506106 05/28/15
- 2572426 Review of ICES
- 317634 Determines Dresden Vulnerability 10/17/05
- 2611812 L2
- DOA 0202-01 Gap Identified 01/13/16 2016-009-00 Loss of High Pressure Coolant Injection System Function as a Result of Failed Flow Controller Signal Converter (a 50.73 Report) 02/26/16 ICES Rpt
- 249702 Failure of Regulator In Containment Environmental Monitoring Sys. Integrator/Computational Module Computational Module 3-8541-19 (Containment Oxygen Analyzer) 06/17/11 ICES Rpt
- 307946 Rod Block Monitor Failed Quarterly Calibration Surveillance 07/17/13 ICES Rpt
- 314317 Intermediate Range Monitor Drive Motor Fuse Blown 11/16/14 ICES Rpt
- 314426 Maintenance Rule Condition Monitoring Criteria Exceeded for Intermediate Range Monitor 12/08/14 ICES Rpt
- 314742 Manual Reactor Scram Due to Transient Caused By Feed Water Level Control System Failure 01/13/15 ICES Rpt
- 315154 Automatic Reactor Scram Due to Loss of Feedwater 02/06/15 ICES Rpt
- 319999 High Radiation Sampling System Heat Trace Relay Chatter Caused by Worn Relay Contact Parts 08/29/15
- Must Know Operating Experience
- 08/26/14
- 1589739 Check-In Self-Assessment Dresden System Engineering Practices and Expectations 02/27/14
- 1589739 Dresden System Engineering Practices/Expectations 02/27/14 Maintenance Audit Report
- NOSA-DRE-14-01 03/05/14 Check-In Self-Assessment Plant Engineering Support of Work Control E-Meetings 05/05/14
- 1612032 Plant Engineering Support of Work Control E-Meetings 05/05/14
- DRAWINGS Number Description or Title Date or Revision 12E-2848G Wiring Diagram Drywell O2 Analyzer System Panel 923-5A
- AK 12E-2848M Wiring Diagram Drywell O2 Analyzer System Panel 923-5A B 12E-3848A Schematic Diagram Containment O2 Sample Selector D 12E-3848A, Sh2 Schematic Diagram Containment O2 Sample Selector A 12E-3848B Internal Wiring Diagram Containment O2 Sample Selector B B-111 Turbine Bldg Plumbing Floor Plan
- EL 517-06 Unit 2 T B-541 Turbine Bldg Plumbling Floor Plan,
- EL 517-06 Unit 3 F
- Dresden Maintenance and Test Equipment (M&TE) Process 07/31/15
- 2409231 Biennial Self-Assessment & Benchmark Program 03/31/15 Level 3 Operating Experience Utilization 10/30/15
- 2453271 NRC Inspection 71124.08, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Assessment 04/15/15
- 2478599 Engineering Safety Check-In Self-Assessment 05/15/15
- 2488514 Dresden FLS Program Check-In 09/11/15 Assessing Maintenance Fundamentals 07/17/15
- 2575235 FASA: Pre-NRC PI&R
- 02/11/16
- 2575547 Pre-NRC 71111.11 FASA 02/25/16 Exelon Emergency Diesel Generator Reliability 03/15/16
- NOSA-DRE-16-01 03/02/16
- 2521704-06 Perform a FASA Results Measurement Review 02/09/16 NOSA-
- DRE-14-05 Engineering Programs and Station Blackout Audit Report 04/07/14
- NOSA-DRE-15-05 Engineering Design Control Audit Report 08/10/15
- NOSA-DRE-15-12 Engineering Programs and Station Blackout Increased Frequency Audit Report 11/04/15
- Dresden Station T-6 Assessment No date
- CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title Date or Revision2654883 Discrepancy Noted Between ICES #
- 249702 and
