IR 05000237/2023003
| ML23317A081 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/13/2023 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EA?23?087 IR 2023003 | |
| Download: ML23317A081 (1) | |
Text
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2023003 AND 05000249/2023003 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear David Rhoades:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On October 18, 2023, the NRC inspectors discussed the results of this inspection with P. Boyle, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Dresden Nuclear Power Station, Units 2 and 3.
November 13, 2023 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000237 and 05000249 License Nos. DPR19 and DPR25
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000237 and 05000249
License Numbers:
Report Numbers:
05000237/2023003 and 05000249/2023003
Enterprise Identifier:
I2023003-0051
Licensee:
Constellation Energy Generation, LLC
Facility:
Dresden Nuclear Power Station, Units 2 and 3
Location:
Morris, IL
Inspection Dates:
July 01, 2023 to September 30, 2023
Inspectors:
J. Cassidy, Senior Health Physicist
A. Muneeruddin, Resident Inspector
M. Porfirio, Illinois Emergency Management Agency
C. St. Peters, Resident Inspector
J. Steffes, Senior Resident Inspector
Approved By:
Robert Ruiz, Chief
Reactor Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.1
List of Findings and Violations
Failure to Perform Performance Response Check for Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000237,05000249/202300301 Open/Closed
[H.11] -
Challenge the Unknown 71124.08 The inspectors identified a finding of very low safety significance (Green), and an associated non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to implement procedures for control of radioactivity. Specifically, the licensee did not conduct a performance source check on a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas, as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.
Failure to Install Safety-Related Circuit Breakers in the Unit 2 Alternate Battery, a Safety-Related System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237,05000249/202300302 Open/Closed None (NPP)71152A A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion III, occurred on July 6, 2023, when it was identified that non-quality controlled, non-dedicated circuit breakers were installed in the Unit 2 125VDC alternate battery, a safety-related system.
Additional Tracking Items
Type Issue Number Title Report Section Status ED EA23087 Enforcement Action EA23087: Failure to Comply with 10 CFR Part 37 71124.08 Closed
PLANT STATUS
Unit 2 began the inspection period at full rated thermal power. On July 8, 2023, the unit was reduced to 82 percent power for control rod pattern adjustment and the unit was returned to full power the next day. On August 19, 2023, the unit was reduced to 82 percent power for control rod pattern adjustment and the unit was returned to full power the next day. On September 1, 2023, the unit was reduced to 84 percent power for control rod pattern adjustment, and the unit was returned to full power the same day. On September 2, 2023, the unit was reduced to 84 percent power for the final control rod pattern adjustment and scram solenoid pilot valve replacement; the unit was returned to full power the same day. On September 8, 2023, the unit entered coast down operations in preparation for refueling outage D2R28 and remained in that condition for the remainder of the inspection period.
Unit 3 began the inspection period at full rater thermal power. On September 1, 2023, the unit was reduced to 67 percent power for control rod pattern adjustment and turbine generator automatic voltage regulator maintenance. The unit was returned to full power operation on September 2, 2023, and remained at or near full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 high pressure coolant injection (HPCI) system on August 2-7, 2023
- (2) Unit 3 A reactor building closed cooling water on August 8-18, 2023
- (3) Unit 2 service water system on August 9-21, 2023
- (4) Unit 2 low pressure coolant injection system on August 31, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone (FZ) 8.2.1A, Unit 2 condensate pumps elev. 469', and FZ 8.2.1B, Unit 3 condensate pumps elev. 469' on July 7, 2023
- (2) FZ 11.3, Unit 2/3 circulating water pumps elev. 490', Unit 2/3 service water pumps / traveling screens elev. 509', and Unit 2/3 crib house ground floor elev. 517' on August 2, 2023
- (3) FZ 11.2.2, Unit 2 southeast corner room elev. 476' on August 3, 2023
- (4) FZ 1.1.2.1, Unit 2 torus basement elev. 476' and torus catwalk on August 3, 2023
- (5) FZ 7.0A.13/8.2.7, Unit 2 battery room elev. 549' on August 7, 2023
- (6) FZ 1.1.1.2 Unit 3 reactor building ground floor elev. 517', and FZ 1.1.1.3 Unit 3 reactor building general area elev. 545' on August 22, 2023
- (7) FZ 11.1.3, Unit 3 HPCI pump room elev. 476', and FZ 11.1.2 Unit 3 southeast corner room elev. 476' on August 30, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on August 10, 2023.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the: Unit 2 reactor building mezzanine elevation 545' Unit 3 reactor building mezzanine elevation 545'
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during rod pattern adjustment in support of end of cycle operations on July 8-9, 2023
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed crew performance in the simulator during scenarios LT SEG 2301A and LT SEG DOA 440006, on August 9, 2023
