IR 05000237/2019004

Integrated Inspection Report 05000237/2019004 and 05000249/2019004

ML20030A139
Person / Time
Site:	Dresden
Issue date:	01/29/2020
From:	Dave Hills NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019004
Download: ML20030A139 (41)

Text

ary 29, 2020

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2019004 AND 05000249/2019004

Dear Mr. Hanson:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On January 10, 2020, the NRC inspectors discussed the results of this inspection with Mr. P. Karaba, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

Five findings of very low safety significance (Green) are documented in this report. Five 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.

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. 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,

/RA/

David E. Hills, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000237 and 05000249 License Numbers: DPR-19 and DPR-25 Report Numbers: 05000237/2019004 and 05000249/2019004 Enterprise Identifier: I-2019-004-0062 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Inspection Dates: October 01, 2019 to December 31, 2019 Inspectors: J. Corujo-Sandin, Senior Resident Inspector M. Domke, Reactor Inspector G. Edwards, Health Physicist R. Elliott, Resident Inspector T. Go, Health Physicist R. Murray, Senior Resident Inspector A. Nguyen, Senior Resident Inspector n C. Phillips, Project Engineer M. Porfirio, Illinois Emergency Management Agency A. Shaikh, Senior Reactor Inspector P. Smagacz, Resident Inspector C. St. Peters, Reactor Engineer L. Torres, Illinois Emergency Management Agency Approved By: David E. Hills, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Dresden Nuclear Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Identify and Control Hot Work Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71111.05Q NCV 05000237/2019004-01 Presence Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.c, for the licensees failure to establish, implement, and maintain Fire Protection Program procedures which ensure fire prevention for hot work. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work," Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Inaccurate and Incomplete Post Maintenance Testing Documentation for Containment Isolation Valve 2-1301-2 Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.1] - 71111.19 NCV 05000237/2019004-02 Identification Open/Closed On November 12, 2019, the inspectors identified a Green finding and associated non-cited violation when the licensee failed to have acceptance criteria for testing containment isolation valves per Technical Specification Surveillance Requirement 3.6.1.3.5, in accordance with 10 CFR 50, Appendix B, Criterion V, and identify and document the action taken in regard to a deficiency in a quality record in accordance with 10 CFR 50, Appendix B, Criterion XVII.

Failure to have Appropriate Installation Procedure for Relief Valve 2-4899-72 Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.19 Systems NCV 05000237/2019004-03 Open/Closed On November 14, 2019, a self-revealed Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings," was identified when the licensee failed to have an appropriate procedure for the installation of the Unit 2 containment cooling heat exchanger shell side relief valve.

Failure to Survey for Work Conducted in a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.14] - 71124.01 Radiation Safety NCV 05000249,05000237/2019004-04 Conservative Open/Closed Bias A self-revealed finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General was identified by inspectors when the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507' Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Failure to Positively Control a Door That Granted Access to a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.8] - 71124.01 Radiation Safety NCV 05000237/2019004-05 Procedure Open/Closed Adherence A self-revealed finding of very low safety significance (i.e. Green) and an associated NCV of 10 CFR 20.1601 (a)(3) was identified by inspectors when the licensee failed to lock and demonstrate positive control over a door that is the access point to an area having general area dose rates of approximately 3000 mrem/hour at 30 cm from the radiation source.

Additional Tracking Items None.

PLANT STATUS

Unit 2 began the inspection period in coast down to prepare for refueling outage D2R26.

The unit came offline on October 27, 2019, to commence D2R26. The refueling outage ended and the unit synchronized to the grid on November 15 and returning to full power on November 16, 2019. On December 9, 2019, the unit was down powered to 22 percent due to unidentified reactor coolant system leakage and returned to full rated thermal power on December 11, 2019. On December 14, 2019, power was reduced to 62 percent for a rod pattern adjustment and returned to full rated power the next day. On December 22, 2019, operators reduced electrical power to 65 percent for a complete rod pattern adjustment and returned to full power the same day. On December 28, 2019, the unit was down powered for a forced outage (D2F59) to repair a generator hydrogen leak and remained in that condition for the remainder of the inspection period.

Unit 3 began the inspection period at full power. On December 3, 2019, the unit was down powered to 82 percent for rod pattern adjustments and 3D3 feed water heater leak repair. The unit returned to full rated thermal power on December 7, 2019, and operated there 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 plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme cold temperatures and conditions that could adversely affect the ultimate heat sink such as ice blockages and frazil ice

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 shutdown cooling on October 28 - 30, 2019

(2) Unit 2 fuel pool cooling with alternate decay heat removal on November 5, 2019

(3) Unit 2 emergency diesel generator on November 5, 2019

(4) Unit 2 AC power while on 4kv cross ties during October 30 through November 5, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Zone (FZ) 1.2.2, U2 Drywell Primary Containment, elevation 517 on November 1, 2019

(2) FZ 8.2.5B, U2 Low Pressure Heater Bay, elevation 517 on October 31, 2019

(3) FZ 8.2.5A, U2 High Pressure Heater Bay, elevation 517 on November 7, 2019

(4) FZ 11.3, Unit 2/3 Circulating Water Pumps, elevation 490'; Unit 2/3 Service Water Pumps / Traveling Screens, elevation 509'; and Unit 2/3 Crib House Ground Floor, elevation 517' on December 30, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) 2/3 Cribhouse (Submersible Emergency Diesel Generator Cooling Water Pumps)

===71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) ===

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 30, 2019 to November 6, 2019:

03.01.a - Nondestructive Examination and Welding Activities.

• Volumetric, manual ultrasonic examination of low pressure coolant injection system piping welds 2/1/1519-16/16-K5 and 2/1/1519-16/16-K6, ASME category R-A, items R1.11/R1.16 located in the drywell

• Volumetric, manual ultrasonic examination of reactor recirculation system welds 2/1/0201A-22/L1/L2 and 2/1/0201A-28/PD1A/L2 and 2/1/0201A-22/L2-D17 and 2/1/0201A-28/PD1A-D15, augmented IGSCC category D, located in the drywell

• Surface, magnetic particle examination of low pressure coolant injection heat exchanger support 2-1503-B located in the reactor building

• Pressure boundary weld review for jet pump instrumentation nozzle overlay weld for weld number 6 designated JP1A/N20A-6

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from April through May 2019

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) The inspectors observed and evaluated licensed operator performance in the Control Room during Plant Shutdown for Refueling Outage, D2R26, on October 25 and October 27, 2019, and Plant Startup on November 14 - 15, 2019

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Fuel Pool Radiation Monitor (a)(1) AR4276469

(2) Control Rod Drive System WO 04768029-03

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 2 Yellow Risk for Lowered Inventory during outage on October 29, 2019

(2) 4kv Crosstie after maintenance on October 30, 2019

(3) Plant Risk associated with performing Unit 2, Division 1 undervoltage test on November 5, 2019

(4) Fire Risk associated with removing the 2/3 service water pump from service on November 6, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) D2R26 Main Steam Isolation Valve Timing Issues

(2) D2R26 Local Leak Rate Test Local Leak Rate Test (LLRT) Feedwater 0220-62A failed LLRT as found conditions

(3) D2R26 Motor Operated Valve 2-1301-2 actuator degradation

(4) D2R26 Relief Valve 2-4899-72 post installation operability

(5) Historical Operability Review: Low Pressure Coolant Injection Loop Logic (DPIS 2-0261-35C)

(6) Part 21 Emergency Diesel Generator Seized Fuel Injector Plunger and Bushing

(7) High Pressure Coolant Injection and post-fire safe shutdown operation

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) U2 High Pressure Coolant Injection closure control MOV 2-2301-8

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Work Order (WO) 04590899, Unit 2 low pressure coolant injection valve on November 2, 2019

(2) Unit 2 Source Range Monitor 22 prior to fuel moves in SE quadrant on November 7 and 8, 2019

(3) WO 04771815, Unit 2 - 59 Main Steam Isolation Valve key interlock bypass test on November 9, 2019

(4) WO 04708044-01, Unit 2 Scram Dump Valves on November 11, 2019

(5) WO 01704408-01, Unit 2 2B Reactor Recirculating Pump Seal on November 11, 2019

(6) WO 04741694, 2A Reactor Recirculating pump on November 12, 2019

(7) Motor Operated Valve 2-1301-2 after control circuit work on November 12, 2019

(8) WO 04856283-01, 2B Control Rod Drive Pump on November 13, 2019

(9) WO 04797506-20, D2R26 PMTs [post maintenance tests] Required Prior to Entering Mode 2, relief valve 2-4899-72 post installation testing on November 19, 2019

==71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Sample 1 Partial)

(1) The inspectors evaluated Unit 2 refueling outage D2R26 activities from October 27 to November 14, 2019 (2) (Partial)

The inspectors evaluated a forced outage, D2F59, due to Unit 2 Generator Hydrogen Leak which began December 28, 2019, and continued into the year 2020

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)==

(1) Low Pressure Coolant Injection Logic System Functional Test (LSFT)on October 3, 2019, WO 04701722

(2) Unit 2 Reactor Cooldown Rate Monitoring on October 28, 2019

(3) Unit 2 Division 1 Under Voltage Test on November 4, 2019

(4) Unit 2 Anticipated Transient Without Scram LSFT per DIS 0263-08 (2 parts),

WO 04718556 on October 29 and November 6, 2019 Containment Isolation Valve Testing (IP Section 03.01) (2 Samples)

(1) Unit 2 Local Leak Rate Testing of Main Steam Isolation Valves (MSIV) 203-1A &

203-2A as per WO 04711481 on October 28, 2019

(2) Unit 2 Reactor Water Clean Up - Local Leak Rate Testing of Primary Containment Isolation Valve as per WO 04797506 on October 30,

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 02.01)

The inspectors evaluated radiological hazards assessments and controls.