- ATI 01230101-03 04/13/16
- 2655164 Reference PowerLabs Report Number is Incorrect in EACE 04/13/16
- 2656097 PI&R NRC Identified Issues 04/15/16
- 2656290 NRC Questioning U2 Recirc Dissolved O2 Indication 04/15/16
- 2659453 Clarification To
- ACE 2479781-02 Previous Events Section 04/22/16
- DBA 04/26/16
- 2661809 PI&R: ACIT
- 1204088-07 has Inaccuracy 04/27/16
- 2667267 10 CFR Part 21 Item not Reviewed at Dresden 05/09/16
- ROOT CAUSES AND APPARENT CAUSES REVIEWED Number Description or Title Date or Revision
- 1331916-06 AEER AHU Belts Came off the Sheaves 02/25/12 Apparent Cause Investigation Report (Equipment):
- 2A IAC Trip on High Element 2 Outlet Temp 05/17/14
- 1662068 Air Intrusion Into MPC #343 -
- RCE 05/19/14
- 1854476 MOV
- 2-1301-3 Stroke Length Found Longer than Expected -
- WGE 09/16/14
- 2411760 D3R23 Work Stopped on Refuel Floor After CAM Alarmed -
- ACE 11/14/14
- 2431208 Unit 2 Turbine Trip Due to Moisture Separator Hi-Hi Level (AC) 02/06/15
- 2437067 Two Reactor Scrams From A Feedwater Level Control System Failure with a Reactor Recirc Pump Runback (RC) 03/13/15
- 04/04/15
- 2562930 Unit 3 B Reactor Building Vent Radiation Monitor Fuse Failure (AC) 10/28/15
- Dresden Unit 2-2B Recirculation Pump Trip due to Inadequate 08/08/14
- ROOT CAUSES AND APPARENT CAUSES REVIEWED Number Description or Title Date or Revision Ownership/Oversight during Implementation of ASD Project
- 1622805-02 Security Document Classification (RCE) 03/24/14
- 2523462-02 LORT Requal Results (AC) 08/04/15 2502695-4 Mispositioned Test Switch During Performance of
- DIS 1500-05 (AC) 06/18/15
- 2548876-02 U2 and U3 Main Condenser Fouling (ACE) 09/11/15
- WORK ORDERS REVIEWED Number Description or Title Date or Revision
- 01484189-01 Degraded Recorder Causing Alarm 10/26/11
- 1434927 Unit 3 5712-1 Battery and Battery Charger Room HVAC a(1) Action Plan 09/21/15
- 1650033
- 2-3902, U2 Standby Coolant Supply MOV a(1) Action Plan 07/09/14
- 1710196 Clean U2 Main Condenser South Tubes with Plastic Condenser Cleaner Plugs 11/11/15 Clean Floor Drains Backing Up 03/10/162419701 AEER HVAC a(1) Action Plan 02/29/152553500 Unit 0 49-1 - Miscellaneous Sumps and Drains a(1) Action Plan 01/08/16Unit 3 SBO
- VLV 10/13/1501775920 - 01 Need Contingency Repair Work Order For
- 2-0220-62B 07/28/1501775920 - 02 Need Contingency Repair Work Order For
- 2-0220-62B 04/02/1501775920 - 05 Need Contingency Repair Work Order For
- 2-0220-62B 11/17/1501775920 - 06 Need Contingency Repair Work Order For
- 2-0220-62B 10/13/1501775920 - 07 Need Contingency Repair Work Order For
- 2-0220-62B 12/11/1401775923 - 01 Need Contingency Repair Work Order For
- 2-0220-58B 07/28/1501775923 - 06 Need Contingency Repair Work Order For
- 2-0220-58B 07/28/1501775923 - 07 Need Contingency Repair Work Order For
- 2-0220-58B 07/28/1501775923 - 08 Need Contingency Repair Work Order For
- 2-0220-58B 10/13/1501775923 - 09 Need Contingency Repair Work Order For
- 2-0220-58B 01/30/15
- WORK ORDERS REVIEWED Number Description or Title Date or Revision
- 01775923 - 10 Need Contingency Repair Work Order For