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Radiation monitoring
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 2 station blackout (SBO) diesel maintenance window from June 26-29, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Emergent plant challenges associated with grassing event at the ultimate heat sink, on July 19, 2023
- (2) Station risk during elevated outside temperatures, week of August 21-25, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 3 battery room A/C compressor and fan breaker tripped, as documented in CR 4688851
- (2) Unit 3 SBO diesel generator output breaker failed to close during testing as documented in CR 4548341
- (3) Unit 3 HPCI check valve 32301-7 will not open < 90 ft/lbs torque as documented in CR 4535439
- (4) FLEX hose trailer 3 not tied down as documented in CR 4694915 (5)2/3 reactor building and chimney particulate, iodine, and noble gas monitor system following sample results as documented in CR 4695055
- (6) Cardox fire suppression system functionality determination following leak identification as documented in CR 4695609
- (7) Unit 2 emergency diesel generator (EDG) failed to start from the control room as documented in CR 4696270 (8)
===24115-500, Fire Protection H2 Seal Unit Deluge System SV, valve closed without required fire watch established as documented in CR 4696111
- (9) Increase in Unit 2 drywell floor drain leakage as documented in CR 4701027
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary or permanent modifications:
- (1) TCC202302-037, U2 digital electrohydraulic control (DEHC) axial thrust bearing wear detector probe #1 forced value entered
- (2) TCC202303-003, Install an auxiliary oil tank in the drywell to provide ability to add oil to the 3B recirculation pump motor lower bearing
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)
- (1) Unit 3 station blackout (SBO) diesel run following breaker replacement, on July 15, 2023
- (2) Unit 3 B fuel pool cooling pump run following replacement of 31901-108B, 3B fuel pool cooling pump suction, on August 25, 2023
- (3) Unit 2 EDG modified run following replacement of control switch 26640-48 on August 28, 2023
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) Unit 3 HPCI system test, work order 5382243
- (2) Unit 2 HPCI system test, work order 5379811
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)2/3 diesel generator cooling water pump test, work order
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling,
Storage, & Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
- (1) Interim Radwaste storage facility
- (2) Unit 1 Sealand yard
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Resins associated with the ALPS system
- (2) Bags and barrels in the radwaste storage bins
Waste Characterization and Classification (IP Section 03.03) (4 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) ALPS Cation Resin
- (2) DAW Smears
- (3) Fuel Pool Resin
- (4) ALPS Anion Resin
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of radioactive shipment DW23026
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) DW22020; Resin Cask; LSA-II
- (2) DW22010; Fuel Pool Cleanup Resin; LSA-II
- (3) DW23001; DAW Trash; LSA-II
- (4) DW23020; ALPS Resin; LSA-II
OTHER ACTIVITIES-BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
- (2) Unit 3 (July 1, 2022 through June 30, 2023)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
- (2) Unit 3 (July 1, 2022 through June 30, 2023)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
- (2) Unit 3 (July 1, 2022 through June 30, 2023)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (November 1, 2022 through May 31, 2023)
- (2) Unit 2 (November 1, 2022 through May 31, 2023)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) November 1, 2022 through May 31, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) November 1, 2022 through May 31, 2023 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample 1 Partial)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Non-safety-related components installed in the Unit 2 125V DC alternate battery feed circuit breakers, which require safety-related components, as documented in CR 4688989 (2)
(Partial)2/3 emergency diesel generator output breaker opened unexpectedly during surveillance run
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement:
Violation: Dresden Nuclear Power Station, Unit 2, Renewed Facility Operating License, section 2.E requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection plan requires compensatory measures are established when fire protection SSCs are impaired. Procedure CCAA211, Fire Protection Program, Revision 9, details the fire protection and prevention administrative control procedures are established to govern the handling and use of transient combustible materials, maintain housekeeping to minimize fire hazards, control cutting and welding operations by use of a permit system, control the use of temporary heating sources, control the impairment of fire protection SSCs, and post fire watches. Procedure OPAA201007, Fire Protection System Impairment Control, Revision 2, provides instructions for establishing and performing compensatory measure fire watch inspections. Last, procedure OPAA108101, Control of Equipment and System Status, Revision 18, addresses the identification of temporary equipment conditions and status via the Abnormal Component Position Sheets (ACPS) and Equipment Status Tags.
Contrary to the above, on August 4, 2023, the licensee failed to implement provisions of the approved fire protection program. Specifically, the site terminated the continuous fire watch previously established when valve 24415-500, Fire Protect H2 Seal Unit Deluge System SV, was taken to the closed position. The fire watch was terminated without restoring the valve to the open position. This is contrary to the guidance and requirements established in the procedures requiring a continuous fire watch until the valve was restored to its normal position, open.
Significance/Severity: Green. Specifically, the inspectors determined that this finding screened to Green because the degraded or non-functional detection or fixed suppression system did not adversely affect the ability of the system to protect any equipment important to safe shutdown.
Corrective Action References: AR 4696111, Impairment closed out improperly Failure to Perform Performance Response Check for Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000237,05000249/202300301 Open/Closed
[H.11] -
Challenge the Unknown 71124.08 The inspectors identified a finding of very low safety significance (Green), and an associated non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to implement procedures for control of radioactivity. Specifically, the licensee did not conduct a performance source check on a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.
Description:
Licensee procedure RPAA700, Controls for Radiation Protection Instrumentation establishes the administrative controls for radiation protection instrumentation maintained for use at the Dresden Station. Step 4.9.5 describes the source response checks for portable survey instruments and stationary GM friskers and states Except as noted below, short-term issued portable survey meters and stationary GM friskers shall be performance checked daily or prior to use, whichever is less frequent. Step 4.9.5.6 (a defined exception to the daily frequency) states, Portable survey instruments and stationary GM friskers may be performance source checked weekly in accordance with this section, provided they are not used for critical surveys. Procedure RPAA700, Controls for Radiation Protection Instrumentation Step 2.9 defines a critical survey as Surveys of personnel or materials for release for unrestricted use On July 3, 2023, the personnel contamination monitor at the radwaste control room was removed from service. This monitor surveyed personnel leaving the radiologically controlled area (RCA) into the unrestricted area. Removing the personnel contamination monitor from service required personnel to use a stationary hand-held frisker to perform the critical radiological surveys necessary to leave the RCA. Consequently, the performance source check frequency should have changed from weekly to daily for this stationary frisker when it was used for these critical surveys.
On July 17, 2023, the frisker successfully passed the performance source check.
On July 19, 2023, the inspectors identified that frisker appeared non-responsive to background radiation with only an occasional click, with long intervals of silence. It was explained that the area was low background. However, when radiation protection personnel conducted a performance source check the asfound condition of the instrument was not within acceptance criteria for the response check.
Corrective Actions: The licensee changed the performance source check frequency for this frisker, and other friskers located at RCA exit points, to a daily frequency. Additionally, the licensee performed radiological survey 2023197910 of the area likely impacted (radwaste control room) by this performance deficiency and demonstrated radioactive contamination was not identified in the unrestricted area.
Corrective Action References: AR 04691430
Performance Assessment:
Performance Deficiency: The licensee did not conduct a performance source check a frisker used to perform critical surveys of personnel for release from the radiologically controlled area to unrestricted areas as required by procedure RPAA700, Controls for Radiation Protection Instrumentation.
Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. The performance deficiency had the potential to lead to a more significant radiation safety concern because of an ineffective radiation program barrier. Specifically, when response checked, the asfound condition of the instrument was not within acceptance criteria for the response check.
This is Example 6.b from Inspection Manual Chapter 0612 Appendix E Examples of Minor Issues.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, because:
- (1) it did not involve aslow-asreasonably-achievable (ALARA)planning or work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, when radiation protection removed the personnel contamination monitor from service the risk from potentially inadequate surveys from the inferior replacement equipment was not recognized, evaluated, or managed.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, states in part, written procedures shall be established, implemented and maintained covering activities contained in Regulatory Guide 1.33, Revision 2, Appendix-A, dated February 1978.
NRC Regulatory Guide 1.33, Appendix A, Section 7 addresses Procedures for Control of Radioactivity, and Section e. Radiation Protection Procedures,
- (4) addresses Contamination Control.
Licensee procedure RPAA700 Controls for Radiation Protection Instrumentation, Revision 09, provides requirements for instrumentation used to survey potentially contaminated personnel and materials before being released to unrestricted areas (a critical survey). Step 4.9.5 requires stationary GM friskers used for critical surveys shall be performance source checked daily.
Contrary to the above, between July 3 and July 19, 2023, the licensee failed to implement step 4.9.5 of procedure RP-AA-700. Specifically, the licensee failed to conduct daily performance source checks as required for a frisker used for critical surveys as required by the procedure.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement Discretion Enforcement Action EA23087:
Failure to Comply with 10 CFR Part 37 71124.08
Description:
On April 27, 2016, the licensee was issued NRC Inspection Report Nos. 05000237/2016405 and 05000249/2016405, which documented a licensee-identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for enforcement discretion as described in Enforcement Guidance Memorandum (EGM)14001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.
Subsequently, the inspectors reevaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14001.
Corrective Actions: As specified in EGM 14001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action.
Enforcement:
Violation: On April 27, 2016, a violation of 10 CFR Part 37 was documented in Dresden Inspection Report Nos. 05000237/2016405 and 05000249/2016405. The inspectors determined that the previously identified violation remains.
Basis for Discretion: This violation met the criteria for enforcement discretion as described in Enforcement Guidance Memorandum (EGM) 14001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.
Failure to Install Safety-Related Circuit Breakers in the Unit 2 Alternate Battery, a Safety-Related System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000237,05000249/202300302 Open/Closed None (NPP)71152A A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion III, occurred on July 6, 2023, when it was identified that non-quality controlled, non-dedicated circuit breakers were installed in the Unit 2 125VDC alternate battery, a safety-related system.
Description:
Around 1978, the 125V DC distribution panel number 5 and two GE model AK circuit breakers were originally installed in the Unit 1 HPCI building for the U1 HPCI 125V DC battery and charger. The original design for the components was U1 Division I Engineered Safety Feature, meaning the components were classified as safety-related (SR). Controlled drawings, on the record, identified nuclear safety-related equipment is shown on this drawing, which implied that SR quality equipment was procured and installed around this timeframe.
In the 1990s, a modification, SR modification M120-90013A 125 vdc Alternate Battery Installation, was approved for the installation of a new U2 safety-related 125V DC alternate battery. This installation was to be in the U1 HPCI building, as well as SR cable connections from distribution panel number 5 to the U2 Turbine Building SR 125V DC Bus 2A1. The modification repurposed the two SR GE model AK circuit breakers that were previously installed for the U1 HPCI 125V DC battery and charger to be used now for the new U2 alternate battery and charger. In 1991, a letter was issued from the NRC to Dresden Nuclear Station to follow up on discussions regarding the 125V DC alternate batteries. The letter included a description of the 125 VDC System design, an overview of the alternate 125 VDC battery design and installation, an overview of the Technical Specification changes to be proposed, and a schedule for submittal of these amendments, and the controls which will be imposed on any alternate battery usage prior to receipt of the amended Technical Specifications. The letter discussed the ability of the alternate battery to be put into service when the main battery is unavailable. Classification was established and controlled in plant documentation.
In 2003, the originally installed AK25 circuit breaker, Equipment Part Number (EPN)283125-5AC2, failed to close and a vendor overhaul was performed. The installed circuit breakers did not have a catalog identification number associated with them. The site planned to procure a new circuit breaker to install while the failed circuit breaker was being overhauled. A Quality Level 4 (QL4), or non-safety-related, catalog identification number was created. The work order created to install a new circuit breaker classified the work as non-safety related (NSR), and a NSR breaker was installed on March 26, 2004. This was a missed opportunity, as the correct quality level for the component should have been QL1, safety related.
In 2006, the site underwent a 16-year breaker overhaul for the original SR AK50 circuit breaker, EPN 283125-5AC1. In the work order for this overhaul, the circuit breaker was incorrectly noted to be a non-safety-related, augmented quality component, or QL3. This was another missed opportunity for the site to identify the circuit breakers were supposed to be safety related, QL1 components.
In 2011, an engineering change request (ECR) was done to add a safety classification to the U2 125V DC alternate battery circuit breakers in the Passport computer system due to the information being blank. The ECR noted the components were classified as safety-related, seismic class 1E components. In 2012, the ECR was completed with the safety classification information being filled in, but no reviews were conducted to look at work performed while the information in Passport was incomplete. This resulted in the site not being aware of the non-safety-related circuit breakers being installed.
In 2023, the site was preparing for the 16-year preventative maintenance on the Unit 2 125V DC alternate battery circuit breakers; it was discovered that the currently installed circuit breakers were non-safety-related components. A condition report was written, and the site performed a corrective action program evaluation (CAPE) to determine the cause of non-safety-related components being installed and maintained for a safety-related function.
The inspectors reviewed the condition report, CAPE, relevant associated documentation, and held discussions with the licensee staff to better understand the time frame and history of the circuit breakers and the U2 125V DC alternate battery. The inspectors questioned if the ECR in 20112013 would have involved reviewing the currently installed components at that time to see if they matched the missing safety classification. The site stated that nothing specific would have prompted that review in the engineering change request process. The licensee informed the inspectors they would be procuring QL1 circuit breakers to install during the planned 16-year preventative maintenance scheduled for September 2023.
Corrective Actions: Corrective actions included, but were not limited to, the site conducting a CAPE and replacement of the non-safety-related circuit breakers with safety-related circuit breakers on September 15, 2023.
Corrective Action References: CR 4688989, U2 125VDC Alt Battery Feed Circuit Breakers, SR Components Required
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to ensure safety-related circuit breakers were installed in the Unit 2 alternate battery, a safety-related system in accordance with 10 CFR 50 Appendix B, Criterion III, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This determination was informed by IMC 0612, Appendix E, example 5.c, due to non-safety-related components, circuit breakers, being installed in the plant and the safety-related system, Unit 2 125 VDC alternate battery, returned to service.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered yes to question A1 in Exhibit 2 - Mitigating Systems Screening Question. This resulted in the issue screening to green.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.
Contrary to the above, from March 26, 2004, to July 6, 2023, the licensee failed to review for suitability of application of parts essential to the safety-related functions of the Unit 2 alternate battery. Specifically, the licensee found non-safety-related circuit breakers were installed when safety-related components were required to be installed in the Unit 2 alternate battery.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 18, 2023, the inspectors presented the integrated inspection results to P. Boyle, Site Vice President, and other members of the licensee staff.
- On July 21, 2023, the inspectors presented the radiation protection inspection results to C. Joseph, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
M22
Diagram of Service Water Piping
EZ
Drawings
M29
Diagram of Low Pressure Coolant Injection Piping, Sheet 1
CR
Drawings
M347
Diagram of Reactor Feed Piping
CK
Drawings
M51
Diagram of High Pressure Coolant Injection Piping
CX
Procedures
DOP 1500E1
Unit 2 Low Pressure Coolant Injection and Containment
Cooling Service Water Electrical Checklist
Procedures
DOP 1500M1
Unit 2 Low Pressure Coolant Injection and Containment
Cooling Valve Checklist
Procedures
DOP 2300M1/E1
Unit 2 High Pressure Coolant Injection System Checklist
Procedures
DOP 3700M2/E2
Unit 3 RBCCW System Checklist
Procedures
DOP 3900E1
Unit 2(3) Service Water and Screen Wash System Electrical
Checklist
Procedures
DOP 3900M1
Unit 2/3 Service Water and Screen Wash Valve Checklist
Procedures
DOP 3900M2
Unit 2 Emergency Room Coolers Valve Checklist
Corrective Action
Documents
4698552
4.0 Critique Crew 5 Q3 Announced Fire Drill
08/25/2023
Fire Plans
100 Prefire Plan
Master Legend
Dresden Generating Station Pre-Fire Plan
Fire Plans
101 U2RB1
Unit 2 Torus Basement Elevation 476' and Torus Catwalk
Fire Plans
103 U2RB3
Unit 2 Southeast Corner Room Elev. 476'
Fire Plans
20 U3RB23
FZ 1.1.1.2 Unit 3 Rx Ground Floor Elev. 517'
Fire Plans
24 U3RB26
FZ 1.1.1.3 Unit 3 General Area Elev. 545'
Fire Plans
133 U2TB36
FZ 8.2.1A Unit 2 Condensate Pumps Elev. 469'
Fire Plans
151 U2TB53
Unit 2 Battery Room Elev. 549'
Fire Plans
157 U3TB68
FZ 8.2.1B Unit 3 Condensate Pumps Elev. 469'
Fire Plans
196 Circ PPs-124
FZ 11.3 Unit 2/3 Circulating Water Pumps Elev. 490'
Fire Plans
197 SW PPs-125
FZ 11.3 Unit 2/3 Service Water Pumps / Traveling Screens
Elev. 509'
Fire Plans
198 U2/3 CH126
FZ 11.3 Unit 2/3 Crib House Ground Floor Elev. 517'
Miscellaneous
Fire Drill Scenario
204
Diesel Generator Fire (IEMA Building)
08/10/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
118 U3RB21
FZ 11.1.2 Unit 3 Southeast Corner Room Elevation 476'
Procedures
119 U3RB22
FZ 11.1.3 Unit 3 High Pressure Coolant Injection Pump
Room Elevation 476'
Engineering
Changes
390874
4KV Switchgear Internal Flood Barrier Protection Risk
Insight - Enhancement Dash Buses 331 and 341
Engineering
Changes
393162
4KV Switchgear Internal Flood Barrier Protection Risk
Insight - Enhancement Dash Buses 231 and 241
Miscellaneous
DRPSA012
Dresden Internal Flood Evaluation Summary and Notebook
Procedures
NFAB720F-1
Control Rod Sequence Review and Approval Sheet
07/05/2023
Procedures
NFAB720F-5
Special Maneuver Rod Move Sheet Sequence
ID: D228019
07/05/2023
Procedures
ReMA Plan
D228019
D2C28 End of Cycle Rod Pull - 9D and 9B Array
07/03/2023
Corrective Action
Documents
4442021
Unexpected Alarm 9033 C3, Isolation Condenser Vent
Monitor Downscale
08/22/2021
Corrective Action
Documents
4551062
Unexpected Alarm 9023 B3 Isolation Condenser Vent Rad
Hi
01/29/2023
Corrective Action
Documents
4676867
Unexpected Alarm 9033 F1 Area Rod Monitor Downscale
05/09/2023
Corrective Action
Documents
4678267
Unexpected Alarm 9033 F1 Area Rad Monitor Downscale
05/15/2023
Corrective Action
Documents
4681722
MCR Nuisance Alarm: 9023 B3 Isolation Condenser Vent
Rad HI
05/31/2023
Miscellaneous
Radiation Monitor System Health Report
Miscellaneous
TS&R 31803-30, ARM 30 Off Gas Filter Building Spurious
Alarms
05/15/2023
Procedures
DIS 130004
Isolation Condenser Vent Radiation Monitor Functional
Calibration and Operational Checks
Work Orders
233135
EWP Mechanical Maintenance 12 Year Preventative
Maintenance 2B Station Blackout Diesel Generator,
Replace Air Start FLEX Hoses
06/26/2023
Work Orders
233234
Unit 2 12Year Preventative Maintenance Replace Starting
Air Motor FLEX Hoses on Station Blackout
06/26/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
1638572
Unit 2 8Year Preventative Maintenance Calibration Station
Blackout Immersion Heater Temperature Switch 26620-
119B
06/27/2023
Work Orders
21931
Electrical Maintenance 2Year Preventative Maintenance
Station Blackout Diesel Generator Electrical Inspection
06/29/2023
Work Orders
26475
EWP Unit 2 2Year Preventative Maintenance Station
Blackout Diesel Generator Mechanical Maintenance
Inspection
06/29/2023
Work Orders
5181428
Unexpected Alarm 9033 C3, Isolation Condenser Vent
Monitor Downscale
2/14/2021
Work Orders
276782
IMD TSR 2B RBV Vent Rad Monitor
07/16/2022
Work Orders
5371795
Rework, EWP Replace 3B RBV Stack Sample Pump
Work Orders
5372150
TS&R U2 IC Vent Rad Monitor Nuisance Alarms
06/05/2023
Corrective Action
Documents
4697778
U2 Circ Water Pump Bearing Temperatures
08/22/2023
Corrective Action
Documents
4698205
U3 Circ Water Pump Motor Bearing Temps Peaking Above
PPC Setpoint
08/24/2023
Corrective Action
Documents
4698424
Unexpected Alarm 9232 C2, TR81 TR83 TR86 Major
08/24/2023
Miscellaneous
Workweek Highlights - DRESDEN Station Week of 0821-
08/25/2023
Miscellaneous
Augmented Operator Round Points
08/23/2023
Miscellaneous
DAN 902(3)-6 E9
RFP Vent Exhaust Air Temp Hi
Miscellaneous
DAN 9322 C2
TR81 TR83 TR86 Major
Procedures
OPDR108111-
1001
Hot Weather Strategy
Procedures
OPDR108111-
1006
Intake Blockage Station Response
Corrective Action
Documents
4535439
HPCI Check Valve 32301-7 Will Not Open < 90 ft/lbs.
11/08/2022
Corrective Action
Documents
4688851
39400-121/5 U3 Battery Room A/C Compressor & Fan
Breaker Tripped
07/05/2023
Corrective Action
4694915
FLEX Hose Trailer 3 Not Tied Down
08/06/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Corrective Action
Documents
4696111
Impairment Closed Out Improperly
08/12/2023
Corrective Action
Documents
Resulting from
Inspection
4694745
Time Critical Action 16 Paperwork Error
Corrective Action
Documents
Resulting from
Inspection
4699214
NRC Questions on CCDR118
08/29/2023
Engineering
Evaluations
350673
Effects of Elevated Temperatures on Unit 3 Station
Batteries
Procedures
660006
Powering Unit 3 4 Kilovolt Buses Via the Station Blackout
Diesel Generator 3
Procedures
CCAA211
Procedures
CCDR118
Site Implementation of Diverse and Flexible Coping
Strategies (FLEX), Spent Fuel Pool Instrumentation (SFPI),
and Hardened Containment Vent System (HCVS) Program
Procedures
DGA12
Procedures
DOP 660005
Powering Unit 2 4 Kilovolt Buses Via the Station Blackout
Diesel Generator 2
Procedures
DOS 001047
Operations Monthly FLEX Inspections
Procedures
DOS 230004
HPCI Testable Check Valve Manual Full Stroke Operability
Test
Procedures
OPAA102106
Operator Response Time Validation Sheet
Procedures
OPAA108101
Abnormal Component Position Sheet (ACPS)
Procedures
OPAA201007
Fire Protection System Impairment Control
Work Orders
5096300
QTR/CSD IST HPCI Test Injection Check Valve Operability
Test Surveillance
11/07/2022
Work Orders
530804007
OP PMT Perform as Left Seat Leak Test Per DOS 710006
11/13/2022
Work Orders
530804008
OP PMT IST HPCI Test Injection Check Valve
230-7 Full Stroke
11/13/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Changes
638300
Temporary Aux Oil Reservoir with Remote Oil Fill for 3B
Reactor Recirculating Pump Motor Lower Bearing
Engineering
Changes
638300
Temporary Aux Oil Reservoir with Remote Oil Fill for 3B
Reactor Recirculating Pump Motor Lower Bearing
Engineering
Changes
638300
Temporary Aux Oil Reservoir with Remote Oil Fill for 3B
Reactor Recirculating Pump Motor Lower Bearing
Engineering
Changes
639377
Temporary Force Unit 2 DEHC Logic Point for Axial Position
Probe
Procedures
CCAA112F-03
Temporary Configuration Change (TCC) Installation and
Removal Authorizations
Procedures
LSAA104
Exelon 50.59 Review Process
Corrective Action
Documents
4689928
U3 SBO Would Not Synchronize to Bus 33
07/11/2023
Corrective Action
Documents
4698273
Unexpected Alarm: 9034 G24 Fuel Pool PP Trip
08/24/2023
Corrective Action
Documents
4698754
4.0 Critique for 3B Fuel Pool Cooling Pump Trip on 8/24/23
08/27/2023
Corrective Action
Documents
Resulting from
Inspection
4689636
NRC Question: 2/3 Emergency Diesel Generator Cooling
Water Pump InService Testing Work Order 5354595
07/10/2023
Corrective Action
Documents
Resulting from
Inspection
4690019
NRC ID: Documentation for DOS 660008 Incomplete
07/12/2023
Procedures
DOS 662007
SBO Unit 2 (3) Diesel Generator Surveillance Tests
Work Orders
538248501
EM EWP Breaker Swap Cubicle 3 at Bus 71 (Feed to Bus
33)
07/21/2023
Work Orders
5391951
U2 EDG Control Switch Contacts Need to be Burnished
08/28/2023
Work Orders
5394386
IMD replace 31901-108B (3B Fuel Pool Cooling Pump
Suction)
08/25/2023
Corrective Action
Documents
Resulting from
NRC ID: Inaccurate Frisking Instructions
07/19/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
Corrective Action
Documents
Resulting from
Inspection
NRC Identified: Frisker Probe Found Broken
07/19/2023
Miscellaneous
Dresden Generating Station Part 37 Security Plan for the
Protection of Category 1 and Category 2 Quantities of
Radioactive Material
Miscellaneous
DRE23001
Leak Test Exemption for Ni63 Sources Used in Explosive
Monitors at Dresden
08/07/2023
Miscellaneous
MA001122
Entry Scan 4 User Manual
Miscellaneous
MA001153
Itemiser3 Enhanced User Manual
Miscellaneous
N-AN-
RP10CFR37CBT
Exelon 10 CFR Part 37, Physical Protection of
Category 1 and Category 2 Quantities of Radioactive
Material
Miscellaneous
TBE Sample ID
L955087
Waste Stream Review and Scaling Factor
Report - ALPS Cation Resin
07/21/2021
Miscellaneous
TBE Sample ID
L955081
Waste Stream Review and Scaling Factor Report - DAW
Smears
11/19/2021
Miscellaneous
TBE Sample ID
L955083
Waste Stream Review and Scaling Factor
Report - Fuel Pool Resin
10/04/2021
Miscellaneous
TBE Sample ID
L955086
Waste Stream Review and Scaling Factor
Report - ALPS Anion Resin
01/11/2022
Procedures
RPAA700
Controls for Radiation Protection Instrumentation
Procedures
RPAA800
Control, Inventory, and Leak Testing of Radioactive Sources
Self-Assessments AR 46722302
Radioactive Solid Waste Processing and Radioactive
Material Handling, Storage, and Transportation
06/30/2023
Shipping Records
DAW23020
Shipping Papers; ALPS Resin
06/06/2023
Shipping Records
DW22010
Shipping Papers; Fuel Pool Cleanup Resin
06/21/2022
Shipping Records
DW22020
Shipping Papers; RWCU Resin
08/04/2022
Shipping Records
DW23001
Shipping Papers; DAW Trash
2/16/2023
Work Orders
Quarterly Radwaste Facility Container Inspection
05/02/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71151
Miscellaneous
MSPI Heat Removal Systems Prepared Data Package
07/01/2023-
06/30/2023
71151
Miscellaneous
MSPI Residual Heat Removal Systems Prepared Data
Package
07/01/2023-
06/30/2023
71151
Miscellaneous
MSPI Cooling Water Systems Prepared Data Package
07/01/2023-
06/30/2023
71151
Miscellaneous
LSAA2090
Monthly Data Elements for NRC ROP Indicator - RCS
Specific Activity
various
71151
Miscellaneous
LSAA2150
Monthly Data Elements for NRC ROP
Indicator - RETS/ODCM Radiological Effluent Occurrences
various
71151
Procedures
ERAA2002
System and Equipment Health Monitoring
71151
Procedures
ERAA2008
Mitigating Systems Performance Index (MSPI) Monitoring
and Margin Evaluation
71151
Procedures
LSAA2200
Mitigating System Performance Index Data Acquisition and
Reporting
Corrective Action
Documents
4332151
Strengthen Procedures Involving Torquing
04/02/2020
Corrective Action
Documents
4360154
Procedure Revisions Required - Corporate Torque High
Intensity Team Actions
07/31/2020
Corrective Action
Documents
4551179
2/3 EDG Output Breaker Trip
01/30/2023
Corrective Action
Documents
4688989
U2 125VDC Alt Battery Feed Circuit Breakers,
SR Components Required
07/06/2023
Corrective Action
Documents
4691063
U2 Extent of Condition Review from IR 4551179
07/17/2023
Corrective Action
Documents
4691067
U3 Extent of Condition Review from IR 4551179
07/17/2023
Corrective Action
Documents
4692803
U2 SBO Banana Jack Extent of Condition Walkdown
07/26/2023
Corrective Action
Documents
4692804
U3 SBO Banana Jack Extent of Condition Walkdown
07/26/2023
Corrective Action
Documents
4701304
Low Resistance Readings During Breaker Inspection
09/08/2023
Corrective Action
PIAA120
Issue Identification and Screening Process
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Corrective Action
Documents
Resulting from
Inspection
4687009
NRC Question: 2/3 EDG Banana Jacks
06/27/2023
Engineering
Changes
387004
Add Safety Classification for U2 125 VDC Alt Batt/Chgr to
Bus Breaker
(EPN 283125-5AC1, Component S35)
04/30/2013
Miscellaneous
NOAA10
Quality Assurance Topical Report (QATR)
Procedures
CCAA304
Component Classification
Procedures
DIP 210028
Banana Jack Installation
Procedures
DIP 210028
Banana Jack Installation
Procedures
PIAA125
Corrective Action Program (CAP) Procedure
Work Orders
1785276
D2 4Y TSNC 125V Sta Main Batt Modified Performance
Test
09/09/2019
Work Orders
4665278
D2/3 10 Year EDG Time Delay Relay (TDR3) Replacement
03/28/2019
Work Orders
509970
Replace Breaker for 125VDC Alt Chgr
03/25/2004
Work Orders
5387993
U2 SBO Banana Jack Extent of Condition Walkdown
08/09/2023
Work Orders
5387995
U3 SBO Banana Jack Extent of Condition Walkdown
08/09/2023
Work Orders
774334
D2 16Y Breaker Overhaul 125 Alt Tie Bkr
07/19/2006
Work Orders
N-C0057
Torque Requirements
2