(1) The inspectors reviewed the following:

Radiological Surveys

• Survey 2019-056853; Reactor Building Equipment Drain Tank Room

• Survey 2019-056188; 2/3 Radwaste 507' Barrel Area Basement

• Survey 2019-053762; 2/3 Radwaste 507' Barrel Area Basement Risk Significant Radiological Work Activities

• Reactor Building Equipment Drain Tank Hydrolasing

• 2/3 Radwaste 507' Barrel Area Basement Hydrolasing

• D3R25 Drywell Control Rod Drive Exchange Air Sample Survey Records

• Survey 2019-055827; Unit 2 Reactor Building Equipment Drain Tank Room

• Survey 2019-056853; Unit 2 Reactor Building Equipment Drain Tank Room

• Survey 2019-121830; Unit 2 Cavity N/E

Instructions to Workers (IP Section 02.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.

(1) The inspectors reviewed the following:

Radiation Work Packages

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1

• DR-2-19-00233; Radwaste Concentrator Maintenance; Revision 00

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs Electronic Alarming Dosimeter Alarms

• Electronic Alarming Dosimeter Dose Rate Alarm on 2/3 Radwaste 507' Barrel Area Basement on 10/22/2019 Labeling of Containers

• Trash Container Located in Dresden Radwaste

• Trash Container Located in Dresden 2/3 Turbine Building

• Trash Container Located in Dresden 2/3 Reactor Building Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) The inspectors verified the following sealed sources are accounted for and are intact:

• Small Plate Source; Cs137

• Small Plate Source; Cs137 Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1 High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

(1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.02 - Occupational ALARA Planning and Controls Implementation of ALARA and Radiological Work Controls (IP Section 02.03)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls.

(1) The inspectors reviewed the following activities:

• DR-2-19-00548; D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve Repairs; Revision 1

• DR-2-19-00333; 2019 Unit 2 Floor Drain System Activities; Revision 1

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:

• Advance Liquid Processing System (ALPS) Radwaste Area 517'

• Sea Vans Storage Yard located at Protected Area

• Radwaste Barreling Area 519'

• Unit-2/3 Radwaste 519' Stock Area and Truck-bay Area The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:

• Turbine Equipment Sealand

• Reactor Building Equipment Sealand

• Torus Filters Sealand

• B-25 Box Containing Contaminated Hoses

• B-25 Box Containing Condensate Storage Tank Equipment

• Sealand for Shipment of Rolls-Royce Equipment DM-19-142 Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Advance Liquid Processing System (ALPS) Radwaste Area 517'

• Dry Active Waste (DAW) Processing at Radwaste Barreling Area 519' Radioactive Waste Resin and/or Sludge Discharges Processes

• Sluicing of Resin Bed from ALPS Filter Tanks at 517' to a High Integrity Container (HIC) in the Radwaste Building 519' Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

(1)

• 2019 DAW -10CFR61 Database Analysis

• 2019 Unit-2/3 Condensate Resin 10CFR61 Analysis

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated and observed the following radioactive material shipment preparation processes:

(1) DM-19-142; Rolls Royce Equipment to Roll-Royce Nuclear Field Service, UN3321, Low Specific Activity (LSA-II)

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)

• DM-19-142; UN3321, Radioactive Material, Low Specific Activity (LSA-II), 7; to Rolls Royce Nuclear Services

• DW-18-012; UN3321, Radioactive Material, LSA-II, 7; U-1 Dry Active Waste (DAW) to Energy Solution's Bear Creek Facility

• DW-19-019; UN3321, Radioactive Material, LSA-II, 7; Sludge from B-Max Waste to Energy Solution's Bear Creek Facility

• DW-19-030; UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to Energy Solution's Bear Creek Facility

• DM-19-021; UN2915, Radioactive Material, Type-A Package, 7; Shepherd Seal Source (A1 Special Form) in a Type-A Drum to J.L. Shepherd Facility

• DW-19-009; UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to Energy Solution's Bear Creek facility

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

(1) Unit 2, October 1, 2018 - September 30, 2019

(2) Unit 3, October 1, 2018 - September 30, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 2, October 1, 2018 - September 30, 2019

(2) Unit 3, October 1, 2018 - September 30, 2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the fire protection program implementation during the last year that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Non-Cited Violation for Security Equipment Loss of Power as documented in Inspection Report 05000237/2019411; 0500249/2019411 (ML19339D759 issued December 5, 2019)

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated 2D3 high pressure feedwater heater leak repair and licensees response on November 19 - 22, 2019

(2) The inspectors evaluated Unit 2 downpower and drywell entry for identifying/correcting increasing unidentified reactor coolant system leakage and licensees response on December 9,

INSPECTION RESULTS

Failure to Identify and Control Hot Work Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71111.05Q NCV 05000237/2019004-01 Presence Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.c, for the licensees failure to establish, implement, and maintain Fire Protection Program procedures which ensure fire prevention for hot work. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work," Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Description:

On November 6, 2019, during the Unit 2 refueling outage (Reactor in Mode 5), the inspectors observed contract pipe-fitters performing grinding work, using a flapper wheel, which resulted in visible sparks inside the drywell. The two workers were preparing to install small bore piping for the 2A Reactor Recirculating pump nozzles. The inspectors were unable to locate a hot work permit, fire watch, or fire extinguisher in the work area. The inspectors asked one of the workers if he was the fire watch and if there was a fire extinguisher available for the hot work. The worker replied he was not the fire watch and that hot work had not yet started.

The inspectors informed the workers that visible sparks are considered hot work. While one continued with the grinding, the other worker searched the work area for a fire extinguisher and then exited the drywell to continue searching for a fire extinguisher. After approximately 10 minutes, the inspectors exited the drywell and again informed the worker that grinding was still occurring without a hot work permit present, a fire watch, or a fire extinguisher. At this time, the worker returned to the work area and informed the other individual to stop the job.

The inspectors reviewed several of the licensees fire protection implementation procedures including OP-AA-201-004, Fire Prevention for Hot Work, Revision 16 and CC-AA-501-1027, Hot Work Precautions and Safety Practices, Revision 2. These procedures outline the site's policies regarding the proper control of hot work. Procedure OP-AA-201-004, Section 2.3 defined, in part, "Hot Work" as work activities that involve welding, cutting, grinding and open flame operations that are capable of initiating fires or explosions. Section 4.1.9 stated, in part, that "an operable Exelon fire extinguisher appropriate for the class of fire that could occur shall be available and conveniently located in the work area." Section 4.2.4 stated, a designated fire watch is required during the performance of all hot work operations governed by this procedure. Section 4.2.7 stated, The fire watch shall be aware of the location of fixed fire extinguisher(s) in the area and visually observe the fixed extinguisher to confirm that it appears to be in good condition prior to starting the hot work activityor have an additional Exelon fire extinguisher that is appropriate for the hazard readily available." Section 4.3.1 stated, An authorized hot work permit is required before any hot work operation is started within the protected area and the permit must be properly filled out and posted at the job site before the operation commences." In addition, procedure CC-AA-501-1027, Section 2.2 defines "Hot Work" as all processes that use or created an arc, flame, spark, or intense heat.

These includes welding, cutting, gouging, grinding, and open flame operations."

Based on their review, the inspectors determined the work performed met the definition of "hot work" and needed to be controlled under the site's requirements for such work.

Specifically, the licensee did not have a hot work permit posted at the job site, no designated fire watch, and no fire extinguisher readily available.

Corrective Actions: In response to the inspectors observation, the workers stopped the grinding activities and licensee managers met with the crew. Licensee managers informed the workers they should have stopped when they started producing sparks, acquired a fire extinguisher, established a fire watch, signed into their hot work permit, and then continued work. In addition, the licensee performed a Work Group Evaluation.

Corrective Action References: AR 4295218, Visible Sparks During 2A RR Pump Bowl Piping."

Performance Assessment:

Performance Deficiency: The inspectors determined the licensees failure to follow fire protection program implementing procedures regarding fire prevention for hot work was contrary to Technical Specification 5.4.1.c, which required that written procedures covering Fire Protection Program implementation, be established, implemented, and maintained and was a performance deficiency. Specifically, the licensee failed to follow OP-AA-201-004, Fire Prevention for Hot Work, Revision 16, which stated before hot work is permitted a hot work permit shall be posted at the job site, a designated fire watch established, and fire extinguisher readily available to the designated fire watch.

Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, failing to comply with fire protection procedure requirements while performing hot work (e.g.

without a designated fire watch and fire extinguisher) increases the fire hazards to the plant by delaying the time it would take to identify and mitigate a potential fire resulting from the hot work.

Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. Specifically, the inspectors determined this finding was of very low safety significance (Green) because the performance deficiency was not expected to increase the likelihood of a fire that would cause a Shutdown Initiating Event, as defined in IMC 0609 Appendix G. This was determined based on the specific work being performed and the very limited combustibles observed in the work area.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the licensee's lack of field presence during the contractors grinding prevented them from promptly correcting the expectations for hot work.

Enforcement:

Violation: Technical Specification 5.4.1.c, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the following activities: Fire Protection Program Implementation.

Procedure CC-CC-211, "Fire Protection Program," Revision 8, described the site's Fire Protection Program. Section 4.8.1 designated procedure OP-AA-201-004 as the administrative positive control process over hot work (via a permit system).

Procedure OP-AA-201-004, "Fire Prevention for Hot Work," Revision 17:

Section 2.3 defined, in part, "Hot Work" as work activities that involve welding, cutting, grinding and open flame operations that are capable of initiating fires or explosions.

Section 4.1.9 required, in part, that an operable Exelon fire extinguisher appropriate for the class of fire that could occur shall be available and conveniently located in the work area.

Section 4.2.4 stated, in part, that a designated Fire Watch is required during the performance of all hot work operations governed by this procedure.

Section 4.3.1 stated, an authorized Hot Work Permit is required before any hot work operation is started within the protected area and inside any building located outside the protected area unless the location is a Designated Hot Work Area. The permit must be properly filled out and posted at the job site before the operation commences.

Contrary to the above, on November 6, 2019, the licensee failed to implement procedures covering activities regarding the Fire Protection Program implementation. Specifically, the licensee failed to follow the requirements of procedure OP-AA-201-004. The licensee failed to:

(1) realize the grinding work being performed was considered hot work;

(2) obtain an appropriate fire extinguisher;

(3) designate a fire watch during the performance of the hot work; and

(4) fill and post the Hot Work Permit.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Inaccurate and Incomplete Post Maintenance Testing Documentation for Containment Isolation Valve 2-1301-2 Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.1] - 71111.19 NCV 05000237/2019004-02 Identification Open/Closed On November 12, 2019, the inspectors identified a Green finding and associated NCV when the licensee failed to have acceptance criteria for testing containment isolation valves per Technical Specification Surveillance Requirement 3.6.1.3.5, in accordance with 10 CFR 50, Appendix B, Criterion V, and identify and document the action taken in regard to a deficiency in a quality record in accordance with 10 CFR 50, Appendix B, Criterion XVII.

Description:

On October 28, 2019, per the licensee's motor operated valve test program, an as-found diagnostic test was perfomed (Work Order 01693537-01, D2 3RFL Com MOV Elect Insp &

Diagnostic Testing 2-1301-2) on an isolation condenser containment isolation valve 2-1301-2 and the work order documentation stated that the valve passed the test. The licensee was also required to do an internal inspection of the valve actuator and found some degradation.

The licensee repaired the degradation and performed another as left diagnostic test (WO 01742662-09, MOV 2-1301-2 Stem Scoring Nut Rust) on November 9, 2018, which the work order documentation stated was acceptable. However, the valve failed to operate from the control room and additional maintenance was performed. The licensee performed post-maintenance testing on the 2-1301-2 on November 12, 2019, which consisted of closing the valve from the control room.

On November 12, 2019, the inspectors observed the post-maintenance testing of primary containment isolation valve 2-1301-2. During the test the licensee timed the valve closure in accordance with DOS 1300-02, Isolation Condenser Valve Operability Check, Revision 21, Step I.5, which was labeled as acceptance criteria within the procedure. The inspectors questioned against what criteria the closure time of the valve was to be compared against to determine operability. The licensee responded that the station was no longer required to time motor operated valves and that valve closure was sufficient to determine operability. The inspectors questioned how the licensee met Technical Specification Surveillance Requirement 3.6.1.3.5, which required the verification that the isolation time of each primary containment isolation valve was within limits. The licensee responded that the Technical Specification Surveillance Requirement was met when the valves were timed during diagnostic testing required by the motor operated valve test program requirements. The inspectors reviewed the as-found diagnostic testing work order performed on October 28, 2019, and the as left diagnostic testing work order performed on November 9, 2019, for the 2-1301-2 valve. The valve was timed during the diagnostic test but the inspectors thought there was no quantitative or qualitative acceptance criteria in the work order documentation.

The inspectors met with members of the licensee's engineering staff on November 21, 2019.

The licensee's staff pointed out there was a line in the as-found work order documentation that stated that the maximum valve closure time was 22.84 seconds and that this was the acceptance criteria. The inspectors pointed out that the actual valve closure time was 28.6 seconds and that the work order documentation stated that the valve passed the test even though the test documentation showed otherwise. The licensee stated that they were aware of this discrepancy at the time of the as-found test and had evaluated the results and later determined the test result was satisfactory. The licensee stated that the 22.84 second acceptance criteria was incorrect and should have been much closer to the actual 28 second closure time. The inspectors asked if this evaluation was documented in a corrective action document or in the work order documentation that the inspectors were not aware of. The licensee stated that the evaluation determination was not documented in the work orders.

The inspectors pointed out the as-found test was performed 12 days before the as-left test and the discrepancy with incorrect acceptance criteria still existed in the as-left test documentation and had not been corrected. Quantitative acceptance criteria for timing of primary containment isolation valves was located in Appendix A of the Technical Requirements Manual which was not referenced in the work order. However, since the valve closure limit time was 45 seconds as listed in Appendix A of the Technical Requirements Manual and the valve closed in about 28 seconds the inspectors had no concern with the operability of the valve.

Corrective Actions: The licensee planned to ensure actions were in place to revise the MOV work orders instructions to document results, ensure accurate acceptance criteria, require written resolution or create a corrective action document for deficiences, and reference Technical Specification and Technical Requirements Manual requirements. An extent of condition review for similar deficiences was planned.

Corrective Action References: AR 4299125, MOV Stroke Time Documentation Issue AR 4300288, NRC Quality Assurance of MOV Work Oders AR 4301626, MOV 2-1301-2 Documentation Inquiry AR 4299431, MOV Program Improvements Resulting from IR 4299125

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's work orders that covered the testing of valve 2-1301-2 required by Technical Specification Surveillance Requirement 3.6.1.3.5 to verify that the closure time of primary containment isolation valves were within limits did not have appropriate acceptance criteria. Procedures that affect quality were required to contain appropriate acceptance criteria in accordance with 10 CFR 50, Appendix B, Criterion V. Valve 2-1301-2 was a safety-related valve and Technical Specification Surveillance Requirement 3.6.1.3.5 was an activity that affected quality. The valve was returned to service and both the work orders were closed without any documentation of the action taken in connection with the deficiency associated with the acceptance criteria as required by 10 CFR 50, Appendix B, Criterion XVII. This was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to have appropriate acceptance criteria in technical specification surveillance test procedures impacted the procedure quality attribute to ensure the valve worked properly in service.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding did not constitute an actual open pathway in the physical integrity of the reactor containment and and there are no hydrogen ignitors at Dresden so therefore the finding screened as Green.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, had the workers identified that the incorrect acceptance criteria was a problem and addressed the issue in the work order documentation this violation would not have occurred.

Enforcement:

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

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVII, Quality Assurance Records, required, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include the action taken in connection with any deficiencies noted.

The licensee established Work Orders 01693537-01 and 01742662-09 as the implementing procedures for verifying the closing time of containment isolation valve 2-1301-2 in accordance with Technical Specification Surveillance Requirement 3.6.1.3.5, an activity affecting quality.

Contrary to the above, A. On October 28, and November 9, 2019, the licensee conducted motor operated valve diagnostic testing on safety-related valve 2-1301-2, an isolation condenser primary containment isolation valve, an activity affecting quality, with Work Orders 01693537-01 and 01742662-09 that did not include appropriate acceptance criteria. The acceptance criteria listed in the Work Orders was inaccurate, causing the documentation to show that the valve failed the timing test.

B. On November 12, 2019, both work orders 01693537-01 and 01742662-09 contained information indicating the tests performed were unsatisfactory in that the time required for the valve to close was deficient in that it did not meet the acceptance criteria given. The valve was returned to service and both the work orders were closed without any documentation of the action taken in connection with the deficiency associated with the acceptance criteria still in the work order.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to have Appropriate Installation Procedure for Relief Valve 2-4899-72 Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.19 Systems NCV 05000237/2019004-03 Open/Closed On November 14, 2019, a self-revealed Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings," was identified when the licensee failed to have an appropriate procedure for the installation of the Unit 2 containment cooling heat exchanger shell side relief valve.

Description:

On November 13, 2019, while Unit 2 was in Mode 2, torus level lowered to -6.16" resulting in the licensee entering T.S. 3.6.2.2, Condition A on Suppression Pool Water Level not within limits per DOS 1600-16, Suppression Chamber Water Level Correction. The licensee also entered DEOP 200-01, Primary Containment Control, per DOP 1600-02, Torus Water Level Control, limitations. The operators filled the torus using high pressure coolant injection (HPCI) per DOP 1600-02.

On November 14, 2019, the licensee was troubleshooting the emergency core cooling system (ECCS) keep fill system as part of the torus level lowering, and identified the 2A Containment Cooling Heat Exchanger Shell Side Relief Valve (2-4899-72) was open.

The licensee reset the valve to the closed position. The relief valve had been replaced in refueling outage D2R26 per Work Order 04709186-01 on November 6, 2019. The inspectors questioned if the relief valve had undergone post-maintenance testing. The licensee responded the valve had been tested on November 11, 2019, and that the testing was considered satisfactory. The inspectors questioned how the relief valve was not reset after the post-maintenance testing. The licensee stated the relief valve has a mechanical gag that can be operated from a lever installed at the top of the valve. Determining whether the valve was open or closed was not part of the post-maintenance testing.

The inspectors met with the licensee staff on November 19, 2019. The inspectors asked the licensee if the control room received an alarm for low torus level. The licensee stated the alarm was already lit for other work being done. The inspectors asked the licensee if any of the pumps aligned to the torus would have a potential to vortex. The licensee pointed out based on the recorded level, the vortex limit was not expected to occur. The inspectors also asked about the operability of the ECCS systems. The licensee stated there were no loss of safety function due to the HPCI turbine exhaust remaining covered as well as the relief valve quenchers remaining covered. The licensee also pointed out that HPCI was not required to be operable until reactor pressure reaches 150 psig and the reactor had been at 0 psig so based on this information as well, the licensee observed that all safety functions had been met for the ECCS systems.

Corrective Actions: The licensee closed relief valve 2-4899-72. The licensee planned to perform a Corrective Action Program Evaluation (CAPE) and generate corrective actions from the results.

Corrective Action References: AR 4297084, DEOP 200-01 Entry for Low Torus Water Level AR 4297420, Relief Valve 2-4899-72 Identified to be Lifted AR 4303551, 4.0 Critique - Unplanned Entry into TS 3.6.2.2 & DEOP 200-1

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's work order for installation of relief valve 2-4899-72, a safety-related component, did not contain appropriate instructions for installation. The licensee's failure to have appropriate work instructions for verifying the relief valve was installed in the correct position was contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings."

Specifically, the work order failed to have instructions to verify the relief valve was closed after its installation. This was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, this condition resulted in the inoperability of the suppression pool which is the safety source of water for ECCS systems.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding did not constitute an actual loss of probable risk assessment functionality for the suppression pool and ECCS systems, and therefore screens to Green.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the workers installing relief valve 2-4899-72 did not have the knowledge to recognize the valve was open, and that the relief valve was installed in the incorrect configuration.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.

The licensee established Work Order 04709186-01 as the implementing procedure for installing relief valve 2-4899-72, an activity affecting quality.

Contrary to the above, from November 6 to November 14, 2019, the licensee failed to have a procedure appropriate for the circumstances for the installation of relief valve 2-4899-72, a safety-related component. Specifically, the work order did not have a step to verify relief valve 2-4899-72 was installed in the correct position.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Survey for Work Conducted in a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.14] - 71124.01 Radiation Safety NCV 05000249,05000237/2019004-04 Conservative Open/Closed Bias A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General was identified by inspectors when the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Description:

On October 21, 2019, three individuals accompanied by a Radiation Protection Technician (RPT) entered the Unit 2/3 Radwaste Basement Barreling Area to complete hydrolasing work that was being conducted in support of the installation of the new Advanced Liquid Processing Station at Dresden Station. During the initial attempt to complete the task, the individuals involved with the work experienced issues with the hydrolasing equipment which caused the individuals and the RPT to exit the Unit 2/3 Radwaste Basement Barreling Area to troubleshoot the issue. During the troubleshooting session, it was decided that the individuals would use a drain port that was in a back corridor of the Radwaste Barreling Area to drain excess water from the hydrolasing equipment that was causing the issues with the task. Access to that area was not included in the original scope of the work activity. The troubleshooting session also involved discussions around how transient conditions existed in the back corridor due to a previous resin transfer that had occurred in the area.

The individuals returned to the Radwaste Barreling Area with a different RPT than who initially covered the job. Before the work resumed, the RPT surveyed the area of the back corridor that contained the drain port only. This survey revealed conditions that were less than 20 mrem/hour general area. When the work was resumed, the individuals began taking turns proceeding to the back corridor to place the excess water into the drain port. While traveling to the back corridor to empty the water in the drain port, one of the individuals heard a loud sound in the opposite direction of the drain port when they entered the corridor. The individual felt that this sound may be result of the issues that the work crew had been experiencing with the hydrolasing equipment and took 2 steps in this direction (to the left) to investigate this noise. The individual then received an electronic dosimeter dose rate alarm of 567 mrem/hour. When RP became aware of elevated dose rates, an RPT measured dose rates that ranged from 400 mrem/hour to 2500 mrem/hour at 30 centimeters from the source of radiation (resin transfer piping) that was unknown yet accessible to workers in the area without barricades to prevent authorized access.

Corrective Actions: When the licensee became aware of elevated dose rates due to the electronic dose rate alarm that was received by an individual conducting work in the area, an RPT was sent to the Unit 2/3 Radwaste Barreling Area to perform follow-up surveys. The survey results revealed dose rates that ranged from 400 mrem/hour to 2500 mrem/hour at 30 centimeters from the source of radiation (resin transfer piping). The licensee also conducted interviews with all involved parties to gain further insights into the cause of the event and to aide in creating an operating experience tool for future reference. Supervisors were also required to observe high radiation area briefings and to periodically shadow technicians in the field while taking radiation surveys.

Corrective Action References: AR 4290588, "Dose Rate Alarm While Working in the Radwaste Basement"

Performance Assessment:

Performance Deficiency: The licensee did not make surveys (as required by 10 CFR 20.1501 (a)(1)) to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the licensee did not make surveys (as required by 10 CFR 20.1501 (a)(1)) to assure compliance with 10 CFR 20.1601 (a)(3) which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. The licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Basement Barreling Area and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (i.e., Green) because:

(1) it did not involve as-low-as reasonably-achievable 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.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee determined that the RP staff knew that a resin transfer had occurred within the area in question and failed to perform a radiation survey. The decision to not survey the area after a resin transfer had occurred was deemed to be non-conservative. Consequently, this led to individuals entering an area where dose rates were not known and/or established.

Enforcement:

Violation: Title 10 CFR 20.1501 (a)(1) requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Contrary to the above, on October 21 2019, the licensee did not make surveys to assure compliance with 10 CFR 20.1601 (a)(3), which requires positive control for entries into areas where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Specifically, the licensee failed to survey all accessible areas in the Unit 2/3 Radwaste 507 Barrel Area Basement and did not provide positive controls for all individuals that entered the room. Consequently, an individual encountered elevated dose rates in an area that had not been previously surveyed following a change of radiological conditions.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Positively Control a Door That Granted Access to a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.8] - 71124.01 Radiation Safety NCV 05000237/2019004-05 Procedure Open/Closed Adherence A self-revealed finding of very low safety significance (i.e. Green) and an associated non-cited violation (NCV) of 10 CFR 20.1601 (a)(3) was identified by inspectors when the licensee failed to lock and demonstrate positive control over a door that is the access point to an area having general area dose rates of approximately 3000 mrem/hour at 30 cm from the radiation source.

Description:

On October 29, 2019, the licensee continued to conduct piping modification work in the Unit 2 Reactor Building Equipment Drain Tank Room (RBEDT Room). At the end of the shift, the workers and the RP technician responsible for covering the job exited the area, but the RP Technician failed to have another technician verify that the door leading into the Unit 2 RBEDT Room had been locked and secured. The RP Technician then performed shift turnover with the new RP Technician that would be covering the job on the next shift. When the new RP Technician approached the door with the new work crew, a member of the work crew pointed out to the RP Technician that the door did not appear to be locked. The RP Technician verified this claim, and the door was unlocked. The RP Technician immediately entered the area to verify that no individuals were currently in the room and to perform follow up surveys to verify if conditions in the room had changed. Conditions in the room were unchanged and were consistent with the initial survey data that showed the Tank in the Unit 2 RBEDT Room having dose rates of 5000 mrem/hour on contact, and 3000 mrem/hour at 30 centimeters from the radiation source. After the survey, the RP Technician did not allow the new shift work in the room to begin. The RP Technician immediately reported the event to their supervisor, and the Radiation Protection Manager was also notified. The site performed a stand down of work activities in the area until the prompt investigation of the event was completed. The investigation revealed that the failure to verify that the door had been locked at the end of the previous shift was the primary cause for this event.

Corrective Actions: The licensee initiated a high radiation area (HRA) door verification practice that involved supervisors verifying that HRA doors were secured and locked after technicians had verified that the doors were secured and locked also. The licensee also verified that all HRA doors at the facility were secured and locked regardless of if the room had been accessed during this time frame. The licensee also placed door guards at the Unit 2 RBEDT Room until the job was completed, and also notified the NRC Resident Inspection staff and Regional Inspector.

Corrective Action References: AR 4292469, "U2 REBT Room Door Left Unsecured"

Performance Assessment:

Performance Deficiency: The licensee failed to lock and demonstrate positive control over a door that is the access point to an area where an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. The area had been posted as an HRA and controlled by a locked door in accordance with 10 CFR 20.1601 (a)(3). General Area dose rates were measured up to 3 Rem/hour.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to lock and demonstrate positive control over a door that is the access point to an HRA could have led to an individual being exposed to dose rates that were greater than or equal to 3 Rem (30 mSv) at 30 centimeters from the radiation source.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (i.e., Green) because:

(1) it did not involve as-low-as reasonably-achievable 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.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the licensee determined that the RP Technician's failure to verify that the Unit 2 RBEDT Room was locked and secured which is required by procedure was the cause of the event.

Enforcement:

Violation: Title 10 CFR 20.1601(a) requires, with exceptions not applicable here, that the licensee ensure that each entrance to a high radiation area has one or more of the following features:

(1) a control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep- dose equivalent of 0.1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates;

(2) a control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or

(3) entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.

Title 10 CFR 20.1601(b) provides that, in place of the controls required by 10 CFR 20.1601(a)for a high radiation area, a licensee may substitute continuous direct or electronic surveillance that is capable of preventing unauthorized entry.

Contrary to the above, as of October 29, 2019, the entrance to the Unit 2 Reactor Building Equipment Drain Tank Room, a high radiation area with a radiation dose rate of approximately 3000 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source, was not controlled by any methods described in 10 CFR 20.1601

(a) or (b).

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Semiannual Trend Review 71152 The NRC and Illinois Emergency Management Agency (IEMA) inspector have noticed what appears to be an adverse trend in the area of fire protection program implementation during the last year (calendar year 2019). There were various issue reports (IRs) documented in the corrective action program system addressing fire protection related deficiencies. In addition, there appeared to be an increasing number of these items being identified by external parties (NRC, IEMA and Exelon corporate Nuclear Oversight). For the purposes of a simple comparison, a comparable time frame was searched in the CAP. The search focused on items related to inoperable or degraded fire equipment or program implementation issues (e.g. fire doors, fire risk assessment, transient combustibles, and intervening combustibles).

This cursory search found the following:

From 6/1/18 to 12/31/18 Two NRC/IEMA-identified issues (IRs 4167042 and 4206398)

Four licensee-identified issues (IRs 4156094, 4188719, 4188731 and 4200212)

From 6/1/19 to 12/19/19 Nine NRC/IEMA-identified issues (IRs 4259040, 4260129, 4271776, 4273498, 4274824, 4291271, 4292782, 4295069 and 4295218)

Nine licensee-identified issues (IRs 4268037, 4269072, 4281360, 4290524, 4290768, 4294704, 4295095, 4295198 and 4299099)

Inspectors noted, not only the increasing number of identified items, but also the increase in number and percentage of items identified by NRC and IEMA. In addition, the inspectors noted the majority of the items identified by NRC and IEMA were in areas typically traversed by plant personnel.

An additional search of the CAP over the last year (keywords "fire"; "TRM 3.7.n"; "hotwork";

"transient combustibles") noted the following number of IRs documenting issues related to:

16 - Fire Door Deficiencies 28 - Fire protection pipping/component leaks, degradation or issues 2 - Transient combustibles 14 - Fire Protection Procedures or fire report deficiencies 14 - Fire Alarm Issues (not counting valid actuation)8 - Fire Extinguisher / Fire Hoses deficiencies 5 - Fire Wraps or Barriers deficiencies (other than doors)4 - Hot Work issues It was important to note these searches were not meant to be exhaustive, but done for the purpose of highlighting what appeared to be an emerging adverse trend. The reasons for this trend have not been determined, however, over the last year the NRC and licensee have identified adverse trends regarding procedure use/adherence and human performance in other areas. It is worth mentioning that the licensee's corporate office noticed a trend in the last few weeks of 2019 regarding support workers performance and fire protection across multiple sites, including Dresden Station. This was documented in corporate IR 04304700.

Based on a review of the available information, and in accordance with our inspection and documentation procedures, the inspectors did not identify any findings or violations of more than minor significance, except for one example. The issue of concern described under IR 4295218, "NRC Id'd - Visible Sparks During 2A RR Pump Bowl Piping," was evaluated by the resident inspectors and determined to result in a Green finding with an associated non-cited violation. The details of this finding are documented in this report under Section 71111.05Q, "Failure to Identify and Control How Work."

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 10, 2020, the inspectors presented the integrated inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

• On November 6, 2019, the inspectors presented the D2R26 ISI exit meeting inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

• On November 22, 2019, the inspectors presented the Radiation Protection Inspection Results inspection results to Mr. P. Karaba, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 4290477 Heating Boiler Schedule Gaps 10/23/2019

Documents 4298569 Ops Crew 1 Clock Reset - Heating Steam Leaks 11/18/2019

299671 DOA 5700-01 Entry 11/25/2019

299678 2/3A Heating Boiler Local Low Level Alarm Will Not Clear 11/25/2019

Corrective Action 4301697 NRC Requests 12/04/19 Shift 2 12/04/2019

Documents 4303211 NRC Request 2/3 Cribhouse Windows DOA 5700-01 12/04/2019

Resulting from

Inspection

Procedures DOA 5700-01 Loss of Heating Boilers 26

DOS 0010-19 Preparation for Cold Weather Operations for Unit 1 & Out 45

Buildings

DOS 0010-19 Checklist 1 Preparation for Cold Weather 45

DOS 0010-22 Preparation for Cold Weather Operations for Unit 2 26

DOS 0010-25 Preparation for Cold Weather Operations for Unit 3 23

DOS 0010-31 Preparation for Cold Weather Operations at the Lift Station, 20

Goose Lake Pump Station, Security Diesel Building, and

Cooling Towers

Work Orders 04883155-01 Preparation for Cold Weather for Unit 2 10/25/2019

04883211-01 Prepare for Cold Weather Unit 1 10/25/2019

04883215-01 Preparation for Cold Weather Chges For R/W 10/25/2019

048833219-01 Preparation for Cold Weather for Unit 3 10/25/2019

04891989-01 Prepare Out Bldgs for Cold Weather for Lift Attion 10/24/2019

71111.04Q Corrective Action 4297625 3D3 Heater Steam Leak 11/15/2019

Documents

Drawings 205LN001-001 Shutdown Cooling System 04

233LN001-001 Fuel Pool Cooling (FPC) System 04

M-31 Diagram of Fuel Pool Cooling Piping BT

Procedures DOP 1000-M1 Unit 2 Shutdown Cooling System Checklist 09

DOP 10000-03 Shutdown Cooling Mode of Operation 82

DOP 1900-E1 Fuel Pool Cooling Electrical 01

DOP 1900-M1 Unit 2 Fuel Pool Cooling System Checklist 17

Inspection Type Designation Description or Title Revision or

Procedure Date

DOP 6400-10 Removing/Restoring Transformer 22(32) For Outage 17

Maintenance

DOP 6400-14 TR 86 Load Tap Changer Operation 17

DOP 6400-15 TR 32 Load Tap Changer Operation 18

DOP 6500-08 Bus 24-1 to Bus 34-1 Tie Breaker Operation 25

DOP 6500-30 Bus 23-1 to Bus 33-1 Tie Breaker Operation 16

DOS 1000-02 Alternate Decay Heat Removal Using Shutdown Cooling and 20

Fuel Pool Cooling

71111.05Q Corrective Action 4035503 2/3 Diesel Fir Pump Local Tachometer Failed PMT 07/26/2017

Documents 4159567 2/3 DFP Tachometer Not Accurate 07/27/2018

Corrective Action 4301893 2/3 - 3903 DGCWP / NRC Request for Info 12/05/2019

Documents 4304481 NRC ID: Fire Protection Report Requires Clarification 12/16/2019

Resulting from

Inspection

Drawings 12E-2096C Electrical Installation Cribhouse Partial Plans and Sections, G

Elevation 490'8"

F-220, Sht 4 Fire Wrap - Cribhouse - Partial Plan & Sections, Elev. 490'8" E

Fire Plans FZ 1.2.2 Unit 2 Drywell Primary Containment, Elev. 517' 2

FZ 8.2.5A Unit 2 H. P. Heaters/Steam Lines Elevation 517' 3

FZ 8.2.5B Unit 2 Low Pressure Heater Bays, Elevation 517' 2

Procedures DAN 923-1 G-4 U2/3 Diesel Fire PP Running 05

DFPS 4123-05 2/3 Diesel Fire Pump Operability 56

DFPS 4123-15 Returning 2/3 Diesel Fire Pump to Standby Following Start 03

71111.06 Corrective Action 0120311 Unit 2 & 3 EDGCW Pump Submersibility Qualification 08/22/2002

Documents

Corrective Action 4301697 NRC Requests 12/04/19 Shift 2 12/04/2019

Documents 4301893 2/3 - 3903 DGCWP / NRC Request for Info 12/05/2019

Resulting from 4302085 NRC Questions Consistency of Harsh Environment 12/06/2019

Inspection Definition

Engineering 338567 Install Water Tight Seals Around Power Cables for the 00

Changes 2-3903 DGCW Pump

338568 Install Water Tight Seals Around Power Cables for the 00

2-3903 DGCW Pump

Inspection Type Designation Description or Title Revision or

Procedure Date

338569 Install Water Tight Seals Around Power Cables For the 00

3-3903 DGCW Pump

23268 Revise Flood Elevation Action Level in UFSAR, TRM and 000

DOA 0010-04

Miscellaneous Binder #: D1528 Crane-Chempump Diesel Generator Cooling Water Pump 004

Crane Instruction Manual n/a

Chempump

Series G

Procedures CC-AA-203 Environmental Qualification Program 14

DES 6600-08 Diesel Generator Electrical Maintenance Surveillance 43

Inspection

71111.08G Corrective Action 2017-6960 Dresden U2 Weld Overlay Drawing 11/12/2017

Documents 4070767 Indications Found in Reactor Head Flange Weld 11/03/2017

4071740 D2R25 -UT Indication -N20A Nozzle Weld 6 11/07/2017

4074270 Nozzle N20A Repair Plan Requires Revision 11/13/2017

4075547 NRC Relief Request for U2 Weld Overlay 11/16/2017

NDE Reports D2R25-APR-05 UT Examination Summary Sheet 11/12/2017

D2R25-UT-030 UT Calibration/Examination 11/06/2017

D2R25-UT-034 UT Calibration/Examination 11/06/2017

D2R26-UT-005 UT Calibration/Examination 10/30/2019

D2R26-UT-006 UT Calibration/Examination 10/30/2019

D2R26-UT-008 UT Calibration/Examination 11/01/2019

D2R26-UT-009 UT Calibration/Examination 11/01/2019

D2R26-UT-010 UT Calibration/Examination 11/01/2019

Procedures ER-AA-335-003 Magnetic Particle Examination 9

GEH-PDI-UT-2 PDI Generic Procedure for the Ultrasonic Examination of 12

Austenitic Pipe Welds

GEH-PDI-UT-3 PDI Generic Procedure for Ultrasonic Through Wall Sizing in 6

Piping Welds

GEH-UT-717 Procedure for the Examination of Reactor Pressure Vessel 4

Welds from the Inside Surface with MICROTOMO in

Accordance with Appendix VIII

GEH-UT-737 Procedure for the Examination of Reactor Pressure Vessel 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Welds from the Inside Surface with the Z-Scan UT System in

Accordance with Appendix VIII

Work Orders 4709411 Perform Weld Overlay on Unit 2 N20A Nozzle Weld Joint 11/17/2017

N20A-6

71111.11Q Corrective Action 4292191 4.0 Critique - U2 Shutdown for D2R26 10/28/2019

Documents 4292642 RTD Thermal Couple and Shackle Became Dislodged in 10/30/2019

RPV

293035 Fuel Moves Stopped / RFB Comes in Contact with Camera 10/30/2019

Cable

Procedures DGP 01-01 Unit Startup 197

DGP 01-S1 Start-up Checklist 102

DGP 01-S5 Mode 3 to Mode 2 Restart Checklist 26

DGP 02-01 Unit Shutdown 171

DGP 03-04 Control Rod Movements 77

DOP 0500-06 Planned Movement of the Reactor Mode Switch 18

DOP 10000-03 Shutdown Cooling Mode of Operation 82

DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool 57

Level Control

71111.12 Corrective Action 4269595 Unexpected Alarm - U2 Fuel Pool CH B Rad Hi 08/05/2019

Documents 4269595 Unexpected Alarm - U2 Fuel Pool CH B RAD Hi 08/05/2019

269595-10 Review GE Reuter Stokes Failure Analysis Results 09/30/2019

269595-11 Revise WGE Based on the GE Reuter Stokes Failure 10/23/2019

273817 SPC4246346-19: 3-1705-16B Failure Analysis Results 08/22/2019

276469 Unexpected Alarm - U3 Fuel Pool CH A Rad Hi 09/03/2019

4300107 Unexpected Alarm: 902-3 B-1 Refuel Floor RAD-Hi 11/26/2019

4300120 Unexpected Alarm, Area Rad Monitor Downscale 11/26/2019

Procedures ER-AA-310-1002 Maintenance Rule Function Safety Significance 3

Determination

Work Orders 04768029-03 Perform Vibration Analysis on 2-0302-3B CRD Pump 11/15/2019

71111.13 Corrective Action 4295069 NRC ID'D Procedure Revision Required For Fire Risk 11/06/2019

Documents Procedure

Resulting from

Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous Protected Equipment Lists for Unit 2 and Unit 3 Risk

Significant Systems

Procedures DOP 6500-08 Bus 24-1 to Bus 34-1 Tie Breaker Operation 25

DOP 6500-14 Returning 4KV Bus 24-1 to Operation After 08

Maintenance/Testing

DOP 6500-15 Removing 4KV Buss 33-1 From operation for 10

Maintenance/Testing

DOP 6500-16 Returning 4KV Buss 33-1 to Operation After Maintenance 09

DOP 6500-30 Bus 23-1 to Bus 33-1 Tie Breaker Operation 16

DOS 6600-06 Bus Undervoltage and ECCS [emergency core cooling 61

system] Integrated Functional Test For Unit 2/3 Diesel

Generator to Unit 2

OP-AA-108-117 Protected Equipment Program 5

OP-DR-201-012- Dresden On-Line Fire Risk Management 6

1001

71111.15 Corrective Action 4270543 Dresden OPEX Review for QDC IR 4266776 08/08/2019

Documents 4270543 Dresden OPEX Review for QDC IR 4266776 08/08/2019

280928 DPIS will not Trip 09/20/2019

280928 DPIC will not Trip 09/20/2019

282612 Enhance DSSPs to Prevent Potential Spurious HPCI 09/26/2019

Actuation

282612 Enhance DSSPs to Prevent Potential Spurious HPCI 09/26/2019

Actuation

290427 Historical Operability Review for DPIS 3-0261-35C 10/23/2019

291863 MSIV 2-203-1A Needs Timing Adjustment 10/28/2019

291864 MSIV 2-203-1C Needs Timing Adjustment 10/28/2019

291865 MSIV 2-203-1D Needs Timing Adjustment 10/28/2019

291868 MSIV 2-203-2B Needs Timing Adjustment 10/28/2019

291993 Part 21 EMD Fuel Injector - Seized Plunger and Bushing 10/28/2019

292440 D2R26 LLRT FW 0220-62A Failed, Added Scope 10/29/2019

292595 D2R26 2C MSIV - Water Intrusion Misc EOC 10/29/2019

292986 DR26 2-0261-35B DPIS Not Zeroed Out 10/30/2019

293026 1C MSIV Actuator is Leaking By Internally 10/31/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

293026 1C MSIV Actuator Is Leaking By Internally 10/31/2019

294831 D2R26 Scope Addition 2-1201-2 Actuator Needs to be 11/05/2019

Rebuilt

QDC IR 4266776 HPCI not Disabled for Fire Areas TB-III and TB-1 09/26/2019

Drawings ISI-105 Inservice Inspection Class 1 Isolation Condenser Piping H

ISI-111 Inservice Inspection Class 1 High Pressure Coolant Injection F

Piping

ISI-122 Inservice Inspection Class 1 High Pressure Coolant Injection G

Piping

M-310 Instrument Installation Details Unit 2 05/25/1968

Miscellaneous OPXR 4259869- QDC IR 4266776 - HPCI not Disabled for Fire Areas 09/26/2019

(QDC)

Procedures DSSP 0100-A1 Hot Shutdown Procedure - Path A1 40

DSSP 0100- Hot Shutdown Procedure - Path A2/B2 42

A2/B2

DSSP 0100-B1 Hot Shutdown Procedure - Path B1 40

DSSP 0100-CR Hot Shutdown Procedure - Control Room Evacuation 51

DSSP 0100-E/F Hot Shutdown Procedure - Path E/F 04

Work Orders 00457621 Perform Testing Following DPIS 3-0261-35C Replacement 09/21/2019

71111.18 Engineering 620175 HPCI Injection MOV 2-2301-8 Closure Control Modification 001

Changes From Torque Switch Close to Limit Switch Close

Work Orders 01693630-01 D2 5RFL Com MOV Elect Insp & Diagnostic Testing 11/03/2019

2-2301-8

04726346-01 24M/RFL TS HPCI Motor Operated Valve Operability Surv 11/13/2019

04797506-18 HPCI PMTS Prior to Startup 11/13/2019

71111.19 Corrective Action 4296162 Cannot Full Stroke The 2-1301-2 Valve From the MCR 11/10/2019

Documents 4297084 DEOP 200-01 Entry for Low Torus Water Level 11/13/2019

297420 Relief Valve 2-4899-72 Identified to be Lifted 11/14/2019

4303551 4.0 Critique - Unplanned Entry into TS 3.6.2.2 & DEOP 12/13/2019

200-1

Miscellaneous White Paper to Answer NRC Questions 11/19/2019

193133013202 U2 ISO COND RX OUTLET ISO (MOV Diagnostic Test 11/09/2019

Data)

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures DMP 0202-01 Recirculation Pump Seal Replacement and Pump Leak Test 36

DOS 0700-03 SRM Detector Position Rod Block Functional Test 21

DOS 0700-12 Determining Source Range Monitor Signal to Noise Ratio 02

and Minimum SRM Count Rate

DOS 1300-02 Isolation Condenser Valve Operability Check 21

DOS 1600-18 Cold Shutdown Valve Testing 50

Work Orders 01286811-01 D2 5RFL Solenoid Valve 2-302-20A 11/01/2019

01310540-01 D2 5RFL PM Repl Solenoid Valve 2-302-20B 11/01/2019

01487915-01 4RFL PM COM MOV Elec Insp & Diagnostic Test 2-1501- 10/31/2019

2A

01704408-01 2B Replace 2B RR Pump Mech Seal with New N-7500 STY 11/12/2019

04590899-01 4 RFL Com MOV Electrical Insp & Diagnostic Test 2-1501- 11/02/2019

21A

04708044-01 D2 24M/RFL TS Mode Switch in S/D Scram Func Test 11/11/2019

04709186-01 CM to Replace LPCI/CCSW Heat Exchanger Relief Valve 11/06/2019

04709880-01 D2 rFL PM CRD 2B Gear Unit Change Oil/Take Oil Sample 11/07/2019

04741694-03 U2 Hydrostatic Leak Test - 2RC01 Class 1 W/D 11/14/2019

04768029-01 Replace 2B CRD Pump Motor (2-0302-3B) 11/11/2019

04771815 59" MSIV Key Interlock Bypass Test 11/09/2019

04797506-18 HPCI PMTS Required for Mode 2 11/15/2019

04797506-20 LPCI Div 1 PMTs Required for Mode 2 11/11/2019

04797506-28 Reactor Recirc PMTS Required for Mode 2 11/14/2019

04856283-01 D2R26 CRD System 11/14/2019

71111.20 Corrective Action 4289667 Apparent EMD WHR Violations 10/18/2019

Documents 4292191 4.0-Critique - U2 Shutdown for D2R26 10/28/2019

292538 SRM 22 Has Increasing Count Rate Trend 10/29/2019

292561 FME on U2 RPV Steam Dryer 10/30/2019

292594 SRM Bypassed and INOP 10/30/2019

293016 Historical FME Discovered on Jet Pump 18- Vessel Side 10/31/2019

293614 D2R26 Feed Water Check Valve 2-0220-62A Failed LLRT 11/01/2019

293954 Unit 2 HPCI AOP Failed to Stay Running 11/02/2019

294290 D2R26 AF LLRT 1601-23 & 62 Test Volume Over Warning 11/04/2019

Limit

Inspection Type Designation Description or Title Revision or

Procedure Date

294413 D2R26 Torus and Centipede Coating Inspection Results 11/01/2019

294422 D2R26 Drywell Protective Coating Inspection Results 10/30/2019

295192 Fatigue Assessment 11/06/2019

295435 Snubber 2-0201B-17 Failed Operational Test D2R26 11/07/2019

295529 Whole Body Counts for Potential Internal Contamination 11/07/2019

295928 SRM 22 Identified to be Leaking 11/08/20219

296041 D2R26 Full Core Sipping Results 11/09/2019

297084 DEOP 200-01 Entry for Low Torus Water Level 11/13/2019

Drawings 27100LN001- Off Gas 08

001a

Miscellaneous 0710-80-0033 Flowserve Technical Notes, N-Seal Operation at Low December

System Pressures 2007

Tagout Walkdown 02-02-ERVS-001

Tagout Walkdown 02-54-TRAPSV-001

Tagout Walkdown 02-54-OFFGAS-001

Tagout Walkdown 02-23-HPICISTM-001

Tagout Walkdown 02-32-2ARFPMN-001

Procedures DFP 0800-01 Master Refueling Procedure 51

DFP 0800-07 Fuel Movements During Refueling Operations 40

DGP 02-02 Reactor Vessel Slow Fill 49

DGP 04-01 Fuel Moves and Refueling 39

DMP 5800-18 Load Handling of Heavy Loads and Lifting Devices 30

DOP 1600-22 Drywell Entry (Initial, Following Closeout, or At Power 28

DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool 57

Level Control

LS-AA-119 Fatigue Management and Work Hour Limits 13

MA-AA-716-008 Foreign Material Exclusion Program 14

MA-AA-716-008- Reactor Services, Refuel Floor FME Plan 16

1008

Work Orders 04713223-02 RFL Reactor Vessel and Cavity Level Instrumentation 10/21/2019

71111.22 Corrective Action 4284229 Delayed Alarm During DIS 1500-05 10/01/2019

Documents

Drawings 239LN001-001 Main Steam System 00

Inspection Type Designation Description or Title Revision or

Procedure Date

DRE204LN001- Reactor Water Clean-Up System and Instrumentation 06

001

M-12 Diagram of Main Steam Piping ABT

Procedures DAN 902(3)-5 H-8 Panel 2202-70A(B) Trouble 09

DGP 02-03 Reactor Scram 115

DIS 0263-08 Unit 2 ATWS RPT/ARI Logic System Functional Test 22

DIS 1500-05 Division I & II Low Pressure Coolant Injection ECCS 36

Initiation Circuitry Logic Functional Test

DOS 7000-01 Local Leak Rate Testing of Main Steam Isolation Valves 09

(Dry Tests)

DOS 7000-02 Local Leak Rate Testing of Main Steam Isolation Valves 05

(Wet Tests)

DOS 7000-08 Local Leak Rate Testing of Primary Containment Isolation 14

Valves

DOS 7000-18 Local Leak Rate Testing of Unit 2(3) Reactor Water Cleanup 06

(RWCU) System Valves

Work Orders 01906071-01 D2 48M/2RFL TS Bus 23-1 UV and ECCS Integrated Func 11/06/2019

Tests

04701722 D2 24M TS Division I & II LPCI Injection ECCS Initiation 10/02/2019

Circuitry LSFT

04710348 Clean Up MO Valve Operability and IST Timing 11/13/2019

04711479 D2 TS LLRT MSIV 203-1C & 203-2C Dry Test 10/28/2019

04711480 D2 TS LLRT MSIV 203-1D & 203-2D Dry Test 10/28/2019

04711481 D2 TS LLRT MSIV 203-1A & 203-2A Dry Test 10/28/2019

04716605-01 As Found LLRT per RWCU MOVs per DOS 7000-18 10/30/2019

04718556 D2 24M/RFL TS ATWS RPT/ARI Logic System Functional 11/06/2019

Test

04797506-29 RWCU PMTS Required for Mode 2 11/09/2019

71124.01 Corrective Action 2019-056888 B SJAE Room 10/28/2019

Documents 4294554 AR 04294554 11/03/2019

295116 Dose Alarm Received Providing Oversite in the 2B SJAE 11/06/2019

299113 Radiation Protection Improvement Plan 11/21/2019

Corrective Action 4298840 NRC ID: NISP-RP-003 Paperwork not Found or 11/20/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Documented

Resulting from 4299123 NRC ID- Inconsistency in Use of RP-AA-460-002 11/21/2019

Inspection 4299139 NRC ID - Documentation Discrepancy During Review 11/21/2019

Procedures NISP-RP-005 Access Controls for High Radiation Areas 1

Radiation 2019-053762 2/3 Radiation 507' Barrel Area Basement 09/27/2019

Surveys 2019-056188 2/3 Radwaste 507' Barrel Area Basement 10/22/2019

2019-056853 Reactor Building Equipment Drain Tank Room 10/28/2019

2019-056862 U2 Drywell 515' General Area 10/28/2019

2019-057152 2/3 Radwaste 507' Barrel Area Basement 10/30/2019

2019-057198 Reactor Equipment Drain Tank Room 10/30/2019

Radiation Work DR-0-19-00233 2019 Radwaste Concentrator Maintenance 0

Permits (RWPs) DR-2-19-00333 2019 Unit 2 Floor Drain System Activities REBT 1

71124.02 Radiation Work DR-2-19-00333 2019 Unit 2 Floor Drain System Activities 1

Permits (RWPs) DR-2-19-00548 D2R26 Dry Well Reactor Water Clean UP 1201-1 Valve 1

Repairs

71124.08 Engineering 14-210 and 14- Conformance of Energy Solutions 14-215H Cask with 4

Evaluations 215H Cask Specifications for DOT 7A, Type A Packaging

Miscellaneous14-210 and 14- Safety Analysis Report for 14-210 and 14-215 Packaging 1

215H

2019 Unit-2/3 2019 Unit-2/3 Condensate Resin Sample Validation 11/05/2019

Condensate

Resin

DAW D2R26- 2019 DAW-10CFR61 Database Analysis -2019 DAW 11/08/2019

2019 Average Ave in Radman WMG Program

FO-OP-023- Dewatering Completion Record on Liner PL8-120FR Liner 10/18/2019

161024 Serial Number 689557-19

Procedures CS-OP-PR-104 Energy Solutions; Operation of the Energy Solutions 2

Demand Advance Liquid Processing System (ALPS)

FO-OP-023- Energy Solutions: Waste Transfer and Bead Resin/Activated 3

161024 Carbon Dewatering Procedure for Energy Solutions14-215

or Smaller Liners at Dresden Station

RP-AA-602 Packaging of Radioactive Material Shipments 21

Shipping Records DM-19-021 UN2915, Radioactive Material, Type-A Package, 7; 08/20/2019

Shepherd Seal Source (A1 Special Form) in a Type-A Drum

Inspection Type Designation Description or Title Revision or

Procedure Date

to J.L. Shepherd Facility

DM-19-142 UN3321, Radioactive Material, Low Specific Activity 11/15/2019

(LSA-II), 7; to Rolls Royce Nuclear Services

DW-18-012 UN3321, Radioactive material, LSA-II, 7; U-1 Dry Active 07/25/2018

Waste (DAW) to Energy Solution's Bear Creek Facility, TN

DW-19-009 UN3321, Radioactive Material, LSA-II, 7; Unit-2/3 DAW to 03/27/2019

Energy Solution's Bear Creek Facility, TN

DW-19-019 UN3321, Radioactive Material, LSA-II, 7; Sludge from B-Max 09/06/2019

Waste to Energy Solution's Bear Creek Facility, TN

DW-19-030 UN3321, Radioactive Material, LSA-II, 7; U-2/3 DAW to 10/24/2019

Energy Solution's Bear Creek Facility, TN

71151 Corrective Action 4304564 Incorrect Calculation of Unidentified and Total Leakage Rate 12/17/2019

Documents

Corrective Action 4303649 NRC Asked Question Regarding Leakrate Reporting 12/13/2019

Documents

Resulting from

Inspection

Miscellaneous LS-AA-2090 Monthly Data Elements for NRC Reactor Coolant System 4

(RCS) Specific Activity (10/01/2018 - 09/30/2019)

Procedures DOP 2000-24, Unit Daily Surveillance Log, Attachment A 142

Appendix A

71152 Corrective Action 4156094 RB 545 Centerline Fire Door Inop 07/16/2018

Documents 4206398 U3 EDG Room Door Will Not Close and Latch on Its Own 12/28/2018

236627 ESOMS Hot Work Permit Does Not Match Att. 2 of OP-AA- 04/05/2019

201-004

258569 Declining Trend in Procedure Use & Adherence 06/21/2019

259040 Fire Door 67 Inop - Not Consistently Latching 06/24/2019

271776 Contingency Fire Hoses Staged for CO Were Out of Date 08/09/2019

273498 Trans. Combustibles Below U3 W LPCI Stairs - IEMA 08/20/2019

Identified

Inspection Type Designation Description or Title Revision or

Procedure Date

274824 IEMA ID: Issues During Walkdown in Turbine Building 08/27/2019

284652 Consider Cleaning Dirty Smoke Detectors 10/03/2019

284987 NOS ID ESOMS Hot Work Permit Does Not match 10/04/2019

284991 Independent Critique Report Not Retained 10/03/2019

292782 IEMA Questions 4kv X-tie 10/30/2019

4304700 Corp Ops ID's Adverse Trend Supp Worker Perf Fire 12/17/2019

Protection

Corrective Action 4295069 NRC ID'd Procedure Revision Required for Fire Risk 11/05/2019

Documents Procedure

Resulting from 4295218 NRC ID'd - Visible Sparks During 2A RR Pump Bowl Piping 11/06/2019

Inspection 4309162 IR Miscoded as NCAP for Potential Regulatory Impact 01/09/2020

71153 Corrective Action 4298330 High Pressure Feedwater Heater Extent of Condition 11/19/2019

Documents 4298508 IEMA Questions on 2D3 & 3D3 FWH Leak Repairs 11/18/2019

298831 NRC Request for Information 11/20/2019

298915 2D3 FWH Extraction MOV Leakby 11/21/2019

4301802 NDE-UT Results for HP FW Htr. Extent of Condition 12/05/2019

4301894 4.0 Critique for 2D3 FW Heater Restoration 11/30/2019

4302516 Leakage From Pipe Cap Downstream of 2-0220-63B/64B 12/09/2019

4304585 4.0 Critique U2 Downpower Performed 12/09/19 - 12/10/19 12/09/2019

Corrective Action 4302546 NRC - Question Regarding Visitor Control 12/09/2019

Documents

Resulting from

Inspection

Drawings 260000-001 Feedwater Heating Flow Paths 02

Procedures SY-AA-101-117 Processing and Escorting of Personnel and Vehicles 31

38