- 2-0220-58B 12/11/1401826415-01 Replace PS 3-6641-526 U3 D/G Main Bearing Low Oil Press (MB1)
- 01868032 - 01 570 TB to RXB Interlock Door Circuit Logic Reconfiguration 12/08/15
- OTHER Number Description or Title Date or Revision1434927 Unit 3 5712-1 Battery and Battery Charger Room HVAC a(1) Action Plan 09/21/15
- 2-3902, U2 Standby Coolant Supply MOV a(1) Action Plan 07/09/142419701 AEER HVAC a(1) Action Plan 02/29/152553500 Unit 0 49-1 - Miscellaneous Sumps and Drains a(1) Action Plan 01/08/162570579 Unit 3 SBO
- 2015-001 ECP Case File
- AP-913 INPO Equipment Reliability Process Description 01/04/00DRE-41511 Failure Analysis of Element, Filter, 5 Micron, for Parker P3NF Series 02/26/16DRE-48700 Failure Analysis of a GE Circuit Breaker and GE Voltage Regulator Card 06/16/11Dresden OE 1 QRT Indicator 02/01/16Dresden PE 2 Request for Engineering Changes 02/01/16Dresden PE 3 Engineering Changes in Development 02/01/16Dresden PE 4 Engineering Changes in Implementation 02/01/16Dresden PE 5 Engineering Change Closeout 02/01/16Dresden PE 6 Engineering Change Incorporation 02/01/16Dresden PE 6 Engineering Change Incorporation 03/01/16EC
- 385199 Replace Obsolete/Failed U2 FW DO Analyzer
- 2-3241-98 01/00/00EC
- 398606 Move HVAC Calculations to Supersede Status 01/00/00Function 103-1
(U3) Maintenance Rule Database:
- Station Blackout Diesel Generator
- Function 49-1 (U0) Miscellaneous Sumps and Drains
- LS-AA-1012 Semi-Annual Safety Culture Review
- TS 3.6.3.1 Primary Containment Oxygen Concentration Amendment 237/230
- UFSAR 9.3.2.6 Primary Containment Oxygen Sampling System 01A
- WR00216398 U3 Prim Containment Oxygen Analyzer 08/13/06WR00290978 Analyzer Flow Not High Enough 12/30/08
- OTHER Number Description or Title Date or RevisionWR00303847 U3 O2 Monitor Having Erratic Indication Over 24 Hours 05/11/09WR00313503 Request a WO to Replace Following Components for U3 DW O2 09/04/09WR00371883 (ASSY) U3 DW Air Sample Sys Return to Torus Upstrm
- FCV 06/21/11Meeting Minutes-Safety Culture Monitoring Panel-1st Quarter
- 2014
- Meeting Minutes-Safety Culture Monitoring Panel-3rdt Quarter 2015
- Organizational Effectiveness Survey Results
- Meeting Minutes-Safety Culture Monitoring Panel-4th Quarter 2015
- ECP Logs, 2014, 2015, 2016
- Equipment Reliability Excellence Plan
- Training Department Human Performance Improvement Plan, 1st Quarter 2016
- Training Department Human Performance Improvement Plan, 4tht Quarter 2016
- System Health Report Unit 2 EDG 4th Quarter 2015
- System Health Report Unit 2/3 EDG 4th Quarter 2015
- System Health Report Unit 3 EDG 4th Quarter 2015
- System Health Report Unit 2 SBO Diesel 4th Quarter 2015
- System Health Report Unit 3 SBO Diesel 4th Quarter 2015
LIST OF ACRONYMS
- USED [[]]
WO Work Order
WR Work Request
B. Hanson -2-
In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the
- NRC 's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS).
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,
/RA/
Jamnes Cameron, Chief
Branch 4 Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos.